The call is coming for feed companies wanting to add “general health” products into their lineups.
The Canadian Food Inspection Agency (CFIA) and Health Canada say they will start taking applications for a pilot project — which will allow commercial livestock feed mixed with a limited list of veterinary health products (VHPs) such as organic acids or essential oils — as of March 15.
Why it matters: With antimicrobial use in livestock in the hot seat in recent years, the feed industry hopes adding VHPs to promote “general health” may help close some gaps.
The federal agencies have linked the project to conversations around reducing antimicrobial use in livestock.
It’s a push the livestock industry has become increasingly embroiled in.
Since December 2018, producers have needed a veterinarian prescription for most livestock antibiotics. The year before, the federal government released a pan-Canadian framework on AMR. Tied to that release, the government singled out Agriculture and Agri-Food Canada’s stance to encourage, “increased adoption of animal health practices that ultimately reduce the use of antimicrobials in animal production.”
Melissa Dumont, executive director of the Animal Nutrition Association of Canada, says the VHP pilot has been anticipated by their membership. ANAC is the national trade association for the livestock feed industry.
Dumont noted that VHPs have previously been approved for companion animals, non-slaughter horses and for use in top dressing and drinking water. Despite those uses, however, Canada’s rules currently do not allow for VHP use in livestock feed.
“When you’ve got 10,000 birds in a barn or a few hundred pigs, top dressing is not necessarily feasible, so we need to mix these into the diet, so this is kind of the next step of the VHP program,” Dumont said.
Nuts and bolts
The CFIA and Health Canada first announced the pilot in January of this year, along with the agency’s intention to propose Feeds Regulations changes and set the conditions for VHP use. The pilot, the agency said, would be a temporary measure, and would inform those future amendments.
The point, the agency also stressed, would be to bolster overall animal health through VHPs, not to treat any specific health condition or disease.
Companies will have to prove that their product is both safe and that there is a, “reasonable expectation of effectiveness when used as intended,” according to a late-February release from the CFIA.
Applications should also include what specific types of feed a product is suitable for and consider how manufacturing practices like pelleting might impact efficacy.
Some products, such as those already approved for use in drinking water, may also be eligible, according to the CFIA, although they would have to add in-feed instruction and dosages.
The CFIA has published a list of ingredients eligible for consideration. A total 37 active ingredients (such as citric acid, garlic, turmeric or oils from herbs like peppermint and rosemary) and 46 inactive ingredients (such as beeswax, plant oils or honey) made the cut.
“This pilot project will initially include a limited group of VHPs that present a low risk to animals, food and the feed supply,” the CFIA said in its January notice.
Should the pilot be successful, the agency added, the list may expand.
The list is restrictive, Dumont said, adding that some products may include active ingredients that have not yet made the list as well as those that have, and must therefore wait.
She also, however, described the project as a starting point only.
“We’ve got to start small and it’s a new world that Health Canada is getting into, so they need to learn about the mixing into feed and what that means,” she said. “There’s not going to be tonnes of products that are going to be coming through this pilot. I think we just need to wait and see which ones will be submitted.”
Only a limited number of products will be accepted for the pilot, the CFIA has also warned, and applications will be considered on a, “first come, first served basis.”
Companies can submit up to two products, although one product will be considered ahead of the other, “to allow for fair participation.”
Dumont expects to see a mix of newly developed and repurposed products under the program.
“There will be potentially some products that are already approved for use in feed through CFIA that we maybe want to use at a bit of a higher rate or for different purposes — have a general health claim as opposed to a feed purpose to it. So some of those products are going to be coming probably throughout the years through the VHP program. And then there’s obviously some new and exciting mixes of different products that will be available and that will be developed by these companies,” she said.
Some companies, Dumont noted, may have already developed products for use in other countries, and may now look to get them approved in Canada.
Dumont says her organization knows of five to 10 potentially interested businesses.
As to how this new avenue might impact the conversation around AMR, Dumont tagged the VHP program as one more tool in the tool box, rather than any silver bullet.
“We know that this is not a replacement,” she said. “I think we often hear people talk about replacement to antibiotics and there is no one solution replacement to antibiotics. This is just part of that tool kit that comes with management; that comes with nutrition.”
The application window is set to close April 2.
The CFIA expects to publish a list of successfully notified products under the pilot. That list is expected July 2021.
“Once products are listed in the compendium, they may be used in the manufacture of livestock feeds,” the CFIA has said. “The compendium will include information that is required on the label of livestock feeds that contain a VHP.”