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1、Proposed SRM Disposal Permitting ProcessNatalie Bragg, D.V.M., M.Sc., Animal Health and Production Canadian Food Inspection AgencySRM DisposalIntent of regulatory enhancementsminimize the risk of BSE transmission associated with the adulteration or cross-contamination of ruminant feeds during manufa
2、cture and distribution and misuse of feed on farmremoving SRM from feed and fertilizer suppliescontrolling the disposal of SRMs 2 Proposed RegulationsExcept in accordance with a permit issued by the Minister, no person shallremove, receive, process, use, export or destroy SRM in any form;or remove,
3、receive, process, use, export or destroy the carcasses of cattle that died or that were condemned before slaughter for human consumption.3 Proposed RegulationsThe Minister shall not issue a permit for the destruction of SRM or carcasses unless the destruction is to be by: incineration; or another me
4、thod, 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. 4Proposed Regulations - ExemptionsPermits would not be required for on-farm disposal of SRM or dead stock
5、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、5Proposed Regulations - ExemptionsConsideration being given to exemption of SRM taken as laboratory specimens and being sent to a laboratory of appropriate biosecurity.6CFIA Working Policy on Assumed Acceptable MethodsMethods of disposal for SRM will include:Methods of treatment or containment that
7、have been assessed by CFIA science branch to present negligible to very low risk of transmission of BSE to domestic ruminants7 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 d
8、isposal 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, anim
9、al health and the environment posed by these disposal methods were considered. 8Risk EstimateThe qualitative range used in the estimation of risk reflects the uncertainties associated with the BSE agent throughout the process.BSE AGENTUNCERTAINTIES IN HAZARD AND IN EXPOSURE 9Probability Definitions1
10、0Risk Reduction Options and AssumptionsDISPOSAL OPTIONSALKALINE HYDROLYSISRendering reduces infectivity by 1-Log. (Ref.: AHRA, 2002)GASIFICATION + INCINERATIONCONTROLLED INCINERATIONInfectivity reduction by a factor of 3-4 log over a three hour period.(Ref.: SSC, 2003)RENDERINGNegligible ControlledI
11、ncineration (temperature at 850C) reduces infectivity by a factor of 105 (correction for incineration failure).Gasification+Incineration and Cementkiln processes could be compared to a controlled incineration over 850C. (Ref.: DNV, 1997; Cummins et al., 2002)BOVINE CARCASSES AND/OR SRMCEMENT KILNRis
12、k Estimate11Risk estimate: NegligibleContainment Options and AssumptionsCENTRALIZED DISPOSAL OPTIONSON-FARM BURIALRisk estimate: Negligible to very lowON-FARM OPTIONRELEASE: Moderate- No degradation of the BSE agent in the environmentEXPOSURE:Negligibletoextremelylow- Appropriate planning and site e
13、valuation- Good systems to collect, treat and dispose of leachate- Very good compliance with regulationsRELEASE: ModerateNo degradation of the BSE agent in the environmentEXPOSURE:Extremelylowtoverylow- Some level of non-compliance - Some proportion of carcasses improperly disposedLANDFILLMASS BURIA
14、L12RELEASE: ModerateNo degradation of the BSE agent in the environmentEXPOSURE:NegligibletolowComposting sites for cattle of all agesAppropriate planning and site evaluationVery good compliance with regulationsRELEASE:Infectivity reduction by a factor of 3-log. (Ref.: Based on similar results in ren
15、dering, Taylor et al., 1994; EU)EXPOSURE:NegligibletoextremelylowRELEASE:ModerateNo evidence of reduction in BSE infectivity of SRMEXPOSURE:The likelihood that secondary infections in domestic ruminant would occur is fromNegligibletolowRELEASE:ModerateNo degradation of the BSE agent in the environme
16、nt EXPOSURE:NegligibletosmallComposting sites for cattle of all agesSome proportion of non-compliance and carcasses not properly disposed. Other TechnologiesCENTRALIZED DISPOSAL OPTIONSMASS COMPOSTINGON-FARM COMPOSTINGON-FARM OPTIONNegligible to lowGASIFICATIONONLYTHERMAL HYDROLYSISEXPOSURE:Land spr
17、eadingRisk EstimateNegligible to moderateNegligible13Categories of Disposal Options1) Risk reduction options2) Containment options3) Other Technologies (some still under investigation)14“Destruction” MethodsRisk reduction optionsControlled IncinerationGasification followed by IncinerationAlkaline Hy
18、drolysisCement KilnThermal Hydrolysis15Acceptable Containment MethodsMass burialLandfill 16Acceptable Containment Methods Approval / Permitting Process - ProposedPremises receiving SRM for containmentapplication by operator of site for permit to receive SRMinspection by CFIA staffsite parameters mus
19、t be similar to those in risk assessmentPermit to receive SRM may be issued by CFIA to the operator of the siteSRM remains SRM therefore no product is allowed to move from the site unless authorized by further permits.17Mass CompostingWorst case assumption of “no reduction in infectivity” usedcurren
20、t lack of scientific dataresults in mass composting being considered as an intermediate processing of SRM, similar to rendering.Mass centralized facility vs on farmpermanent facilityoperating parameters controlled and monitoredcompliance with regulations18Mass Composting Mass composting facility mus
21、t apply for permit to receive SRM Facility will be inspected by CFIACFIA 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 issuedPermits to receive SRM will be required by recipients o
22、f compost and conditions will limit use to non agricultural applications.19Mass Composting Site Inspection Proposal OnlySeparationDomestic ruminants must not have contact with composting site and/or SRM on siteCompost to be covered (tarp, non-organic substrate)SignageStating site receives SRM as per
23、 Health of Animal RegulationsCleaningEquipment to be cleaned and disinfected or dedicated to SRM composting site 20Mass Composting Site Inspection Proposal OnlySite PreparationImpermeable base?Sloping standard as per provincial regulationRun off collection systemLeachate Control SystemCompost requir
24、es a permit to leave site21On-Farm Disposal On farm disposal of SRM is exempt from proposed CFIA permit requirements On farm burialOn farm compostingRisk estimate of BSE transmission from on farm burial is negligible. 22On-Farm CompostingDue to worst case assumption that composting does not reduce i
25、nfectivity, risk estimate of on farm composting is negligible to moderate.CFIA recommends on farm composting is not a preferred approachhowever: if on farm composting of SRM is undertaken in contained areaend product is not used on land to which ruminants have accessPermits would be required if end
26、product left farm, as it is still considered to be SRM.23Permitting Scenarios24AbattoirSRM / Deads stained segregatedDeadstock on-farm vet practices / hospitalsDeadstock collectorApplies to CFIA for permit to convey SRMWill stain / tranport deads Mass Composting FacilityApplies to CFIA for permit to
27、 receive / process SRMCFIA inspection re dedication / containment of received product and final productIssuance of permit with restrictions of end useGolf Course ? (non agri land)Applies to CFIA for permit to receive SRMInspection to ensure that it is non agriculturalIssuance of permit for receipt a
28、nd application of SRM*transport*transport25Additional InformationAdditional information regarding BSE and the proposed enhanced feed ban is available at the CFIA website:www.inspection.gc.caContact:Dr. Natalie Bragg, D.V.M., M.Sc.braggninspection.gc.caTel: (780) 495-3957 cell: (780) 499-8284Fax: (780) 495-7022 2627
