Proposed SRM Disposal Permitting Process

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Proposed SRM Disposal Permitting Process

• Natalie Bragg, D.V.M., M.Sc.,
• Animal Health and Production
• Canadian Food Inspection Agency

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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

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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.

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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.

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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.

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Proposed Regulations - Exemptions

• Consideration being given to exemption of SRM
  taken as laboratory specimens and being sent to a
  laboratory of appropriate biosecurity.

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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

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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.
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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
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Probability Definitions
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Risk Reduction Options and Assumptions
BOVINE CARCASSES AND/OR SRM
DISPOSAL OPTIONS
RENDERING
ALKALINE HYDROLYSIS
Rendering reduces infectivity by 1-Log. (Ref.
AHRA, 2002)
GASIFICATION INCINERATION
CONTROLLED INCINERATION
CEMENT KILN
Infectivity reduction by a factor of 3-4 log over
a three hour period. (Ref. SSC, 2003)
Controlled Incineration (temperature at 850C)
reduces infectivity by a factor of 105
(correction for incineration failure). Gasificat
ion Incineration and Cement kiln processes
could be compared to a controlled incineration
over 850C. (Ref. DNV, 1997 Cummins et al.,
2002)
Risk Estimate
Negligible
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Containment Options and Assumptions
CENTRALIZED DISPOSAL OPTIONS
ON-FARM OPTION
ON-FARM BURIAL
LANDFILL
MASS BURIAL
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
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
Risk estimate Negligible to very low
Risk estimate Negligible
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Other Technologies
CENTRALIZED DISPOSAL OPTIONS
ON-FARM OPTION
MASS COMPOSTING
ON-FARM COMPOSTING
GASIFICATION ONLY
THERMAL HYDROLYSIS
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 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
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 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.
EXPOSURE Land spreading
Risk Estimate
Negligible to moderate
Negligible
Negligible to low
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Categories of Disposal Options
1) Risk reduction options 2) Containment
options 3) Other Technologies (some still under
investigation)
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Destruction Methods

• Risk reduction options
• Controlled Incineration
• Gasification followed by Incineration
• Alkaline Hydrolysis
• Cement Kiln
• Thermal Hydrolysis

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Acceptable Containment Methods

• Mass burial
• Landfill

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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.

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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

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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.

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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

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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

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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.

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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.

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Permitting Scenarios
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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

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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_at_inspection.gc.ca
• Tel [phone] cell [phone]
• Fax [phone]

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