I'd like to thank you for the opportunity to express the views of the rendering industry to this committee. My name is Graham Clarke, and I'm an independent consultant who represents the Canadian Renderers Association in Ottawa. With me I have Mr. André Couture, the chairman of the board of Sanimax.
The membership of the Canadian Renderers Association is composed of the three major independent renderers in Canada. They are Sanimax, which has operations in Quebec, Ontario, Alberta, and the United States; Rothsay, which is part of Maple Leaf Foods and has operations in Nova Scotia, Quebec, Ontario, and Manitoba; and West Coast Reduction, which is based in Vancouver and has operations in British Columbia, Alberta, and Saskatchewan. Between them, these three companies transport, process, and dispose of almost all the specified risk material, SRM, produced in this country by the packing industry and the producers of livestock/deadstock.
As for the independent roles of the three companies, both West Coast Reduction and Sanimax have dedicated operations to process on independent lines with specified risk material. Rothsay does not process specified risk material, but it does transport the raw material, either for rendering or to landfill.
I should point out that the rendering industry is ultimately a service industry. The major customers are the livestock producers and the packing industry. The rendering industry will do what it can to service these industries in the best way possible. In the past, they have pointed out some of the issues with the feed ban rules.
As to the economics of specified risk material, there are about 240,000 metric tonnes of this material generated every year in Canada by the packing industry. When this material is rendered, you end up with steam, which is the moisture content recycled for energy; you end up with fat, the tallow, which is a saleable commodity; and you end up with about 60,000 metric tonnes of meat and bone meal. This is the protein portion that would contain the infected agent, should any animals be infected with bovine spongiform encephalopathy. That material must be destroyed.
Before the BSE crisis in 2003, the 60,000 tonnes of meat and bone meal represented by the SRM was a marketable commodity. It was valued at around $250 to $400 a tonne, depending on market conditions. This material now has no value and must be destroyed at a cost of about $60 a tonne, because landfill is the preferred method at the present time. The reality is, the loss to the livestock value chain in the beef industry is between $310 and $460 a tonne, which on an annual basis would be the equivalent of $18.6 million to $27.6 million, depending on market conditions. Before BSE, the rendering industry was able to pay for this material, but now that it's of no value, to cover the costs, they charge to collect it, render it, and dispose of it.
This raises two key issues. The first one is the environmental issue. The current situation requires all this material—60,000 metric tonnes—to be put into landfill. The main issue is with the deadstock, because bovine deadstock by definition contains SRM. The amount of deadstock being collected has dropped by 30% to 60%, depending on the part of the country we're talking about, from pre-BSE times. This raw material, the deadstock, is now being buried on the farm, composted, incinerated, or, in some cases, left to decompose in the environment. This is clearly not a satisfactory situation, but economically it's unfortunate that the farmers are no longer able to pay for collection. The other environmental impact of this applies to all deadstock. When you lose the volume of bovine deadstock, which constitutes a large volume, it is no longer economical to run trucks along the trucking routes to pick up this material. Consequently, the impact of losing the bovine deadstock also has effects on small stock such as hogs and sheep. You have environmental issues that are somewhat undesirable.
The second issue that I'd like to raise is the business risk associated with the current regulations. It is no longer possible to obtain insurance for any industrial problems relating to BSE. Small packers, who are under a lot of economic stress, face a significant challenge: although the rendering industry will pay for non-SRM, which still has value, it now charges to pick up the SRM, which is divided by the packer. It is a big risk that a packer could either accidentally or perhaps deliberately put the SRM material in with the non-SRM material, and if that were to occur, you would have the potential for a major recall throughout the feed chain when this is processed into animal feed, costing many millions of dollars.
This is not an unfounded fear; this has in fact happened. It happened in western Canada early this year. This was not a small packer involved, but a large one, where accidentally SRM material was put into the ruminant material with the SRM removed. This resulted in a major recall of feed throughout western Canada, and it cost a large amount of money. So clearly this is a major issue and a big problem for the rendering industry.
Certainly from the point of view of the customers, there's a clear cost discrepancy between the U.S. and Canada due to the different regulations. The CRA membership does indeed support the efforts of the customers in the beef processing industry and the cattle producers to seek additional support until such time as this discrepancy is removed, through either harmonization with the U.S. regulations or by some other means.
At this point, I will turn the microphone over to André to ask if he has any other further comments.