Inspection fever sweeps Ontario

Mount Carmel's Van Osch Farms feels it can stand up to any scrutiny from inspectors checking up on medicated feeds and nutrient management. Not all farmers are as happy at the prospect

by DON STONEMAN

Don Glavin is in charge of mixing the feed and getting it to the cattle at Van Osch Farms, east of Mount Carmel on the border between Middlesex and Huron Counties. Altogether, 6-7,000 head fatten at a time in six feeding yards. According to the Canadian Food Inspection Agency (CFIA), Glavin is doing an exemplary job.

In 2001, the CFIA performed a "pre-pilot project" testing proposed new medicated feed regulations on 10 farms across the country. Only a few of the farms passed all the tests, and Van Osch Farms was one of them. Sooner or later, Glavin will hold a license to manufacture livestock feeds containing medications and will be subject to inspection at any time. So will anyone else running an on-farm feed mill which mixes medication into feeds in a premix or even supplement form.

Canada currently regulates medicated feeds, but on a product basis, says Ray Perron, a CFIA feed evaluation specialist. "You deal with anything that's wrong (with a feed) after it's manufactured," he says. The new regulations specify how these feeds will be made. "If they are made properly," Perron says, "chances are you will end up with a good product."

Inspectors will test how well the feed mills work. Producing these feedings will require licensing. And with licensing comes a new level of inspection.

Many Ontario's farmers are concerned about increased government scrutiny. The proposed nutrient management regulations that swept through farm complacency like an avalanche this winter have put producers on edge about inspections in general.

Ontario Federation of Agriculture president Ron Bonnett hears reports of "aggressive" inspections by Ministry of Natural Resources officers in the deer and elk industries and also by Ministry of Environment (MOE) officers in horticultural production. In both cases, Bonnett says, "there doesn't seem to be a lot of consistency. While there may be one policy across the province, there seem to be problems with implementation."

The apparent inconsistencies in application of regulations worries Bonnett. "We're going to have to make sure that farmers know what rights they have under regulations. We're are still working our way through that one."

Bonnett says that, in late January, he secured an agreement from provincial environment minister Chris Stockwell that an inter-ministerial protocol will be developed for nutrient management regulations. The agriculture ministry staff will be called first when "minor infractions" are investigated. "What everyone is worried about is that the MOE will come stomping onto the farm property with their ticket books out."

Spot checks of pesticide storages

The MOE's nutrient management officers are still in training; other inspectors are sometimes active and visiting farms. Last September, inspectors were targeting horticultural and greenhouse operators in the Niagara Peninsula. Growers won't talk publicly, says Mary Lou Garr, a local federation of agriculture director and chairman of Agricultural Groups Concerned About Resources and the Environment (AgCare). "No one wants to irritate the good folks at the MOE."

The targets of the spot inspections were crop-protection products that had been withdrawn by the manufacturer. They aren't supposed to be in the pesticide storage, Garr says. She doesn't know how farmers are supposed to know that a product has been withdrawn and it is a particular problem for growers who use a very small amount of a product in a season and store the leftovers.

Nevertheless, Garr points out, farmers must comply with inspectors who demand to check their storages. She says this demonstrates that "we have to find a way to work with the ministry of environment...They must understand our farm operations and demonstrate a little courtesy," especially where bio-security is an issue.

As far as nutrient management planning is concerned, "the good news is that the ministry of agriculture is going to be training these people and hopefully they will give them a sound grounding in agriculture before they head out."

Back at the farm feed mill, it's not clear when new medicated feed regulations will come into place. One scenario has commercial feed mills being regulated starting this spring, with farm feed mills being phased in at a later date. Two reasons are cited for the phasing in. One is a lack of resources to inspect the large number of on-farm feeding operations in Canada properly. While there are 300 commercial feed mills in Canada that sell medicated products, CFIA estimates that as many as 30,000 farms now make their own feed and may require licensing and inspection to mix drugs. A second reason is that some questions remain about how to meet all the commitments involved with a license issued by CFIA.

One of the major concerns is reconciliation of feed inventory, says Perron. The kind of reconciliation that CFIA is looking for involves weighing what is left of a product after a day's mixing. It is supposed to add up to the correct total. It's not that hard to weigh what comes out of a bin when it is put into a feed, Perron says. But weighing what is left when it is in a bulk bin is a different story.

It's a requirement that concerns Henk Boekhorst, a farrow-to-finish operator from Bothwell. Boekhorst markets hogs raised from 170 sows fed on homegrown feed from 500 acres. A year ago, a CFIA inspector told him he would have to buy a weigh cell for his feed bin. The cost is about $10,000.

"We know (reconciliation) is a problem," Perron says. "We've suggested that perhaps we will temporarily not impose that on this bulk requirement."

Scrupulous attention to detail

East of Mount Carmel, the Van Osch feed mill dominates the skyline with four 40-by-150 foot concrete silos. Each contains corn from roughly 1,000 acres. Three hold high moisture corn and the fourth silo holds dry corn. In the covered feed mixing area are concrete bays with various feed ingredients. Each feeder wagon Glavin loads can feed 500 head of cattle for the day.

Co-owner Gerald Van Osch credits Glavin, a former pork producer, with running a spotlessly clean ship. Glavin, in turn, praises a good veterinarian and a good nutritionist for putting the program together. But his own scrupulous attention to detail can't be passed over either. He is doing some things that most farmers aren't.

Van Osch Farm is one of a handful in the province to make its own mineral mixes, buying in raw ingredients such as salt, calcium and brewers grains. There are three different mineral mixes, one each for starter, grower and finisher cattle, and only the starter mix contains medication. The minerals are made carefully in sequence, Glavin says; it is critical that they remain separate, since only the starter mineral contains medication. It is fed to cattle entering the feedlot for the first 10 days or so.

Glavin makes the starter mineral first. The grower mineral mix is made next, and is used to "flush" the system free of any remaining medicated minerals. The finishing mineral mix is made last. Colour-coded and labelled pails and scoops are used exclusively for up to four critical additives (one of them a medicine), which go into the minerals. The colour coding prevents cross-contamination. The CFIA suggested that he use this system, Glavin says.

For the pre-pilot project, CFIA inspectors went over the operation with a fine toothcomb, Glavin says. Inspectors took samples when Glavin made the medicated feed and more samples when he cleaned the mixer out. They sampled the grower and finisher rations. They also took 50 samples from the TMR (total mixed ration) wagon to determine if the medication and mineral was mixed thoroughly in the mixer wagon. They were looking for residues lingering from one batch of feed to the next and they didn't find any, Glavin says.

The Van Osch mill is capable of making a mineral mix just like a premix company. Certainly most farms can't do that.

Are any particular types of mills problematic? Based on testing in subsequent pilot projects, Perron says no. "From what we saw, they were working properly or they could be made to work right with some changes. It shouldn't be a big deal."

Farmers have expressed concerns that their proportioner mills might not pass muster. Replacing worn screens and hammers brings them into performance requirements, says a CFIA document summarizing results of the pilot project.

In January 2002, the CFIA started stepping up inspections of farms using medicines. Inspectors were checking to see that facilities met current regulations under the Feeds Act and also Health of Animals Act, but were also asking farmers questions related to proposed regulations that were not yet in force.

Bothwell hog producer Henk Boekhorst got caught up in this. His feed was tested during a drive-by visit from a CFIA inspector on Jan. 4, 2002. In December, the inspector dropped in again with bad news. Boekhorst's feed sample was supposed to contain 31.2 mg of the active ingredient Tiamulin per kg of feed. The drug's label says it is a treatment "to control swine dysentery in pigs on premises with a history of swine dysentery." The CFIA testing showed a medicine content of 18.4 mg.

"This sample is not within tolerance levels allowed under the Feed Act," Boekhorst's feed report says. Feeds aren't supposed to be "under-medicated," say CFIA documents. Low doses are ineffective at preventing disease. "Imprudent manufacturing" may also contribute to the presence of antibiotic-resistant bacteria in animals that could remain on food intended for consumption by humans." If the proposed regulations were in place, Boekhorst would have failed to get the license necessary to legally add a purchased premix at his on-farm mill.

Nearly a year after the fact, Boekhorst didn't know where to turn. Was the problem in the mill calibration, in his calculations or even in the quality of the premix? Both the feed and the premix had long since been used up. Now, Boekhorst is looking for a strategy to protect himself. "If this was for real, I would be the bad guy," Boekhorst says. "I've got to defend myself."

Are the new regulations going to put small operators out of business? A document from the CFIA says that the number of farm mills mixing medications may drop to as low as 10,000 from 30,000 as the regulations come into place. Perron says that if it does, it's not because of the type of mixer. A pilot project shows that proportioner mixers such as Boekhorst uses can meet the new feed specifications.

Permits galore for raising fish

Gerald Van Osch, who runs Van Osch Farms with his brother Fred, says it is likely that these new medicated feed regulations will force some small farms out of business. Nutrient management regulations may well do the same thing.

Boekhorst is frustrated by the increase in paperwork that he expects for both medicated feeds and nutrient management, but at this point he doesn't see himself quitting raising pigs.

Fish farmers are less sanguine. "Any other farmer who thinks he has a problem (with inspectors and licenses) ought to walk a mile in my shoes," says Gord Cole, co-owner of Aquacage Fisheries Ltd. in Parry Sound, which raises three million pounds of trout a year in big nets suspended off shore in Georgian Bay.

At least no one in the provincial government argues that agriculture is a bad thing, Cole says. He believes that there are elements in the Ministry of Natural Resources who see aquaculture as a threat to sports fishing and "don't believe that fish farming should exist." Furthermore, the ministry has no policy on fish farming, in spite of the fish farming industry having gone three rounds of consultations with the ministry in the last 10 years in an effort to develop such a policy.

And then there is the licensing. Cole needs eight licenses, permits and "special dispensations" from various ministries, municipalities and the local Indian reserve where the farm headquarters is located. There is a dispute between the township and the reserve over which has jurisdiction over the water where the big fishnets are located. To cover himself, Cole acquired permits from both.

There's resistance even to starting a fish farm on Georgian Bay now, Cole says. He cites another operator who wants to start a trout farm on St. Joseph's Island near Manitoulin. He's been jumping through regulatory hoops for three and a half years to prove that a fish farm won't hurt the existing spawning grounds for wild fish. He says that, by comparison, starting a beef farm is easy. "Imagine being asked to prove that putting cattle onto a pasture won't adversely affect the local deer population," Cole says. BF