Sludge Watch ==> Canada's new legislation to try to keep BSE prions out of feed and fertilizers

[Maureen Reilly]

Sludgewatch Admin:

The Canadian Food Inspection Agency has finally passed their new strengthened provisions to prevent transmission of prion diseases. You can read the Act at the link below.


It bans  bovine Specified Risk Material (that is the BSE prionic risk bits) from cattle 30 months or older from all animal feed, pet food, and fish food. All SRMs will have to get a permit.  So if a slaughterhouse has some animal waste with SRM or some wastewater solids with SRM then those materials will need a permit...so their movement and presence in feed, fertilizer, or other disposal will be regulated by CFIA permits.  

Unfortunately the CFIA weakened the provisions they were planning when it came to fertilizer. Last year the CFIA proposed that all fertilizers needed to be registered...that way if prion risk material was in the fertilizer they would know about it.  The way the law reads now is that (bizarrely enough) fertilizers made from chemicals need to be registered (go through a thorough review by the CFIA before being brought to market). However fertilizer made from sewage sludge doesn't need ANY review from the CFIA before being sold.  Astonishing that some of the most toxic contaminated materials, known to be pathogenic and uneven in quality- get less rather than more scutiny.

Because sludge 'fertilizer' could contain SRMs the CFIA had proposed that this exemption of sludge fert from registration  would end.  Well, the industry pulled long faces and put up a howl.  Looks like they got their way.  Still no registration for sludge based fertilizer.  Instead, fertilizers containing SRMs aren't supposed to go on pasture land.  (Duh?  isn't land in crops some years and in pasture other years?...Land use changes and prions stay infectious)  So that is a fatuous approach.  Also ....'wash your hands' must appear on the label of prion risk fertilizers.  How about that for regulatory controls?  More interesting is the fact that all fertilizers that contain SRM will have to keep records of who received the material that will allow it to be traceable to the end user.  This will also collect the information necessary in the event of a recall of the material.   This will make it harder for sludge fert to escape both the federal and provincial legislation. Historically sludge based fertilizers tell the province they are making fertilizer ...so the sludge pellets are no longer covered by provincial waste permits (CofA).  And then they give away the pellets (or pay people to take them) because a) there is no market for the material..people won't pay for it, and b) the pellets are illegal for sale...since most fail to meet the quality assurance guarentees on the label.  Twenty-four percent of the sludge-fertilizer marketed in Canada failed to meet the fecal coliform limits.  Another 15% failed to meet the salmonella limits.  So much of the sludge fertilizer is quietly slipped out the back door - unregulated by any agency.  A registration requirement would have helped prevent that.  

 The new legislation doesn't ban all prionic risk material into feed or fertilizer.   Human Creutzfelt Jacob infective  tissues are not covered...for reasons I fail to understand.  Isn't human CJD prionic material as infectious to humans and to cows as bovine SRM?  The CFIA seem to have plumb forgot about all the mortuary waste and hospital wastes.  Also deer and elk prion risk materials will...astonishingly...still be allowed in pet food...which is the feed most likely to be consumed by children.   The CFIA doesn't seem to think there is a provable link between CJD and prionic risk materials from deer or elk (Chronic Wasting Disease) . By the way, composted bovine SRM materials are still considered to be SRMs and will be subject to permitting requirements for transportation and utilization. 

So bovine sources of prionic risk materials will require a permit, but human, elk, deer, sheep, etc...forms of prionic disease risk materials will not be required to get permits and will be allowed for land application as fertilizer.  Ruminant risk materials will not be allowed in ruminant feeds (as before), but non bovine ruminant risk materials will be allowed in pet food.

...........................................................................

What about the land application of wastewater sludges from facilities that processes bovine Specified Risk Materials (SRMs)?  

The new legislation requires that a slaughterhouse or rendering plant that processes SRM must have a permit from CFIA.  So in situations like the Rothsay Rendering plant in Truro Nova Scotia who spreads wastewater sludges from their plant that takes in bovine Specified Risk Material...that material will have to have a federal permit from the CFIA that will set out what can and can't be done with it.  

The new reg can be found here:
http://www.inspection.gc.ca/english/reg/appro/2006/20098_e.shtml

And a regulatory impact report
http://www.inspection.gc.ca/english/reg/appro/2006/20098ria_e.shtml

Sludgewatch Word for Today:  FATUOUS    fat.u.ous  
adjective 
Foolish or silly, especially in a smug or self-satisfied way
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