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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 enhancementsminimize the risk of BSE transmission associated with the adulteration or cross-contamination of ruminant feeds during manu
2、facture and distribution and misuse of feed on farmremoving SRM from feed and fertilizer suppliescontrolling the disposal of SRMs,3,Proposed Regulations,Except in accordance with a permit issued by the Minister,no person shallremove,receive,process,use,export or destroy SRM in any form;or remove,rec
3、eive,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,t
4、hat 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 stockdoes no
5、t 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,Propose
6、d 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 b
7、een 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 dispos
8、al 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 healt
9、h 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
10、,Risk Reduction Options and Assumptions,DISPOSAL OPTIONS,ALKALINE HYDROLYSIS,Rendering reduces infectivity by 1-Log.(Ref.:AHRA,2002),GASIFICATION+INCINERATION,CONTROLLED INCINERATION,Infectivity reduction by a factor of 3-4 log over a three hour period.(Ref.:SSC,2003),RENDERING,Negligible,Controlled
11、 Incineration(temperature at 850C)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 850C.(Ref.:DNV,1997;Cummins et al.,2002),BOVINE CARCASSES AND/OR SRM,CEMENT KILN,Risk
12、Estimate,12,Risk estimate:Negligible,Containment Options and Assumptions,CENTRALIZED DISPOSAL OPTIONS,ON-FARM BURIAL,Risk estimate:Negligible to very low,ON-FARM OPTION,RELEASE:Moderate-No degradation of the BSE agent in the environmentEXPOSURE:Negligible to extremely low-Appropriate planning and si
13、te evaluation-Good systems to collect,treat and dispose of leachate-Very good compliance with regulations,RELEASE:ModerateNo degradation of the BSE agent in the environmentEXPOSURE:Extremely low to very low-Some level of non-compliance-Some proportion of carcasses improperly disposed,LANDFILL,MASS B
14、URIAL,13,RELEASE:ModerateNo degradation of the BSE agent in the environmentEXPOSURE:Negligible to lowComposting sites for cattle of all agesAppropriate planning and site evaluationVery good compliance with regulations,RELEASE:Infectivity reduction by a factor of 3-log.(Ref.:Based on similar results
15、in rendering,Taylor et al.,1994;EU)EXPOSURE:Negligible to extremely low,RELEASE:ModerateNo evidence of reduction in BSE infectivity of SRMEXPOSURE:The likelihood that secondary infections in domestic ruminant would occur is from Negligible to low,RELEASE:ModerateNo degradation of the BSE agent in th
16、e environment EXPOSURE:Negligible to smallComposting sites for cattle of all agesSome proportion of non-compliance and carcasses not properly disposed.,Other Technologies,CENTRALIZED DISPOSAL OPTIONS,MASS COMPOSTING,ON-FARM COMPOSTING,ON-FARM OPTION,Negligible to low,GASIFICATIONONLY,THERMAL HYDROLY
17、SIS,EXPOSURE:Land spreading,Risk Estimate,Negligible to moderate,Negligible,14,Categories of Disposal Options,1)Risk reduction options2)Containment options3)Other Technologies(some still under investigation),15,“Destruction”Methods,Risk reduction optionsControlled IncinerationGasification followed b
18、y IncinerationAlkaline HydrolysisCement KilnThermal Hydrolysis,16,Acceptable Containment Methods,Mass burialLandfill,17,Acceptable Containment Methods Approval/Permitting Process-Proposed,Premises receiving SRM for containmentapplication by operator of site for permit to receive SRMinspection by CFI
19、A staffsite parameters must 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.,18,Mass Composting,Worst case assumption of“no reductio
20、n in infectivity”usedcurrent 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 regulations,19,Mass Composting,
21、Mass composting facility must 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
22、 be required by recipients of compost and conditions will limit use to non agricultural applications.,20,Mass Composting Site Inspection Proposal Only,SeparationDomestic ruminants must not have contact with composting site and/or SRM on siteCompost to be covered(tarp,non-organic substrate)SignageSta
23、ting site receives SRM as per Health of Animal RegulationsCleaningEquipment to be cleaned and disinfected or dedicated to SRM composting site,21,Mass Composting Site Inspection Proposal Only,Site PreparationImpermeable base?Sloping standard as per provincial regulationRun off collection systemLeacha
24、te Control SystemCompost requires a permit to leave site,22,On-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.,23,On-Farm Composting,Due to worst case assumptio
25、n 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 approachhowever:if on farm composting of SRM is undertaken in contained areaend product is not used on land to which ruminants have access
26、Permits would be required if end product left farm,as it is still considered to be SRM.,24,Permitting Scenarios,25,Abattoir,SRM/Deads stained segregated,Deadstock on-farm vet practices/hospitals,Deadstock collectorApplies to CFIA for permit to convey SRMWill stain/tranport deads,Mass Composting Faci
27、lityApplies to CFIA for permit to receive/process SRMCFIA inspection re dedication/containment of received product and final productIssuance of permit with restrictions of end use,Golf Course?(non agri land)Applies to CFIA for permit to receive SRMInspection to ensure that it is non agriculturalIssu
28、ance of permit for receipt and application of SRM,*transport,*transport,26,Additional Information,Additional 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)495-7022,27,
