CFIA looking for comments on the use of distiller's grains as animal feed

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from the beyond factory farming mailing list:

ACTION ALERT: CFIA SEEKING INPUT ON FEED POLICY RE: ETHANOL DISTILLERS GRAINS

Deadline -April 18, 2008

1) Distillers Grain – Should livestock be fed a waste product from the ethanol manufacturing process?

The Canadian Food Inspection Agency (CFIA) has released a draft policy for applying existing feed regulations to Distillers Grain (DG) that is a by-product of the ethanol fuel production process. Since the mid-1980s DG from breweries and distilleries has been approved by the CFIA under the Feeds Regulations, Schedule IV. However, because ethanol fuel manufacturing is an industrial process, the CFIA has determined that some of the ingredients used have not been assessed for safety and may prove to be hazardous to humans, the environment and the health of animals. In spite of this uncertainty, ethanol DG is being used as livestock feed in Canada.

DEADLINE: Comments on this draft policy must be received by Friday April 18th, 2008. The draft policy is posted at http://www.inspection.gc.ca/english/anima/feebet/consult/distillerse.shtml or in French at http://www.inspection.gc.ca/francais/anima/feebet/consult/distillersf.shtml Comments may be submitted via the link on the same page or you can submit them to

John Gillmore

Science Information Specialist, Feed Section

Floor 2, Room 2321 W

59 CAMELOT DR

OTTAWA ON K1A 0Y9

Telephone: (613) 221-3927

Fax: (613) 228-6614

gillmorej@inspection.gc.ca

2) General issues

With the rapid expansion of the ethanol industry in Canada and the US (and elsewhere), it is becoming evident that no thought was placed on what to do with the waste by-product (DG). A quick google reveals that a tremendous amount of research has recently been initiated to determine the impacts of using this by-product at different percentages as feed rations in cattle, swine and poultry. The bulk of the research focuses on the health and performance of the animal as well as the characteristics of the meat. However, it is becoming clear that a number of unintended consequences can result from using DG as a feed additive.

CFIA uses a risk management approach to regulation. Instead of safeguarding against hazards, risk management allows for the weighing of risk of harm against economic benefit. Unknown and uncertain hazards are discounted as matters to be solved in the future, pending the collection and analysis of more data if deemed significant. Furthermore, those subject to being harmed by the risks are not the same as those that benefit economically, nor do they have the power to reduce their personal risk of harm resulting from such decisions.

In contrast to the risk management approach, precautionary decision-making has been summarized as follows, in the Wingspread Statement on the Precautionary Principle:

· Where an activity raises threats of harm to the environment or human health, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.

· In this context the proponent of an activity, rather than the public bears the burden of proof.

· The process of applying the Precautionary Principle must be open, informed and democratic, and must include potentially affected parties. It must also involve an examination of the full range of alternatives, including no action.

The Lowell Statement on Science and Precaution states that precautionary decision-making is consistent with sound science because of the large areas of uncertainty and even ignorance that persists in our understanding of biological systems, in the interconnectedness of organisms, and in the potential for interactive and cumulative impacts of multiple hazards.

3) Specific Impacts of using DG from fuel ethanol production in feed identified by CFIA (quotes)

* It has been determined that some of the ingredients used in the ethanol process have not been assessed for safety and require approval.

* Veterinary Drugs Directorate (VDD) requires baseline data for antimicrobial residues in DG as currently being produced, be established in order that a complete risk assessment can be conducted.

* Other drugs which were assessed and not found to be acceptable without further information or restrictions are monensin sodium and tylosin tartate.

* Based on information from submissions and inspections the enzymes and yeast that are being used are: …not food grade…produced from genetically modified organisms.

* Fermentation microorganisms and enzymes that contain a novel trait must be assessed.

* Processing aids including antifoams and boiler chemicals may be of concern as they can be recycled into the by-products that are fed to the livestock†(Chlorine dioxide, EDTA, sodium borohydride and sodium metabisulfite) These aids must be on an approved list.

* Research studies have demonstrated the potential for 2 to 4 fold concentration of mycotoxins in DG.

* Distillers grain from ethanol production may contain elevated levels of sulphur and sodium, which could cause adverse health effects in livestock if the amounts fed are not managed properly

* Phosphorus is another mineral that has the potential to concentrate in DG from corn

* Other contaminants that could potentially raise health risk considerations in feed are pesticides.

* If manufacturers wish to use ingredients that are not listed or referenced in the policy documents, a safety assessment of the ingredient will be required.

* The introduction of new ingredients, including genetically modified grains, and modernizations in the technology and process used to produce ethanol, will create new challenges.

4) Other impacts not identified by CFIA:

* Recent research at Kansas State University has found that cattle fed distiller's grain have an increased prevalence of E. coli 0157 in their hindgut which poses a health risk to humans, who can acquire it through undercooked meat, raw dairy products and produce contaminated with cattle manure. E. coli 0157 was the bacteria that killed people in Walkerton, ON.

* The potential effects of horizontal gene transfer from genetically modified organisms used through the fermentation process.

* Environmental impacts of metabolized toxic processing chemicals in the livestock manure.

5) Information deficiencies and outstanding questions

* CFIA has its own monitoring and testing program on DG derived from ethanol plants. This information has not been publicly released. The ethanol industry also has its own testing program and sends their database to CFIA.

* It is unclear as to whether DG from ethanol fed to livestock is currently legal. For example, Schedule 4 lists DG from “the distilling industry†on their approved feed list, but there is no definition of “distilling industryâ€. The genetically modified organisms used in the fermentation process, which would remain in the DG, may be considered to have “novel traits†as defined by the feed regulations, but have not been approved as feed ingredients.

* It is unclear as to whether the final policy would be used as the instrument to guide ethanol producers or if the Feeds Regulation will be amended. As a result of the federal “Smart Regulation†strategy, there is a policy to avoid creating new regulations.

* The Veterinary Drugs Directorate still requires baseline data.

* There are a number of ingredients used that need to be assessed for safety and approved.

Call for Action

We recommend that a precautionary approach be taken in this matter. Thus, there should be a moratorium placed on utilizing DG derived from the fuel ethanol production process as a feed additive for livestock.

For more information please contact Glen or Cathy at Beyond Factory Farming – www.beyondfactoryfarming.org (scroll down the right side of the home page for contact information details)

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_________________________________________

Cathy Holtslander

Beyond Factory Farming Coalition

#501 – 230 22nd Street East

Saskatoon, SK

S7K 0E9

Phone (306) 955-6454

Toll free 1-877-955-6454

Fax (306) 955-6455

www.beyondfactoryfarming.org

“Livestock production for health and social justiceâ€