I am a representative of the BCAC on a Meat Industry Committee. My role is to provide input as far as producers needs and interests are concerned. Naturally, I am concerned about the effect of the Meat Regulations. The following was provided the committee, made up primarily of abbatoir operators. Of particular interest to you should be the part that relates to the disposal of SRM's on ALR land.

Specified Risk Material (SRM) Regulatory Overview
Provided by Abra Brynne, Waste Specialist on the MIES Help Desk, BCFPA
November 2010
This document is second in a series devoted to the waste management issues and requirements facing abattoir operators.
Background
Specified Risk Material is defined as the portions of cattle (Bos species1) that contain the prions implicated in Bovine Spongiform Encephalopathy (BSE). BSE is one form of a disease family known as “transmissible spongiform encephalopathy” (TSE), found in elk and deer (as chronic wasting disease), sheep (as scrapie) and humans (as Creutzfeldt-Jakob disease).
Note that the programs established to monitor and contain or destroy SRM are for the purpose of keeping prions out of the human or animal feed supply in an endeavour to control TSE diseases in both target populations. SRM is NOT a hazardous material as defined by the BC Ministry of Environment in the Hazardous Waste Regulation (under the Environmental Management Act) and as determined by the CFIA (see: http://inspection.gc.ca/english/anim...hazmate.shtml2)
Agency Oversight
The only agency specifically tasked with oversight of SRM management in Canada is the Canadian Food Inspection Agency (CFIA). However, their requirements impact practices in the Agricultural Land Reserve (ALR - see below). With regards to the Ministry of Environment, because SRM is not classified as a hazardous material, their regulatory oversight of SRM is no different than it is for the rest of the solid waste coming out of an abattoir (see first document in this series “Solid Waste Management Requirements Overview”, August 2010).
Regulatory Requirements
At slaughter all SRM must be removed, stained and segregated from the rest of the solid waste stream in dedicated and clearly marked containers (in French and English). This is done under surveillance by the CFIA inspector on site. The presence of the CFIA inspector confirming that the remaining solid waste is non-SRM enables more options for disposal than those available for SRM.
Should the SRM remain on the site where it is generated it is not subject to the bulk of the CFIA requirements. The operator who does not remove the SRM from his / her site is not required to stain the SRM or place it in a designated container. However, records of the SRM weight as well as the date and method of disposal of the SRM must be kept for 10 years. Any movement off that site requires a permit from the CFIA for transportation and the SRM can only be disposed off in a permitted and approved manner and at a permitted site.
What constitutes SRM varies depending on if the animal is Under or Over 30 months of age (UTM or OTM). The 30 months threshold is a based on scientific data demonstrating that
1 Does not include bison, water buffalo, sheep or lamb.
2 CFIA seems to change its website structure at an alarming rate so this link may not work for very long but was active on 4 November 2010.
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animals under 30 months do not carry the prions in the portions of the animals deemed SRM in older bovines. SRM is defined as:
 the skull, brain, trigeminal ganglia (nerves attached to the brain), eyes, tonsils, spinal cord and dorsal root ganglia (nerves attached to the spinal cord) of cattle aged 30 months or older; and
 the distal ileum (portion of the small intestine) of cattle of all ages.
Abattoir operators are required to keep detailed records of SRM volumes handled by their plant. These records are to be kept daily and record the date, weight of SRM generated, name of the dye used to mark the SRM, numbers off the Canadian Cattle ID Agency tags, the date the SRM is transported off the site, the name and contact information of the person transporting the SRM off site, and the destination of the SRM. These records must be kept for 10 years.
Disposal Options
When the SRM is moved off the site where it was generated, it must either be permanently contained or destroyed using one of only a few approved methods.
Landfilling / Burial is regarded as permanent containment by the CFIA. However, SRM can be landfilled but only at sites permitted by the CFIA. Such a permit is only granted if the site meets fairly onerous physical and operations requirements. For public landfills, there is not much incentive for the local government to seek and obtain such a permit. There are only three (I believe) public landfills in the province that are permitted to accept SRM and they are all located north of Williams Lake. (Note that the Ministry of Environment allows landfilling of slaughter waste on-site.) West Coast Reduction and Advanced Waste Solutions both offer SRM pick-up services to limited portions of the province and at a cost of $0.12 - $0.15 / pound, at last report. Both companies truck the SRM to Alberta for rendering and then final disposal at a CFIA-permitted landfill in central eastern Alberta, or for incineration in a cement kiln.
Composting of SRM is allowed by the CFIA in recognition that it reduces the volume of material and transforms the organic material into a more stable state. However, the final compost is still regarded as SRM. Land on which composted SRM has been spread must not have bovines grazing on it for five years. Further, if it is off-site (from where the SRM was generated) then the compost could only be moved off site under a CFIA permit to a location that has also been permitted by the CFIA.
Destruction options for SRM are prohibitively expensive and include gasification and incineration. The Livestock Waste Tissue Initiative funded a pilot project to test a European-made incinerator against the requirements of the CFIA (time and temperature) and the Ministry of Environment (emissions). The incinerator did not perform as expected, was quite costly to run (fuel costs) and did not meet the Ministry of Environment’s emission requirements.
The Agricultural Land Commission (ALC) and SRM
The ALC’s mandate is to preserve and protect land for agriculture. Thus they don’t want composted SRM spread in the ALR as this would essentially quarantine the land for 5 years from cattle grazing. The ALC’s Oct 2008 Information Bulletin entitled Slaughter plants and handling red meat waste in the ALR assumes that on-site incineration is an option for abattoirs based in the ALR. Since the publication date of that Information Bulletin incineration has proven to be prohibitively expensive.
On-site options that do not require approval from the CFIA and that adhere to Ministry of Environment requirements generally launch a Non-Farm Use application by the ALC. This is
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really the only option for an activity in the ALR that is not described and allowed in the ALR Use, Subdivision and Procedure Regulation. However, the local government reviews any non-farm use applications first. If they reject the application it never gets to the ALC office. Depending on the political inclination and will of the local government, this can effectively work as a veto against SRM management practices allowed by the other relevant agencies and that may be approved by the ALC where they to receive the application.
Final Thoughts
All bovines carry Specified Risk Material, living or dead. Under the Agricultural Waste Control Regulation, dairies and ranches across the province are burying or composting their mortalities, an allowed practice in the ALR. Since these are happening on the farm where they lived and died, the CFIA finds this an acceptable practice (though ideally the farmer / rancher is keeping records).
However, this is the proverbial moose in the room with regards to the ALR since this means that SRM in the form of dead cattle is being buried or composted – in direct contrast the the ALC’s official position on SRMs in the ALR – at least in the context of abattoirs. Ideally this should be addressed but not in a way that would result in more onerous requirements of the farmers and ranchers across the province for something from which they cannot recoup any costs.