Clarification on application of Table 4 to veterinary prescription feeds

In May 2016, CFIA released a memorandum on “Regulatory authorities related to application of Table 4 to veterinary prescription feeds”. The memorandum was published in response to multiple inspectors requesting clarification on whether feeds manufactured under a veterinary prescription are required to meet Table 4 guarantees for nutrients. This question is of particular interest in Quebec where all medicated feeds require a veterinary prescription. The memorandum from CFIA confirms that veterinary prescription feeds are not subject to Table 4 limits provided the following conditions are met:

 1)     The medication is added at a level or for a species that is not indicated in the Compendium of Medicating Ingredient Brochures (CMIB). If the prescription meets all CMIB requirements, it is not a veterinary prescription in the context of feed federal regulations and thus it would be subject to Table 4 requirements.

 2)     The exemption is only granted to medicated feeds prescribed by veterinarians in accordance with the first point above. Thus a non-medicated feed prescribed by a veterinarian would not be exempt from Table 4 requirements or, potentially, registration.

 3)     The feed modified by the veterinary prescription should be a pre-existing single ingredient or mixed feed meeting regulatory requirements. For example, the veterinarian is modifying with a medication in an off label manner, either a pre-existing customer formula or floor stock feed.

 4)     Being a feed, it is labelled in accordance with the requirements of a veterinary prescription feed as identified in Section 26 of the Feed Regulations, which includes an accurate statement of guaranteed analysis for the feed.

 5)     If a specific nutrient is being prescribed by a veterinarian at levels outside Table 4, the source of the nutrient must be a DIN source.

Tuesday, February 28, 2017