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On this page
- Introduction
- About the consultation
- What we heard
- Next steps
- Appendix I – Proposed maximum nutrient values in horse feeds
Introduction
The Canadian Food Inspection Agency (CFIA) has embarked on a comprehensive change agenda to strengthen its foundation of legislation, regulatory programs and inspection delivery. These directions set the context for the renewal of the Feeds Regulations, 1983 (the regulations).
The goal of modernizing the regulations is to reduce the compliance burden and support innovation, while ensuring feeds are safe and contribute to the production and maintenance of healthy livestock and safe foods of animal origin that do not pose a significant risk to the environment. The modernization of the regulations is being designed to benefit the collective Canadian feed industry, which includes livestock producers, commercial feed manufacturers, retailers, importers, exporters, ingredient manufacturers, and food processors. As well as aligning with other international feed regulatory regimes, modernization also maintains the objective of enhancing animal health and food safety for the Canadian public.
The oversight of maximum nutrient values in feeds is just one aspect of the regulations that is being reviewed as part of the comprehensive modernization project. Table 4 of Schedule I was created and incorporated into the Feeds Regulations, 1983 in the 1980s as a mechanism to exempt certain groups of feeds from registration. Currently, if a complete feed provides nutrients that fall within the ranges listed in Table 4, or a supplement has directions for use that would result in a complete feed that provides nutrients that fall within the Table 4 ranges, the feed can be exempted from registration. Feeds that provide nutrients that fall outside the ranges listed in Table 4, and that do not meet any additional exemption criteria, require assessment and registration by the CFIA prior to manufacture and sale.
The values in Table 4 no longer have the same nutritional relevancy that they did when the table was first introduced. Stakeholders have indicated that they feel Table 4 prevents innovation for new feed products; however, many of the maximum nutrient limits that are currently set in Table 4 have health and safety implications that must be considered.
The CFIA undertook a consultation from July 10, 2018 to August 17, 2018 on a proposal to identify maximum nutrient values in horse feeds to identify maximum nutrient values in horse feeds. It was also proposed that Table 4 be removed from the regulations and no longer serve as a trigger for registration of feeds based on specified ranges of nutrient content. Finally, the proposal indicated that these maximum nutrient values would be included in a document to be incorporated by reference in the regulations to allow the flexibility to amend the lists in a timely manner, as necessary.
This report consolidates and summarizes the comments received on the maximum nutrient values in horse feed proposal and the CFIA's response to those comments.
The CFIA would like to thank everyone who participated in the consultation for contributing their time to the consultation process and sharing their views.
About the consultation
The primary mode of consultation involved the preparation and posting of the Proposal – Maximum Nutrient Values in Horse Feeds on the CFIA website, and outreach directly to industry stakeholders, government partners, and CFIA staff. 6 sets of written comments were received.
What we heard
- Respondent profile
- Key respondent messages
- Feedback on the proposed maximum nutrient values in horse feeds
Respondent profile
| Category of respondent | Distribution |
|---|---|
| Feed industry – individual | 2 |
| Feed industry – association | 2 |
| Livestock producer – individual | 1 |
| Livestock producer – association | 0 |
| Other feed inputs | 0 |
| Government (Canadian federal/provincial) | 1 |
| Total | 6 |
Comments were received from feed industry associations that represent Canadian commercial feed manufacturers, and from individuals within the feed industry. The Canadian feed manufacturers associations represent 90% of commercial feed manufactured in Canada. A response was also received from a colleague at the CFIA.
Key respondent messages
While stakeholders provided suggestions for improvement regarding the proposed maximum nutrient values in horse feeds, the CFIA did not receive any comment indicating an outright disagreement with the proposed regulatory approach.
Respondents indicated they agreed with the concept of discontinuing the use of Table 4 as a means of exempting feeds from registration; however, they also raised some concerns regarding the proposal, including:
- forage intake values and horse classes/production phases
- regional and seasonal variability of nutrient levels in forages; high levels of some nutrients in forages; and lack of data on nutrient levels in forages
- some of the proposed maximum nutrient values were not appropriate
- determining compliance for maximum nutrients values based on total diet
A more detailed discussion on these concerns and the CFIA's responses follows below.
Feedback on the proposed maximum nutrient values in horse feeds
- Scope of the proposal
- Horse classes and average intakes
- Macrominerals
- Trace minerals
- Vitamins
- Additional respondent feedback
Scope of the proposal
The scope of the proposal included:
- determining those nutrient values that may impact the health and safety of the respective livestock, humans, and environment
- determining those nutrient values that support a nutritional purpose as opposed to a therapeutic purpose; and
- determining those nutrient values that may produce residues in the resulting food that could be harmful to those consuming the products
2 respondents commented on the stated scope of this proposal. All respondents provided positive support for the replacement of, or at least changes to, Table 4 values with scientific-based nutrient values, and understood that changes to Table 4 would increase the number of feeds that would not require registration.1 respondent provided a comment about how removing the minimum levels of nutrients in feeds could be problematic in determining feeds that are suitable for their intended purpose and meet the nutritional requirements if minimum nutrient values are no longer established.
In general, positive feedback and support was provided on the scope of this proposal.
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CFIA response to the scope of this proposal
As mentioned in the proposal, minimum levels for nutrients will no longer be established; however, feeds will still need to be suitable for their intended purpose, which includes meeting the minimum nutritional needs and requirements for the intended livestock species. The CFIA has focussed on setting maximum nutrient values where animal health and food safety impacts were more likely to be observed. If producers are not sure if the feed being fed to their livestock are meeting their nutritional requirements, it is suggested an animal nutritionist be consulted to ensure a well-balanced and formulated diet is being fed.
Horse classes and average intakes
The proposal included a table displaying the range of dry matter (DM) intake, and forage intake for horses. In addition, the proposed maximum nutrient values were applied to the total dietary intake. It was the intent to establish proposed maximum nutrient values on a total diet basis that were high enough to provide flexibility to formulate nutritionally sound diets while remaining safe for livestock and not resulting in food safety concerns.
No comment was provided with regards to horse classes (mature and growing) identified in the proposal and the average intakes (range of DM intake) for each horse class. However, 3 respondents provided comments regarding the percentage of forages in the total diet for horses. In addition, 2 respondents provided comments that a separate class for pregnant and lactating mares be created as this particular production class has different requirements for certain nutrients (that is, zinc).
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CFIA response to dry matter and forage intake
To clarify, the average DM and forage intakes for horses stated in the proposal do not reflect all feeding or production situations. The CFIA provided average ranges of DM and forage intakes for horses and is aware of the variations in intake associated with breed, weight, age, and varying feeding and production conditions. The table has been modified to include a footnote that the forage intake values are typical average values and may vary depending on a number of factors. The table is not intended for use as a "standard or fact" for calculations of intakes for compliance verification since production conditions differ.
The CFIA welcomes work by industry experts on the development of reference values for forages that account for seasonal and regional variability, and provide more realistic nutrient profiles for forages across Canada for nutritionists to use when formulating feeds.
The proposed modifications have been set out in the table below.
Class Range of DM intake
(% body weight)Table Note 1Forages Horses (mature and growing) 1.5 to 3.2 Up to 90% Pregnant and lactating mares 1.5 to 3.2 Up to 90% Table Note
- Table Note 1
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Note: The range of DM intakes and forage intakes on farms may be below or above these intake values.
Macrominerals
Calcium (Ca) and phosphorus (P)
3 respondents provided comments regarding the proposed maximum calcium value for horses. In all instances, respondents felt the proposed maximum calcium value was too low and should be increased. 1 comment was provided regarding the proposed maximum phosphorus value for horses and the respondent felt the proposed value was too low.
| Nutrient | Number of respondents with comments | Number in agreement with proposed values | Number not in agreement – Summary of feedback |
|---|---|---|---|
| Calcium (Ca) | 3 | 0 | 3 respondents commented that the maximum nutrient value for calcium is too low and not high enough to account for forages that contain naturally high levels of calcium. The respondents proposed a maximum nutrient value of 3% for calcium. |
| Phosphorus (P) | 1 | 0 | 1 respondent commented that the proposed maximum phosphorus value of 1% is too extreme. |
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CFIA response to the proposed maximum nutrient values for calcium and phosphorus in horse feeds
Calcium
After careful review and consideration of responses received and the suggested maximum value of calcium from all respondents, the CFIA intends to amend the maximum calcium value in horse diets to account for high calcium levels in forages (for example, alfalfa, legume forages and hay). 2 respondents provided information on the levels of certain nutrients (for example, calcium) in forages that are used typically in the horse diets. Since forages, which can make up close to 90% or more of the total diet of horses, can contain levels of calcium approaching the proposed maximum, a higher maximum calcium value of 3% total diet DM would allow for greater flexibility when formulating diets during normal feeding practices. No risk to animal health or food safety would be anticipated with the maximum nutrient value of 3% total diet DM for calcium for all horse classes.
For calcium and phosphorus, the correct ratio balance is more important than the individual nutrient content. The nutrient profile of the ingredients should be known and typical of what is available and used within the industry. In addition, having a diet that is formulated with the correct calcium to phosphorus ratio tends to mitigate toxicity. NRC 2007 states that the intakes of both calcium and phosphorus by horses must be adequate, but also the ratio of calcium to phosphorus is important and must be evaluated. If the calcium intake is less than the phosphorus intake (that is, calcium to phosphorus ratio of less than 1:1), calcium absorption may be impaired. If the diet contains an adequate amount of calcium, excessive phosphorus intake may lead to skeletal abnormalities. Although a low calcium to phosphorus ratio can result in adverse effects, ratios of calcium to phosphorus as high as 6:1 in growing horses may be acceptable if the phosphorus intake is adequate.
The proposed modification is set out in the table below.
Current
(% of complete feed, as fed)Proposed
(% of total diet DM)Revised
(% of total diet DM)2 2 3 Phosphorus
1 respondent provided a comment that the proposed maximum phosphorus value of 1% of the total diet DM was too extreme. However, no additional information was provided to support and amend the maximum nutrient value for phosphorus. Therefore, the maximum nutrient value of 1% of the total diet DM for phosphorus for horses will be maintained as identified in the proposal. The importance of balancing the calcium to phosphorus ratio was discussed above.
Magnesium, sodium, potassium, and sulfur
3 respondents provided comments regarding the proposed maximum potassium value for horses. In all instances, respondents felt the proposed maximum potassium value was too low and should be increased. No comment was provided regarding the proposed maximum magnesium, sodium, and sulfur values for horses.
| Nutrient | Number of respondents with comments | Number in agreement with proposed values | Number not in agreement – Summary of feedback |
|---|---|---|---|
| Magnesium (Mg) | 0 | 0 | 0 |
| Sodium (Na) | 0 | 0 | 0 |
| Potassium (K) | 3 | 0 | 3 respondents commented that the maximum nutrient value for potassium is too low and not high enough to account for forages that contain naturally high levels of potassium. The respondents proposed a maximum nutrient value of 5% for potassium. |
| Sulfur (S) | 0 | 0 | 0 |
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CFIA response to the proposed maximum nutrient values for magnesium, sodium, potassium, and sulfur in horse feeds
Magnesium
No comment was received concerning the maximum nutrient value of 0.8% of the total diet DM for magnesium for horses. As such, the CFIA will proceed with a maximum nutrient value of 0.8% of the total diet DM for magnesium as identified in the proposal.
Sodium
No comment was received concerning the maximum nutrient value of 2.4% of the total diet DM for sodium for horses. As such, the CFIA will proceed with a maximum nutrient value of 2.4% of the total diet DM for sodium as identified in the proposal.
Potassium
After careful review and consideration of responses received and the suggested maximum value of potassium from all respondents, the CFIA intends to amend the maximum potassium value in horse diets to account for high potassium levels in some forages, which can make up greater than 90% of the horse diet. No risk to animal health or food safety would be anticipated with the maximum nutrient value of 5% total diet DM for potassium.
The proposed modification is set out in the table below.
Current
(% of complete feed, as fed)Proposed
(% of total diet DM)Revised
(% of total diet DM)3 3 5 Sulfur
No comment was received concerning the maximum nutrient value of 0.5% of the total diet DM for sulfur for horses. As such, the CFIA will proceed with a maximum nutrient value of 0.5% of the total diet DM for sulfur as identified in the proposal.
Trace minerals
Cobalt, copper, iodine, and iron
4 respondents provided comments regarding the proposed maximum nutrient values for cobalt and that the maximum nutrient value for cobalt was too low. 4 respondents provided comments regarding the proposed maximum nutrient values for iodine with 1 respondent agreeing with the proposed maximum iodine value. 3 respondents provided comments regarding the proposed maximum nutrient values for iron and that the maximum nutrient value for iron was too low. No comment was provided regarding the proposed maximum copper value for horses.
| Nutrient | Number of respondents with comments | Number in agreement with proposed values | Number not in agreement – Summary of feedback |
|---|---|---|---|
| Cobalt (Co) | 4 | 0 |
2 respondents commented that the maximum nutrient value for cobalt is too low and should be kept at 10 mg/kg in complete feed (added) until additional information is obtained on the content of cobalt in feed. Worker safety issues for the use of cobalt and cobalt compounds in the workplace are addressed under the Workplace Hazardous Materials Information System (WHMIS) and associated regulations and should not restrict the maximum nutrient value set in feed. 1 respondent commented that the maximum nutrient value for cobalt is too low as horses are provided cobalt-iodized salt blocks that are available on pasture. 1 respondent commented that the maximum nutrient value for cobalt is too low and proposed a maximum nutrient value of 5 mg/kg of total diet DM for cobalt. |
| Copper (Cu) | 0 | 0 | 0 |
| Iodine (I) | 4 | 1 |
1 respondent commented that the maximum nutrient value for iodine is too high. 2 respondents commented that the maximum nutrient value for iodine is too low and that having a separate nutrient iodine value for pregnant and lactating mares and a separate nutrient iodine value for the other horse classes is warranted. The respondents proposed a maximum nutrient value of 10 mg/kg of the total diet DM on an "added" basis. |
| Iron (Fe) | 3 | 0 |
2 respondents commented that the maximum nutrient value for iron is too low due to high levels of iron in forages, water and minerals as well as differences and bioavailability of iron-containing compounds. The respondents proposed a maximum nutrient value of 750 mg/kg of total diet DM for iron. 1 respondent proposed a maximum nutrient value of 750 mg/kg of total diet DM for iron. |
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CFIA response to the proposed maximum nutrient values for cobalt, copper, iodine, and iron in horse feeds
Cobalt
In light of the limited data for the levels of cobalt in forages and grains, and after reviewing the information provided and considering the suggested values from all respondents, the CFIA intends to amend the proposed maximum cobalt value in horse diets to 5 mg/kg of total diet DM.
No animal or food safety issue has been shown with the increase to 5 mg/kg of total diet DM for cobalt. The maximum tolerable level (MTL) of 25 mg/kg DM intake set for cobalt for horses was derived from interspecies extrapolation (NCR 2005). The cobalt requirement for horses is 1.1 mg/day or less (NRC 2007). While the revised maximum cobalt value is below the MTL, it provides sufficient room to formulate feeds to meet the requirements of horses. It is important to note that the inclusion of supplemental cobalt in feeds in excess of the requirements is not recommended, since cobalt and cobalt compounds pose a risk to workers during mixing and feeding due to their dusting potential and presumed carcinogenicity after inhalation. Reducing unnecessary amounts being used in feeds reduces worker exposure and the associated risk. The careful handling of cobalt and cobalt compounds, especially highly concentrated sources, is recommended due to worker safety concerns.
The proposed modification is set out in the table below.
Current
(mg/kg of complete feed, as fed)Proposed
(mg/kg of total diet DM)Revised
(mg/kg of total diet DM)10 1 5 Copper
No comment was received indicating a concern with the maximum nutrient value of 125 mg/kg for copper for horses. As such, the CFIA will proceed with a maximum nutrient value of 125 mg/kg for copper as identified in the proposal.
Iodine
In light of the limited data for the levels of iodine in forages and the variable access of horses to salt blocks, and after careful review of the information provided and the consideration of the suggested values from all respondents, the CFIA intends to amend the maximum iodine value in feed for pregnant and lactating mares to 5 mg/kg of total diet DM and amend the proposed maximum iodine value in horse feed for all other classes of horses to 5 mg/kg of the total diet DM.
The proposed modification is set out in the table below.
Class Current
(mg/kg of complete feed, as fed)Proposed
(mg/kg of total diet DM)Revised
(mg/kg of total diet DM)Pregnant and lactating mares Not applicable 3 5 All other horse classes 2.5 4 5 Iron
In light of the limited data for the levels of iron in forages, and after reviewing the information provided and considering the suggested values from all respondents, the CFIA intends to amend the proposed maximum iron value in horse feed to 750 mg/kg of the total diet DM for all classes of horses. Based on the available scientific literature, horses appear to tolerate elevated levels of iron in their diets. The European Food Safety Authority concluded that the maximum authorized iron content in feeds of 750 mg/kg for other species (including horses) is safe as a provisional measure and could be maintained for horses. Additional data could be provided in the future to further modify the maximum iron value for horses.
The proposed modification is set out in the table below.
Current
(mg/kg of complete feed, as fed)Proposed
(mg/kg of total diet DM)Revised
(mg/kg of total diet DM)500 500 750
Manganese, selenium, and zinc
3 respondents provided comments regarding the proposed maximum nutrient values for manganese, selenium, and zinc for horses. In all instances, respondents felt the proposed maximum nutrient values were too low and should be increased.
| Nutrient | Number of respondents with comments | Number in agreement with proposed values | Number not in agreement – Summary of feedback |
|---|---|---|---|
| Manganese (Mn) | 3 | 0 |
1 respondent commented that the maximum manganese value is too low and proposed 300 mg/kg of total diet DM for all horse classes. 2 respondents commented that the maximum manganese value is too low and proposed 300 mg/kg of total diet DM for all horse classes. Worker safety issues for the use of manganese and manganese compounds in the workplace are addressed under the WHMIS and associated regulations and should not restrict the maximum nutrient value set in feed. |
| Selenium (Se) | 3 | 0 |
1 respondent commented that the maximum selenium value is too low and proposed 2.0 (total) mg/kg of total diet DM for all horse classes. 2 respondents commented that the maximum selenium value is too low due to the high and variable levels of selenium found in forages. The respondents expressed concerns on setting a maximum selenium value based on the "total" diet as opposed to an "added" basis and concerns with basing the maximum selenium value on food safety risks, and proposed 1.0 (added) mg/kg of total diet DM for all horse classes. |
| Zinc (Zn) | 3 | 0 |
1 respondent commented that the maximum zinc value is too low and proposed 500 mg/kg of total diet DM for pregnant mares and 400 mg/kg of total diet DM for the all other horse classes. 1 respondent commented that the maximum zinc value is too low and not high enough to account for forages that contain naturally high levels of zinc. The respondent requested that, as a minimum, a separate class be created for pregnant and lactating mares and proposed a maximum nutrient value of 400 mg/kg total diet DM. 1 respondent commented that the maximum zinc value is too low and not high enough to account for forages that contain naturally high levels of zinc. The respondent requested that, as a minimum, a separate class be created for pregnant and lactating mares and proposed a maximum nutrient value of 500 mg/kg total diet DM. |
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CFIA response to the proposed maximum nutrient value for manganese, selenium, and zinc in horse feeds
Manganese
After review of the information provided and the consideration of the suggested values from all respondents, the CFIA intends to amend the proposed maximum manganese value in horse diets to 300 mg/kg total diet DM.
No risk to animal health or food safety would be anticipated with the maximum manganese value being increased to 300 mg/kg total diet DM for horses. This value is less than the MTL of 400 mg/kg DM for horses. The requirement for manganese for horses is 900 mg/day or less (NRC 2007). While the revised maximum manganese value is below the MTL, it provides sufficient room to formulate feeds to meet the requirements of horses.
It is important to note that the inclusion of manganese in feeds in excess of the requirements is not recommended as manganese and manganese compounds pose a risk to workers during handling. Manganese compounds are considered eye irritants, and some are considered skin irritants and dermal sensitizers. The presence of nickel in manganese-containing compounds may result in contact dermatitis. It is known that exposure to manganese in dust and exposure to nickel contained in these manganese-containing compounds can pose a risk to workers and users by inhalation. Reducing unnecessary amounts being used in feeds reduces worker exposure and the associated risk.
The proposed modification is set out in the table below.
Current
(mg/kg of complete feed, as fed)Proposed
(mg/kg of total diet DM)Revised
(mg/kg of total diet DM)400 150 300 Selenium
After review of the scientific literature and consideration of the suggested values from all respondents, limited data and high variability of selenium levels in feed, the CFIA intends to maintain the proposed maximum selenium value in horse diets of 1.0 mg/kg of total diet DM.
NRC 2007 reports that a true requirement for selenium could not be determined but recommendations are 2.25 mg/day or less. This level is known to prevent deficiencies. The MTL for dietary selenium in horses is 5 mg/kg DM and was derived from interspecies extrapolation. When setting this level, only animal health was considered and lower levels are necessary to avoid excessive accumulation in edible tissues (NRC, 2005).
Feedback from stakeholders indicated that a total selenium maximum of 1 mg/kg (total) (DM) was achievable in feeds for other terrestrial livestock species. This level is more than sufficient to meet the dietary requirements for horses. In comparison, the European Union (EU) has set a total selenium level of 0.5 mg/kg of complete feed with a moisture content of 12% for all animal species. The EU maximum level limits the content of organic forms of selenium to 0.2 mg/kg. The CFIA is proposing a maximum selenium value for horse diets that is higher than the current maximum level set by the EU and aligns with the CFIA's proposed maximum selenium value of 1.0 mg/kg total diet DM for other terrestrial livestock species, including beef and dairy cattle, swine, and poultry.
Setting maximums for selenium on a total diet rather than an added selenium basis aligns with how the standards are set for all nutrients. Recent work by Environment and Climate Change Canada under the Chemical Management Plan highlights the need for risk management measures to reduce selenium releases caused or influenced by humans into water. This would include releases from agriculture, including releases from feed. A standard based on total selenium rather than added selenium limits inputs in feeds, thereby reducing agricultural releases. It also addresses the need to limit selenium transfer to foods of animal origin. The CFIA provided Health Canada's Food Directorate with data on the transfer of selenium to foods of animal origin through feed. Health Canada has indicated that 1 mg/kg total selenium in the diet should not result in selenium levels of concern in foods of animal origin. The data provided by CFIA covered studies using both organic and inorganic sources of selenium in diets and accounted for intrinsic and added selenium identified in diets.
Current
(mg/kg of complete feed, as fed)Proposed
(mg/kg of total diet DM)Revised
(mg/kg of total diet DM)No requirement specified (NRS) 1 (total) 1 Zinc
After carefully reviewing the scientific literature and information provided, and considering the high and variable levels of zinc in forages and the values suggested by all respondents, the CFIA intends to revise the proposed maximum zinc value in horse diets to 280 mg/kg total diet DM. This will provide sufficient room to meet the requirements of different classes, sizes, and activity levels of horses, including lactating and pregnant mares, which NRC 2007 indicates is less than 1000 mg/day. The revised maximum is equivalent to those proposed for beef and dairy cattle and is set lower than MTLs to address antimicrobial resistance and environmental concerns.
Current
(mg/kg of complete feed, as fed)Proposed
(mg/kg of total diet DM)Revised
(mg/kg of total diet DM)500 (all horse classes) 150 280
Vitamins
Vitamin A, vitamin D, and vitamin E
No specific comment was provided regarding the proposed maximum nutrient values for vitamin A, vitamin D, and vitamin E for horses. However, 1 respondent provided a general concern on the maximum nutrient values for vitamins being significantly decreased.
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CFIA response to the proposed maximum nutrient values for vitamin A, vitamin D, and vitamin E in horse feeds
The proposed maximum nutrient values for vitamin A and vitamin D have been lowered and a maximum nutrient value for vitamin E has been established. The proposed maximum nutrient values for vitamins A, D, and E were established based on the presumed upper safe level for vitamin A and E for horses and the EU's authorized maximum content for vitamin D3 in feeds for equines. Since no information was provided by respondents to support the current maximum nutrient values being maintained or amended to something different, CFIA will be maintaining the proposed maximum vitamin values as identified in the proposal and summarized below.
Vitamin A
No comment was received indicating a concern with the maximum nutrient value of 16,000 IU/kg of total diet DM for vitamin A for horses. As such, the CFIA will proceed with a maximum nutrient value of 16,000 IU/kg of total diet DM for vitamin A as identified in the proposal.
Vitamin D
No comment was received indicating a concern with the maximum nutrient value of 4,000 IU/kg of total diet DM for vitamin D for horses. As such, the CFIA will proceed with a maximum nutrient value of 4,000 IU/kg of total diet DM for vitamin D as identified in the proposal.
Vitamin E
After careful review of the scientific literature, current levels of vitamin E in horse feed, current feeding practices within the horse industry, and consideration of the suggested values from all respondents, the CFIA intends to maintain the current maximum vitamin E value of no maximum specified (NMS).
Class Current
(IU/day)Proposed
(IU/kg of total diet DM)Revised
(IU/kg of total diet DM)Horses (all) No requirement specified (NRS) 2,400 No maximum specified (NMS)
Additional respondent feedback
1 respondent provided comments that the proposed maximum nutrient values should be based on animal health and food safety concerns, and not environmental concerns.
1 respondent provided comments with regards to the labelling of feeds with specific nutrient guarantees to help with formulating well-balanced nutritional diets and identifying that there are different nutrient requirements and tolerable levels for different production classes, as well as for different equine species.
3 respondents provided concerns on how CFIA inspection staff will determine compliance when maximum nutrient values are established for the total diet, and not solely established for complete feed.
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CFIA response to additional respondent feedback
Environmental considerations
The modernized regulatory framework of the Feeds Regulations has focussed on the health and safety of animals, humans and the environment. Some of the endpoints that CFIA considered when setting maximum nutrient values and maximum contaminant values were environmental concerns, in addition to human and animal health concerns. Certain minerals fed in excess of nutritional requirements for the intended livestock species can contribute to food safety concerns as well as environment concerns. Minerals fed in excess of nutritional requirements are excreted into the environment. It is important to note that even though the MTL of a given mineral may be significantly greater than the nutritional level, feeding at the MTL may result in a negative impact on the environment. The environment was considered, but was never the only consideration taken into account when setting the maximum nutrient levels.
Nutrient guarantees on feed labels
The requirement for nutrient guarantees on mixed feed labels is one aspect that is being reviewed as part of modernizing the Feeds Regulations. The CFIA consulted from June 13, 2016 to July 15, 2016 on a proposal to continue to specify nutrient guarantees that must be included on a feed label based on the intended livestock species and feed type. It was also proposed that in addition to nutrient guarantees required by the regulations, other nutrient guarantees that are truthful, verifiable, and not misleading be allowed on livestock feed labels in the future, at the discretion of the packager ("voluntary guarantees"). The Consultation Summary on Nutrient Guarantees on Feed Labels contains an Appendix with a table that outlines the mandatory nutrient guarantees for different feed types and a table that outlines voluntary guarantees. Based on the feed type, certain nutrient guarantees are required on the product label and will help formulate total diets that are safe and meet the nutrient requirements of the intended livestock species.
It is known that certain production classes for a particular species may have different nutrient requirements and certain species may have different tolerances to certain nutrients. The proposals for maximum nutrient values for livestock species have captured these differences.
Determining compliance for maximum nutrient values based on total diet
Compliance verification and enforcement of labelled nutrient guarantees for prescribed maximums would evaluate the information on the associated feeds label, including the directions for use indicating the amount of the mixed feed to be included in the total diet. The safe use of feeds is a shared responsibility. The directions for use on the labelled feed along with the guaranteed analysis, when used together, should result in values below prescribed maximums. Producers should make use of the labelled directions, as well as knowledge of the nutrient contents of other components of their animals' diets to ensure that they are feeding below the maximums. In the event that a feed has guaranteed analysis and directions for use that bring into question room for specific nutrients in forages, and in the absence of available region- or producer-specific forage data from the feed mill or from a particular producer, the CFIA may consider NRC values for forages. If there is specific forage data from a producer or feed mill that better represents the region or particular feeding program, this can be provided to a CFIA inspector and used. This should allow for greater flexibility across the country to account for geographic difference in forages, and even in cases where mixtures of forages are being used.
As these proposed maximums would be included in a document to be incorporated by reference in the regulations, the values may be adjusted from time to time to keep up with science and new production technologies. Over formulating nutrients in feeds with respect to maximums is a hazard and feed mills would be expected to have preventive controls in place to avoid this. These controls might include such things as nutrient testing and purchase agreements so as to know the nutrient contents of inputs as well as knowledge of the needs of producers they are servicing. Nutrient maximums are not targets to reach when formulating feeds; rather, feeds should be formulated to meet the nutrient requirements of livestock for whom they are intended.
Next steps
The CFIA is preparing a formal regulatory proposal for publication in the Canada Gazette, Part I, which will incorporate the comments received on all the consultation proposals, public meetings, stakeholder workshops and submissions, and other outreach activities that have been used over the course of the project. A draft of the Maximum Nutrient Values in Horse Feeds will be available for public review and comment at the time of the Canada Gazette publication.
Appendix I – Proposed maximum nutrient values in horse feeds
Horse classes and average intakes: Dry matter (DM) basis
| Class | Range of DM intake (% body weight)Table Note 2 |
Forages |
|---|---|---|
| Horses (mature and growing) | 1.5 to 3.2Table Note 2 | Up to 90%Table Note 2 |
| Pregnant and lactating mares | 1.5 to 3.2Table Note 2 | Up to 90%Table Note 2 |
Table Note
- Table Note 2
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Note: The range of DM intakes and forage intakes on farms may be below or above these intake values.
Macrominerals
| Class | Proposed (% of the total diet DM) |
Revised (% of the total diet DM) |
|---|---|---|
| Horse (All) | 2 | 3 |
| Class | Proposed (% of the total diet DM) |
Revised (% of the total diet DM) |
|---|---|---|
| Horse (all) | 1 | 1 |
| Class | Proposed (% of the total diet DM) |
Revised (% of the total diet DM) |
|---|---|---|
| Horse (All) | 0.8 | 0.8 |
| Class | Proposed (% of the total diet DM) |
Revised (% of the total diet DM) |
|---|---|---|
| Horse (All) | 2.4 | 2.4 |
| Class | Proposed (% of the total diet DM) |
Revised (% of the total diet DM) |
|---|---|---|
| Horse (All) | 3 | 5 |
| Class | Proposed (% of the total diet DM) |
Revised (% of the total diet DM) |
|---|---|---|
| Horse (All) | 0.5 | 0.5 |
Trace minerals
| Class | Proposed (mg/kg of total diet DM) |
Revised (mg/kg of total diet DM) |
|---|---|---|
| Horse (All) | 1 | 5 |
| Class | Proposed (mg/kg of total diet DM) |
Revised (mg/kg of total diet DM) |
|---|---|---|
| Horse (All) | 125 | 125 |
| Class | Proposed (mg/kg of total diet DM) |
Revised (mg/kg of total diet DM) |
|---|---|---|
| Pregnant and lactating mares | 3 | 5 |
| Horse (All others) | 4 | 5 |
| Class | Proposed (mg/kg of total diet DM) |
Revised (mg/kg of total diet DM) |
|---|---|---|
| Horse (All) | 500 | 750 |
| Class | Proposed (mg/kg of total diet DM) |
Revised (mg/kg of total diet DM) |
|---|---|---|
| Horse (All) | 150 | 300 |
| Class | Proposed (mg/kg of total diet DM) |
Revised (mg/kg of total diet DM) |
|---|---|---|
| Horse (All) | 1 (total) | 1 |
| Class | Proposed (mg/kg of total diet DM) |
Revised (mg/kg of total diet DM) |
|---|---|---|
| Horse (All) | 150 | 280 |
Vitamins
| Class | Proposed (IU/kg of total diet DM) |
Revised (IU/kg of total diet DM) |
|---|---|---|
| Horse (All) | 16,000 | 16,000 |
| Class | Proposed (IU/kg of total diet DM) |
Revised (IU/kg of total diet DM) |
|---|---|---|
| Horse (All) | 4,000 | 4,000 |
| Class | Proposed (IU/kg of total diet DM) |
Revised (IU/kg of total diet DM) |
|---|---|---|
| Horse (All) | 2,400 | NMS (NMS = no maximum specified) |