Record Keeping
Under the 1997 Animal Health Protection From BSE, manufactures using animal products or by-products are required to keep certain manufacturing and sales records for a period of two years.
This requirement applies if you are making feeds for ruminants, horses, pigs, chickens, turkeys, ducks, geese, ratites or game birds. You are required to maintain records of direct distribution or sales only. Records of any further distribution and sale are the responsibility of your customer.
Enhanced Animal Health Safeguards extends record keeping requirement to 10 years
Under the Enhanced Safeguards, there are no changes to the content of the records that you are required to keep. These records include:
- The formula, including the name and weight of each ingredient, for each lot of animal feed;
- A mixing sheet showing the feed has been produced in accordance with its formula;
- Information as to whether or not the animal feed contains prohibited material;
- The date of preparation;
- Information to identify each lot of feed;
- The name and address of anyone to whom feed is sold, with a description of the feed, including the product name and quantity;
- Anyone importing from a rendering plant must also keep the name and address of the rendering plant and the date of production of the product imported.
Formulas and mixing sheets must indicate if a feed contains ruminant meat and bone meal. The purpose is to alert feed mill employees that special handling measures may be required, and for the information of the Canadian Food Inspection Agency (CFIA) inspectors. To meet this requirement, feed manufacturers may:
- include a CFIA-approved cautionary statement on mixing sheets and formulas, and/or
- clearly identify by name the source species of the meat-and-bone-meal used in the formula (e.g. porcine meal)
Options for cautionary statements on mixing sheets and formulas include:
- the full warning statement (as prescribed under the Enhanced Feed Ban);
- ``contains prohibited material``, or ``contains restricted material`` or ``contains multi-species meat meal``;
- an action statement such as ``Clean-out`` or ``Sequence/Flush``;
- any appropriate cautionary statement which clearly highlights that the product contains specific ingredients and/or that the product should not be fed to ruminants, provided this statement is approved by the CFIA Feed Section.
A “lot number” can be in any form (alpha and/or numeric characters by themselves or in combination with dates of manufacture, symbols etc.), shape or size as long as it uniquely identifies each lot of feed and the record is available and retrievable within a reasonable period of time.
Beginning July 12, 2007 the retention period for records required under the Enhanced Feed Ban has been extended to 10 years. This will apply to any records that are in your system on that date. Therefore manufacturing and sales records produced on or after February 1, 2005 in accordance with the 1997 Feed Ban should be retained for the full 10-year period.
How will CFIA use your records
The CFIA can require you to produce any of these records upon request for the purpose of examining them, making extracts, or taking copies. CFIA inspectors have the authority to examine and to obtain and take away copies of records and other documents associated with regulated activities. Inspectors are, however, directed by CFIA to not remove any original records or other documents from any premises.
As with the 1997 Animal Health Protection, electronic records are acceptable as long as they can be produced in hard copy within a reasonable time frame (i.e. by close of the next business day) and safeguard procedures are in place to protect the integrity of the records. Under the feed industry's HACCP program FeedAssure ™, it is also recommended that feed manufacturers undertake frequent, scheduled back ups of computer data as part of their electronic record keeping protocols. Records can also be stored off-site provided they can be retrieved within the required time-frame.
Once CFIA completes any review and compliance assessment is completed, CFIA inspectors are directed to retain copies of records on file with related inspection reports and other documents for a period of at least one year to facilitate reviews by supervisors for consistency and uniformity with inspection procedures and assessments of compliance.
Feed retailers and distributors subject to record keeping requirements
If you import, package, store, distribute, sell or advertise for sale, animal feed that contains animal products or by-products you are also required to keep certain sales records. Again, this requirement applies if you are handling feeds for ruminants, horses, pigs, chickens, turkeys, ducks, geese, ratites or game birds.
Under the Enhanced Safeguards, you are required to maintain records that include:
The use of a lot number to identify animal feeds is a new requirement for retailers under the Enhanced Feed Ban. In addition, under the Enhanced Feed Ban, the record retention period for these records will increase from two to 10 years. Sales records produced on or after July 12, 2005 in accordance with the 1997 Animal Health Protection should be retained for the 10-year period.
