It is not clear that consumers interests will be advanced in any significant way, although it is apparent that livestock farmers will, as a result of broad coverage regulations, incur additional cost and suffer economic loss. The current regulatory approach is considered to be inefficient and costly, detecting problems after manufacturing error rather than identifying or even preventing error through process controls. Consequently, preventative process controls with enforcement through a licencing regime is proposed. The Ontario farm representatives do not oppose a stricter regime to ensure the appropriate and effective use of medication in feed. It is recognized that some restrictions on the use of medications and the production of medicated feeds are necessary for the reasons CFIA has articulated.
Process controls can be an appropriate and effective means of addressing the issue.
However, Ontario livestock producers question if the proposed approach is the best under the circumstances and, in fact, if the regulations themselves are clear, efficient, non-detrimental to the economic interests of producers and enforceable. The regulations are intended to provide a risk based strategy for animal health and food safety. The OFA and Ontario livestock producers would like to discuss further with CFIA any review of current risk exposures and the means by which risk is reduced to acceptable levels across widely varying circumstances by the proposed regulations. This review will assist in understanding the impetus for the stringent regulatory scheme proposed and may lead to the identification of more effective and efficient processes. There should be no need to include zero withdrawal products in the definition of medicating ingredients.