Livestock feeds: Record keeping and traceability requirements

Introduction

Under the Feeds Regulations, 2024, most feed establishments are required to keep documents related to traceability and maintain various records related to the livestock feeds they manufacture, store, package, label, sell/distribute, import and export. There are additional record-keeping requirements for animal food in the Health of Animals Regulations.

For regulated parties, maintaining accurate records of livestock feeds ensures traceability and supports the implementation and effectiveness of a preventive control plan (PCP). A good record keeping system will simplify the retrieval of records when they are needed and is a foundational piece of a complete written PCP.

Accurate records enable us to conduct effective feed safety investigations, trace potential issues and take enforcement actions if necessary. In the event of a recall, lot numbers and detailed records allows us to communicate risks to the public efficiently and ensure that any health hazards are promptly addressed.

Purpose

This document provides information about the record keeping requirements under the Feeds Regulations, 2024. This includes:

manufacturing records
traceability records
documenting your PCP
records to support the implementation of a PCP

Information on records that must be kept under the Health of Animals Regulations for animal food can be found in RG-5 Regulatory Guidance: The Enhanced Feed Ban Statement, Lot Numbers and Record Retention for Animal Food, Labels and Documentation.

Roles and responsibilities

Stakeholders that conduct livestock feed-related activities are responsible for complying with the applicable requirements in the Feeds Regulations, 2024. They must demonstrate compliance by ensuring that feeds and processes employed at their establishments meet all regulatory requirements.

We verify the compliance of a feed business by conducting activities that include inspection and surveillance. When a non-compliance is identified, we take appropriate compliance and enforcement actions.

Records

A record is a type of document that permanently captures information demonstrating that an action was taken. It can be in either hard copy (printed) or electronic (digital) format. The information can take various forms such as text, figures, graphics, data pictures and videos.

Accurate record keeping is essential to the implementation of a written PCP. Records enable you to confirm easily and with confidence that your preventive control plan is implemented and working effectively. Records can also help you improve your PCP by providing a means for you to, for example:

identify the root cause of an issue
analyze and improve a process or procedure
identify gaps in training and in training needs

The records you keep will be unique to your feed establishment(s) depending on the size of your operation, the livestock feeds you manufacture, store, label, package, sell, export and/or import and the design of your PCP. Some examples of records include:

observations or measurements taken to monitor a critical control point in relation to its critical limit (such as time and temperature readings) and other processing-related records
ingredients, raw materials, finished feeds
equipment calibration logs
personnel training records
incident reports (such as for broken glass, chemical spills or biological contamination)
corrective action records
verification procedure records

The following practices help ensure hard copies and electronic records are complete, useful and accurate:

the recorded information is legible, permanent and accurately reflects the actual event, condition or activity
each entry on a record is made by the responsible person at the time that the specific event occurred
the completed records include the date and identify the responsible person
for numerical recordings, the unit of measure is indicated

Electronically generated records

To ensure the integrity and authenticity of electronically generated monitoring data, an electronic recording and data storage system should:

be validated to ensure its accuracy, reliability and consistency
detect invalid or altered records
generate copies of records in a readable format
protect records for accurate and timely retrieval throughout their retention period
- this may include systems to maintain appropriate backup records
  Note: a backup record could be a copy of the electronic record kept in another location
create an audit trail by independently recording the date and time of operator entries and actions that create, modify or delete electronic records
- record changes should not obscure previously recorded information
limit system access to authorized and trained individuals
have a frequency of recording data at a rate that ensures any process deviations will be captured
- if the memory storage fails or is removed or reaches its maximum storage capacity, the electronic recorder should automatically recognize this event, log it and trigger the necessary actions to preclude unsafe/unmonitored operations
have up-to-date technical documentation for the operation and maintenance of the recording system
be power protected to minimize the risk of data loss in the case of a power outage
transfer data to another system (if applicable) without modifying the information

Record keeping procedures

Record keeping procedures are considered a best practice to help you manage your records but are not regulatory requirement.

Record keeping procedures:

identify the current record version to be used and its location
provide instructions on how to fill out the record (who, what, how and when)
identify where completed records are kept
specify how long records must be kept
include measures to protect the integrity and authenticity of records during the retention period
include instructions on how to maintain and store change logs when an update or change is made to your procedures

Lot numbers

Lot numbers (or identification codes) are crucial for ensuring the traceability of livestock feed. We use lot numbers during feed safety investigations. If a lot is deemed a risk to human or animal health or the environment, we will issue a recall notice and use the lot code to communicate the risk to the public.

Manufacturers are responsible for defining what constitutes a lot for their products. Lot numbers are mandatory for livestock feeds and all feeds classified as animal food under the Health of Animals Regulations.

For bulk feeds, a "lot" can be a single batch or multiple batches that comprise an order, each identified by a lot number. For bulk ingredients, such as mixed animal meat and bone meal, a day's production typically constitutes 1 lot. However, manufacturers may determine an appropriate lot size based on their business practices.

Manufacturers should consider that if an issue is identified with a feed, the entire lot may be subject to enforcement actions.

Traceability

The purpose of traceability is to track the movement of livestock feeds (single ingredient feeds (SIF) and mixed feeds), 1 step back and 1 step forward. You must be able to identify where you sourced your material (1 step back) and to whom you provided your product (1 step forward). You must prepare, keep and maintain traceability documents related to livestock feed that you provide to another person.

If you provide a SIF to another person, the following information must be included in the traceability documents:

name of the SIF
identification code (commonly referred to as the lot number) of the SIF
name and address of the person who manufactured the SIF or caused it to be manufactured
name and address of the person who provided the SIF to you and the date which it was provided (if applicable)
name and address of the person who received the SIF from you and the date which it was provided

If you provide a mixed feed to another person, the following information must be included in the traceability documents:

name of the mixed feed
identification code (commonly referred to as the lot number) of the mixed feed
name and address of the person who manufactured the mixed feed or caused it to be manufactured
name of any SIF, any medicating ingredient referred to in the Compendium of Medicating Ingredient Brochures (CMIB), any pest control product, any non-feed product referred to in the Compendium of Non-Feed Products (CNFP) or any other feed (for example, a premix) used to make the final mixed feed; the name and address of the person who provided it to you and the date on which you received it
name and address of the person who provided the mixed feed to you and the date which it was provided (if applicable)
name and address of the person who received the mixed feed from you and the date which it was provided

The requirement to keep distribution records (who you provided feed to) applies to both the transfer of feeds between commercial feed businesses and retail sales. However, the documents are not required to contain the identification code in the case of a feed sold at retail.

In addition, the requirement to keep traceability documents does not apply for complete feeds and supplements in packages of 25 kilograms or less intended for horses; and treats intended for any livestock species.

End users of feeds (farmers) are not required by the Feeds Regulations, 2024 to keep records of who they received their feed from. However, under the Health of Animals Act and the Health of Animals Regulations farmers and other feed businesses may be required to keep certain records and they need to verify the list of those records and the correct retention times for those records, if applicable.

Distribution records (the step forward part of traceability) are required for any animal food as defined under the Health of Animals Act and the Health of Animals Regulations and these distribution records must be kept for 10 years. In some cases, the livestock feeds mentioned previously may meet the definition for animal food and therefore would no longer be exempt from not having distribution records and those records being kept for 10 years as required by the Health of Animals Regulations. Feed establishments must ensure they are familiar with the record retention periods in various legislation, if applicable, as the longer retention time must be chosen.

Prescribed documents to support traceability under the Feeds Regulations, 2024 must be kept for at least 2 years, be accessible in Canada and be provided to us upon request. However, if those same records are applicable to the Health of Animals Act and the Health of Animals Regulations or any other regulation a different retention period may apply. The longer retention time must be chosen.

Additional records

Additional record keeping requirements for livestock feeds are outlined in other sections of the Feeds Regulations, 2024.

Records – Manufacturing of livestock feeds (section 64)

Certain records must be kept related to the manufacturing of livestock feeds and are dependent on the types of livestock feeds being manufactured.

SIF

If a feed establishment manufactures a SIF, documents must be kept that include the name of the SIF, lot number, date of manufacture, quantity manufactured and a copy of any mix formula.

Mixed feeds

If a feed establishment manufactures a mixed feed, copies of the mix sheet and mix formula must be kept. Copies of the written orders that are signed by the purchaser or veterinary prescription are also required for feed establishments that manufacture a customer formula feed or custom medicated feed, respectively.

These records must be kept for at least 2 years from the last date of manufacture of the livestock feed, be accessible in Canada and be provided to us upon request.

Records – PCP (section 60)

Written copies of the PCP must be kept for a period of 2 years following the last day the plan ceases to be implemented. Examples of documents to be included are:

preventive controls
identification and evaluation of hazards (hazard analysis)
identification and evaluation of control measures implemented and the evidence that they are effective
critical control point documentation, including critical limits
monitoring and corrective action procedures
verification procedures and supporting documents
operational procedures and records used to implement the PCP
measures describing how other relevant regulatory requirements are being met

Supporting documents used and produced during the development of the PCP and documents that demonstrate that the PCP has been implemented (such as production records, staff training and effectiveness verification of the PCP) must be kept for 2 years from the date they were prepared.

The PCP must be reviewed at a frequency appropriate to the feed establishment and revised as necessary. Records related to the reassessment of the PCP also need to be maintained when:

something is new or has changed (for example, type of livestock feeds manufactured, ingredients or incoming materials, formulations, equipment, processing steps, etc.)
a problem has been identified (for example, deficiency or deviation observed during monitoring or verification procedures, non-compliance identified by the us or third-party auditors, customer complaints that reveal a problem with the PCP, recalls, unsatisfactory laboratory results, etc.)

Reassessing the PCP includes reviewing records and conducting on-site assessments of all preventive controls. It is important that changes or updates made to your PCP are precisely and clearly logged.

Maintaining change logs for a PCP is essential for several reasons. Change logs:

ensure traceability by tracking modifications, which is crucial for identifying the origin of any issues and maintaining accountability
provide evidence of compliance with regulatory standards during audits and inspections, demonstrating adherence to regulatory requirements
support quality control by monitoring the impact of changes on feed quality and safety, thereby maintaining consistent product standards
play a vital role in risk management by enabling the assessment of risks associated with each modification, helping to mitigate potential hazards
detailed records of changes facilitate continuous improvement by allowing the feed establishment to analyze the effectiveness of different strategies and make informed decisions for future enhancements

Change logs must be kept for 2 years according to the Feeds Regulations, 2024, unless other laws (like the Health of Animals Act) require a longer period. Instead of creating a new version of the PCP (Product Control Plan) every time it changes, you can keep 1 current copy of the PCP with a list of changes or a change log. This change log should show exactly what was changed, with both the old and new wording. If you only list which sections were changed without showing the actual wording or if you only describe what changed without showing the actual changes, that won't meet the requirements.

Request for documents

Records, including traceability documentation, may be requested and reviewed during routine inspection activities.

In addition, section 72 stipulates that if there is an event where there are reasonable grounds to believe there is a risk of harm to human or animal health or the environment, traceability related documents may be requested from anyone required to keep them. These documents generally must be provided within 24 hours unless additional time is granted. This is to ensure information is provided in a timely manner when responding to feed safety investigations and feed recalls.

Record-keeping information for specific feed establishments

On-farm feed mills

You are required to keep records of the medicated feeds you manufacture (mix) and any incoming starting materials, mixed feeds or SIFs used in those livestock feeds. This includes the mix sheet and mix formula for all medicated feeds that you manufacture as well as any copies of veterinary prescriptions. In addition, you will need to keep a copy of your PCP and any records to support the implementation of your plan.

Feed exporters

You are required to keep records of the feeds you export. This includes details of when you exported your feed. In addition, you are required to keep records of the incoming materials, SIFs and mixed feeds you use and where they came from, for your feeds you intend to export. The records must include the name of the feed, the lot number, the date and contact information.

Feed importers

You are required to keep records of the livestock feeds you import for sale, including when and where they came from, as well as to whom you ship or sell the feed. The records must include the name of the feed, the lot number, the date and contact information.

The record keeping requirements for mix formulas and mix sheets do not apply to manufacturers outside of Canada. However, section 67 mandates that anyone importing feed for sale must demonstrate that the feed has been manufactured, stored, packaged and labeled under conditions that provide at least the same level of protection as those applicable to feeds manufactured in Canada. To meet this requirement, importers may need to provide documents that verify these conditions.

This section is outcome based which allows flexibility in how importers will meet this requirement, however audits of the foreign manufacturers' documentation may be considered good practice.

Mixed feed manufacturers

You are required to keep records of the feeds you manufacture and sell. This includes the mixing sheet and mix formula for all mixed feeds that you manufacture as well as any copies of written orders that are signed by the purchaser and veterinary prescriptions. In addition, you are required to keep records (related to traceability) of the incoming ingredients and mixed feeds you use and where they came from, as well as who you ship or sell the feed to. The records must include the name of the feed, the lot number, the date and contact information.

Feed retail outlets

You are required to keep records of the feeds you receive and sell. In addition, you are required to keep records (related to traceability) of the feeds you received which must indicated from whom they came and for feeds that are sold, to who they were sold. The records must include the name of the feed, the date and contact information.

SIF manufacturers

You are required to keep records of the SIFs you manufacture and sell. This includes any mix formulas and documents containing the name of the feed, the lot number, date of manufacture and quantity manufactured. In addition, you are required to keep records (related to traceability) of the incoming ingredients you used and where they came from, as well as who you ship or sold the SIFs to. The records must include the name of the feed, the lot number, the date and contact information.

Record keeping timelines

Requirements for retaining records related to activities that you may perform as an individual or feed establishment may fall under the authority of multiple acts and regulations. Records that are required under the Feeds Act and the Feeds Regulations, 2024 must be kept for 2 years. Records that are required under the Health of Animals Act and the Health of Animals Regulations for animal food must be kept for 10 years. You must ensure you are familiar with the record retention periods in various legislation as needed as the longer retention time has to be chosen.

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