Proposed SRM Disposal Permitting Process

1. Proposed SRM Disposal Permitting Process Natalie Bragg, D.V.M., M.Sc., Animal Health and Production Canadian Food Inspection Agency

2. SRM Disposal • Intent of regulatory enhancements • minimize the risk of BSE transmission associated with the adulteration or cross-contamination of ruminant feeds during manufacture and distribution and misuse of feed on farm • removing SRM from feed and fertilizer supplies • controlling the disposal of SRMs

3. Proposed Regulations • Except in accordance with a permit issued by the Minister, no person shall • remove, receive, process, use, export or destroy SRM in any form; • or remove, receive, process, use, export or destroy the carcasses of cattle that died or that were condemned before slaughter for human consumption.

4. Proposed Regulations • The Minister shall not issue a permit for the destruction of SRM or carcasses unless the destruction is to be by: • incineration; • or another method, that will ensure that the SRM or carcass will not be used as food for humans or animals and will not enter the environment in such a way that it could contaminate any water or food supply….

5. Proposed Regulations - Exemptions • Permits would not be required for on-farm disposal of SRM or dead stock • …does not apply in respect of specified risk material that was removed from cattle slaughtered on a farm or ranch.. Or was removed from or is contained in, the carcasses of cattle that die on a premises, if neither any of the carcasses nor any part of any of the carcasses is removed from the premises.

6. Proposed Regulations - Exemptions • Consideration being given to exemption of SRM taken as laboratory specimens and being sent to a laboratory of appropriate biosecurity.

7. CFIA Working Policy on Assumed Acceptable Methods • Methods of disposal for SRM will include: • Methods of treatment or containment that have been assessed by CFIA science branch to present negligible to very low risk of transmission of BSE to domestic ruminants

8. Scope of Disposal Risk Assessments The scope is to evaluate the risk associated with new cases of BSE arising in cattle and other domestic ruminants emanating from various disposal methods of raw and/or rendered SRM. They provide: An evaluation of risks arising from BSE via Release and Exposure pathways, in connection with domestic ruminant population only. Please note that wild animals have not been considered. Also, no other potential implications on public health, animal health and the environment posed by these disposal methods were considered.

9. Risk Estimate • The qualitative range used in the estimation of risk reflects the uncertainties associated with the BSE agent throughout the process. BSE AGENT UNCERTAINTIES IN HAZARD AND IN EXPOSURE

10. Probability Definitions

11. Risk Reduction Options and Assumptions BOVINE CARCASSES AND/OR SRM RENDERING DISPOSAL OPTIONS Rendering reduces infectivity by 1-Log. (Ref.: AHRA, 2002) CONTROLLED INCINERATION GASIFICATION + INCINERATION CEMENT KILN ALKALINE HYDROLYSIS Controlled Incineration (temperature at 850°C) reduces infectivity by a factor of 105 (correction for incineration failure). Gasification + Incineration and Cement kiln processes could be compared to a controlled incineration over 850°C. (Ref.: DNV, 1997; Cummins et al., 2002) Infectivity reduction by a factor of 3-4 log over a three hour period. (Ref.: SSC, 2003) Risk Estimate Negligible

12. Containment Options and Assumptions ON-FARM OPTION CENTRALIZED DISPOSAL OPTIONS ON-FARM BURIAL LANDFILL MASS BURIAL RELEASE: Moderate No degradation of the BSE agent in the environment EXPOSURE: Extremely low to very low - Some level of non-compliance - Some proportion of carcasses improperly disposed RELEASE: Moderate - No degradation of the BSE agent in the environment EXPOSURE: Negligible to extremely low - Appropriate planning and site evaluation - Good systems to collect, treat and dispose of leachate - Very good compliance with regulations Risk estimate: Negligible to very low Risk estimate: Negligible

13. ON-FARM OPTION CENTRALIZED DISPOSAL OPTIONS Other Technologies ON-FARM COMPOSTING MASS COMPOSTING GASIFICATION ONLY THERMAL HYDROLYSIS RELEASE: Moderate No degradation of the BSE agent in the environment EXPOSURE: Negligible to small Composting sites for cattle of all ages Some proportion of non-compliance and carcasses not properly disposed. RELEASE:Moderate No degradation of the BSE agent in the environment EXPOSURE: Negligible to low Composting sites for cattle of all ages Appropriate planning and site evaluation Very good compliance with regulations RELEASE: Moderate No evidence of reduction in BSE infectivity of SRM EXPOSURE: The likelihood that secondary infections in domestic ruminant would occur is from Negligible to low RELEASE: Infectivity reduction by a factor of 3-log. (Ref.: Based on similar results in rendering, Taylor et al., 1994; EU) EXPOSURE: Negligible to extremely low EXPOSURE:Land spreading Risk Estimate Negligible to moderate Negligible Negligible to low

14. Categories of Disposal Options 1)Risk reduction options 2) Containment options 3) Other Technologies (some still under investigation)

15. “Destruction” Methods • Risk reduction options • Controlled Incineration • Gasification followed by Incineration • Alkaline Hydrolysis • Cement Kiln • Thermal Hydrolysis

16. Acceptable Containment Methods • Mass burial • Landfill

17. Acceptable Containment Methods Approval / Permitting Process - Proposed • Premises receiving SRM for containment • application by operator of site for permit to receive SRM • inspection by CFIA staff • site parameters must be similar to those in risk assessment • Permit to receive SRM may be issued by CFIA to the operator of the site • SRM remains SRM – therefore no product is allowed to move from the site unless authorized by further permits.

18. Mass Composting • Worst case assumption of “no reduction in infectivity” used • current lack of scientific data • results in mass composting being considered as an intermediate processing of SRM, similar to rendering. • Mass centralized facility vs on farm • permanent facility • operating parameters controlled and monitored • compliance with regulations

19. Mass Composting • Mass composting facility must apply for permit to receive SRM • Facility will be inspected by CFIA • CFIA will have to satisfied that the facility can adequately contain the product received and the product leaving the facility • Permit to receive and to process SRM may be issued • Permits to receive SRM will be required by recipients of compost and conditions will limit use to non agricultural applications.

20. Mass Composting – Site Inspection – Proposal Only • Separation • Domestic ruminants must not have contact with composting site and/or SRM on site • Compost to be covered (tarp, non-organic substrate) • Signage • Stating site receives SRM as per Health of Animal Regulations • Cleaning • Equipment to be cleaned and disinfected or dedicated to SRM composting site

21. Mass Composting – Site Inspection – Proposal Only • Site Preparation • Impermeable base?? • Sloping standard as per provincial regulation • Run off collection system • Leachate Control System • Compost requires a permit to leave site

22. On-Farm Disposal • On farm disposal of SRM is exempt from proposed CFIA permit requirements • On farm burial • On farm composting • Risk estimate of BSE transmission from on farm burial is negligible.

23. On-Farm Composting • Due to worst case assumption that composting does not reduce infectivity, risk estimate of on farm composting is negligible to moderate. • CFIA recommends • on farm composting is not a preferred approach • however: if on farm composting of SRM is undertaken in contained area • end product is not used on land to which ruminants have access • Permits would be required if end product left farm, as it is still considered to be SRM.

24. Permitting Scenarios

25. Deadstock on-farm vet practices / hospitals SRM / Deads stained segregated Abattoir • Deadstock collector • Applies to CFIA for permit to convey SRM • Will stain / tranport deads *transport • Mass Composting Facility • Applies to CFIA for permit to receive / process SRM • CFIA inspection re dedication / containment of received product and final product • Issuance of permit with restrictions of end use *transport • Golf Course ? (non agri land) • Applies to CFIA for permit to receive SRM • Inspection to ensure that it is non agricultural • Issuance of permit for receipt and application of SRM

26. Additional Information • Additional information regarding BSE and the proposed enhanced feed ban is available at the CFIA website: • www.inspection.gc.ca • Contact: Dr. Natalie Bragg, D.V.M., M.Sc. braggn@inspection.gc.ca Tel: (780) 495-3957 cell: (780) 499-8284 Fax: (780) 495-7022