Incidental feed additives (IFAs) are substances used in feed manufacturing processes that have no nutritional or technical function in livestock feeds but, given their use, may become residues in feeds. Residues of IFAs may be present in a variety of single ingredient feeds (SIFs) or mixed feeds given their use in livestock feed manufacturing. Some examples include:
- boiler chemicals, where the steam comes in contact with livestock feeds, including steam used in pelleting
- processing additives used in the production of SIFs
For example, antimicrobial agents, enzymes, yeasts and chemicals used in industrial ethanol production where the by-products from the production process are then used as SIFs (for example, distillers grains) - water treatment chemicals used in rendering, feed manufacturing, and food processing plants to recover solids, where the recovered solids are then used as raw materials to produce SIFs (for example, where recovered solids are added back to inedible rendering from which meat and bone meal are produced)
- denaturants and dyes used for marking inedible and prohibited materials in meat processing and rendering
Feed manufacturers are responsible for ensuring that substances used in their establishments are safe and suitable for their intended use. This is an essential part of good manufacturing practices to prevent the contamination or adulteration of livestock feeds from these materials. Feed manufacturers are also required to meet all applicable regulatory requirements of the Feeds Act and regulations and Health of Animals Act and regulations.
Documentation pertaining to IFAs must be accessible and up to date for Canadian Food Inspection Agency (CFIA) inspectors to verify that the materials being used are compliant with all applicable regulatory requirements. Where there are reasonable doubts about the safety of any IFA products used, CFIA inspectors may request additional supporting documents with which to conduct a more in-depth review to verify that the IFA products meet all applicable regulatory requirements. If the safety assessment indicates potential feed safety issues, the CFIA will take appropriate compliance actions. Compliance actions taken will be on a case-by-case basis and will depend on the composition of the product(s) identified.
This guidance provides feed manufacturers with recommended options to demonstrate the safe use of IFAs below:
- Some non-food chemical products previously included in the Reference Listing of accepted construction materials, packaging materials and non-food chemical products and those that have a no objection letter (NOL) from Health Canada
The Reference Listing of Accepted Construction Materials, Packaging Materials and Non-food Chemical Products (otherwise known as the reference listing) is a list of items which were previously found by the CFIA to be acceptable for a specific use in food establishments.
The CFIA no longer pre-approves such materials and products. The reference listing is now available as a reference only. The last update to the listing was made in January 2016. Further, Health Canada's Bureau of Chemical Safety (BCS), on a voluntary basis, assess the safety of incidental additives that may come in direct contact with food in food processing establishments as per their Guidelines for Incidental Additive Submissions. Letters expressing acceptable BCS opinions are called "No Objection Letters" (NOLs).
The Animal Feed Program (AFP) of the CFIA does not object to the non-food chemical products on the reference listing or, with a Health Canada NOL in the following categories being used for their intended purposes in the production of livestock feeds:
- category: boiler water treatment compounds (not for food process water)
- Sub-category: boiler water treatment compounds where the treated water or the steam produced may come in contact with food products (w1)
- category: decharacterizing agents
- Sub-category: red meat (i1)
- Sub-category: white meat (i1)
- category: denaturing agents
- Sub-category: red meat (i1)
- Sub-category: white meat (i1)
As the reference listing is no longer maintained, it is recommended that feed manufacturers verify the accuracy of the following information with the manufacturer(s) of the product(s).
- the product continues to be used for the intended and previously accepted use(s) (formulation, label directions, etc.)
- the manufacturer of the product continues to support the product for this use
- category: boiler water treatment compounds (not for food process water)
- Products registered by the CFIA Animal Feed Program (AFP)
Previously, the CFIA AFP registered some products now classified as IFAs for use in various processes including:
- water treatment chemicals like flocculants, coagulants, and anti-foams used in rendering and food processing plants to recover solids, when the recovered solids are then used as raw materials to produce SIFs (for example, recovered solids are added back to inedible rendering from which meat and bone meal are produced)
The registrations of these products will lapse over time and will be transitioned by the AFP to a Letter Of No Objection (see item 3 below). Once transitioned, registration numbers should no longer appear on labels but may take some time to fully disappear from the marketplace. It has been program policy to allow product to move through the marketplace carrying the previous label for a period of 6 months. Manufacturers and sellers of livestock feeds will be given a 6 month period to use up old labels containing the registration numbers. After that time period, product offered for sale with labels containing the expired registration number would be considered as non-compliant and require relabeling.
- Letter Of No-Objection (LONO)
As per RG-1 Chapter 3 - Guidelines for Incidental Feed Additive (IFA) Data Review Applications, the CFIA the AFP evaluates, on a case-by-case basis, the acceptability of various IFA products voluntarily submitted by manufacturers wishing to supply their products to feed manufacturers. Letters expressing favorable opinions are called "Letter Of No-Objection (LONO)". The product manufacturers may then present these directly to prospective feed manufacturer customers to be included in a preventive control plan (PCP) or, if needed, provide them in support of a Letter of Guarantee. In the case where new safety information comes available that suggests that the IFA product is no longer safe for its intended use, the CFIA reserves the right to retract a previously issued LONO. It is the responsibility of industry to ensure that all LONOs on file at their establishment are current, and still valid for all applicable IFA products.
- Supplier or manufacturer Letter of Guarantee (LOG)
A Letter of Guarantee (LOG) is a document from the supplier or manufacturer of an IFA indicating that the product is safe, suitable for use and meets the specifications of the customer. The letter should contain the following information:
- name of the supplier
- date of issuance
- description of the product
- brand name or code number
- a statement that the IFA product is safe and suitable for the intended use
- a reference to the related LONO (if applicable)
- signature of the supplier
It is important to retain a LOG for any product that is not covered by items 1 to 3 above.
Since a LONO and LOG can be retracted or changed at any time, it is up to industry to ensure that the status of the letters is verified at an acceptable frequency. Where a feed establishment has preventive control plan in place, it is important to ensure that LOGs and LONOs are included in these plans.
- SIFs described in Schedule IV or V of the Feeds Regulations included in IFAs
SIFs listed in part I of Schedule IV or V of the Feeds Regulations and registered sources of part II SIFs may be used as components of an IFA product for an IFA purpose. If all the components of such an IFA are listed in part I of Schedule IV or V or are registered part II SIFs, the risk posed by the use of these products for an IFA purpose is considered negligible. IFAs containing unregistered SIFs listed in part II of Schedule IV or V or other formulating ingredients not listed in Schedule IV or V should demonstrate their acceptability by means of items 1 to 4 above.