WHEREAS the livestock industry has estimated the cost of existing Canadian Food Inspection Agency (CFIA) regulations pertaining to Specified Risk Materials (SRM) removal and traceability to be in the range of $80-$100 per animal; and

WHEREAS any expansion on existing regulations will be an unneccessary burden to producers already suffering from low livestock prices;

The greatest contribution to the confidence of producers and the slaughter industry remains public and international confidence in the safety of Canad'a beef products.  The enhanced feed ban (EFB) promotes confidence at home and abroad, and it is a major contributing factor to Canada's current status as a controlled bovine spongiform encephalopathy (BSE) risk, as determined by the World Health Organization for Animal Health (OIE).

Prior to the actual implementation of the EFB, local governments, industry, producers and stakeholders were consulted for more than a year leading up to the regulations being written.  Since August 2003, the Candian Food Inspection Agency (CGIA) has consulted widely with interested industries on proposals for and EFB, and their concerns were taken into account in the development of the enhanced regulations.  The CFIA has been, and will continue to be, flexible in its approach to meeting the objectives of the EFB.  In addition, full consideration was given to the comments received during the formal Canada Gazette comment period procedures.

The CFIA created the Industry Liaison Team (ILT) in January 2007, which includes representatives from industry sectors having a role in regard to the commercial production of ruminants and their products or by-products.  The ILT provided industry associations with a forum for discussion and resolution of industry concerns surrounding the implementation of the EFB.  The CFIA helpd regular conference calls with the ILT to support industry in its preparation to implement the EFB.

The ILT was composed of representatives from the processing, cutting, packing, rendering and feed sectors of the industry and related industry associations, as well as members of the CFIA Feed Ban Task Force.  These weekly conference calls provided a stage for issues to be brought forward, discussed and resolved, progress reports and policy changes shared, and updates communicated in a transparent and open environment.  The CFIA completed a Regulatory Impact Analysis Statement, published in the Canada Gazette, Part II, in July 2006, which explored the implementation, cost and benefits of the proposed enhanced ban.

The Canadian Meat Council (CMC) later undertook a study, in fall of 2007, to survey the costs associated with the EFB.  The results indicated that the total cost associated with the EFB on a per head basis averaged between $2.83 and $6.82 for cattle under 30 months of age and between $10.16 and $14.80 for those over 30 months of age.  The CFIA is committed to ensuring an ongoing, outcome-focused approach to achieving the EFB objectives in the most cost-effective manner.

In response to industry concerns about costs associated with EFB implementation requirements, the CFIA worked with industry and Agriculture and Agri-Food Canada to establish the EFB Preliminary Implementation Review working group in August 2007.  The implementation of many of the working group's recommendations is aimed at reducing the costs of the EFB requirements without compromising the original policy objectives.  Three of these recommendations were implemented in January 2008.  The CMC has already reorted a reduction in specified risk material (SRM) volume and, as a result, in the cost of disposal.

While the CFIA works with provinces and industry to reduce the volume of SRM, the Agency recognizes that the implementation of the EFB requirements represents an important investment in the long-term viability of the Canadian cattle sector.