Most horse owners buy the feed and supplements their horses need and probably don’t think very much about the manufacturing process and the amount of monitoring and effort required to keep substances out of feed that should not be there. But a lot happens between the field and the stable. The raw materials are grown, harvested, transported, processed, and as they go through this lengthy process, there is a risk that they can become contaminated with substances that might be harmful to the horse or disqualify it from certain competitions.
To combat this risk, in 2009, the British Equestrian Trade Association (BETA) established a scheme to reduce the risk of naturally occurring prohibited substances (NOPS) in equine feed. It’s voluntary, so horse feed and supplement companies can choose whether to comply with it, but if they do, it means that during manufacturing, they must evaluate the risk of NOPS contamination in every stage of the process, from field to feed store. Brands sourcing material, producers of raw material, suppliers of raw material, and manufacturers of finished products can all be accredited by the BETA NOPS scheme. In order to comply, companies must be certified to a recognised Hazard Analysis and Risk Assessment (HACCP), as the NOPS code itself doesn’t specify a testing regime. But it does state that if a company is using suppliers that aren’t NOPS certified, it must carry out its own supplier assurance program.
This might sound like convoluted red tape, but schemes like this help keep horses both safe from potentially toxic substances and legal for competition and racing, since many of the substances tested for aren’t dangerous, but they are illegal in competition. It means that owners who buy feed from an accredited company (the logo will be on the product’s packaging) can feel assured there are no potentially harmful or illegal ingredients that have accidentally made their way into the feed or supplement.
A naturally occurring prohibited substance is, according to the BETA website, “any substance that can exert an effect on a horse,” either naturally present in certain ingredients, or occurring as a result of inadvertent cross-contamination before it arrives at the feed manufacturer’s facility.
The main NOPS tested for are:
- Caffeine — (cacao)
- Theobromine — (cacao, found in chocolate)
- Theophylline — (tea)
- Morphine — (opium poppy, Papaver somniferum)
- Hyoscine — (nightshade, Datura)
- Hordenine — (germinating barley)
- Atropine — (nightshade, Atropa belladonna)
It might come as a surprise to horse owners that coffee and tea can be toxic to horses (it is probably less of a surprise that morphine is). But coffee and tea contain the stimulant trimethylxanthine, which can cause an irregular heartbeat, while theobromine in large doses can cause colic, seizures, and internal bleeding. In small doses, these substances can affect performance.
Historically, the principal risks of cross-contamination have come from caffeine, theobromine, and morphine. The presence of morphine around horse feed should hopefully decrease due the cessation of poppy cultivation in the UK this year, however, the risk of hyocene and atropine has increased, as these toxic substances naturally occur in weeds that can grow around crops used for horse feed.
As herbal supplements have become more ubiquitous, the NOPS scheme, since 2016, has required manufacturers to test for substances which occur in herbs. There are two categories of herbal substances, high priority and low priority. The high priority ones are banned from any horse supplement, and they include the following:
- Cathinone/Cathine — Khat
- Digitoxin — Foxglove (Digitalis sp)
- Ephedrine/Pseudoephedrine — Ephedra sp.
- Reserpine — Indian snakeroot, Devil’s Pepper; (Rauvolfia sp.)
- Synephrine — “Bitter” orange cultivars (Citrus sp.)
The low priority ones are frequently found in supplements horse owners use, like devil’s claw root (a natural painkiller), but they are banned from competition horses by the FEI and British Horseracing Authority. While the horse is unlikely to be harmed by any of these, the consequences can be serious for competition horses and their connections. If a horse were found to have any of these in its system, it could be eliminated from the competition and its owner and/or rider could face sanctions. The NOPS logo is not permitted to be shown on any supplement containing a prohibited substance, which include but are not limited to, the following:
- Harpagosides — Devil’s Claw
- Salicylic acid — Willow bank, Meadow Sweet
- Valerenic acid — Valerian (Valeriana Officinalis)
- Yohimbine — Yohimbe tree (Rauvolfia sp.)
Horse & Hound approached 13 feed and supplement manufacturers and asked if they comply with the BETA NOPS code, what steps they have taken to do so and how they have changed their manufacturing processes over the last decade, since the code has been in place. Eight of the companies responded and provided us with a view into the extensive process they have in place to avoid accidental contamination of their products by naturally occurring prohibited substances.
Jane Buchan, a spokesperson with Baileys, set some groundwork, telling Horse & Hound: “All companies that sign up to the BETA NOPS code are audited against that code, every 12 months, and this includes a number of procedures that must be adhered to, by all manufacturers.”
The manufacturers who responded to Horse & Hound’s queries were Saracen, Baileys, Spillers, Blue Chip, Science Supplements, NAF, Nupafeed, Aviform, and Feedmark.
The respondents emphasised, first of all, the importance of monitoring and regular audits of the supply chain, from the fields where ingredients are cultivated, to transport, storage, and processing. Supply chains are risked assessed, so if the product is at risk of potential cross-contamination at any stage in the process, anyone involved should be aware of it and taking steps to minimise or eliminate it. The feed manufacturers keep a close eye on the suppliers.
Lesley Howell, the quality assurance manager at Saracen, told us that they only accept feeds from approved suppliers and from approved and risk-assessed hauliers.
Andrea Stott, the quality assurance manager at Spillers, expounded that they use the HACCP (Hazard Analysis of Critical Control Points) model, adding: “To risk assess every stage of our process from the sourcing of raw materials to the manufacturing and dispatching of finished products for the risk of prohibited substances contamination.” They train their associates in the risk of NOPS as part of their induction process and retrain them every two years.
Laura Cackett, who works for Blue Chip, explained: “We have procedures in place to regularly audit our suppliers to satisfy ourselves that they have strict NOPS codes of conduct and at no point is there a chink in the chain where contamination could happen.”
All of the manufacturers described similar oversight of their suppliers.
Testing products is the other critical piece of BETA NOPS compliance. Howell clarified: “Samples are then taken from the selected products using an automated sampling machine, which takes a sample from every other bag ensuring that the sample is homogeneous. These samples are then sent to the LGC Laboratory in Newmarket for analysis using mass spectrometry to test for NOPS contaminants.”
NAF’s senior nutritionist, Kate Hore, also briefly explained their testing process: “Once raw materials arrive, we test all batches of all raw materials, and also every batch of every completed product.”
Most of the companies use independent labs with mass spectrometers for testing, except for Nupafeed, which is not part of the BETA NOPS scheme but has an in-house lab, where every batch, they explained: “is subject to a guaranteed analysis which is signed off by the supervising pharmacist.”
During the production process, suppliers must obviously take steps to eliminate cross-contamination, but so do the factories themselves. Companies maintain strict standards of cleanliness and control on their factory floors to guarantee that nothing slips into the feed or supplement that shouldn’t be there.
Cackett told Horse & Hound: “You could literally eat your dinner off [Blue Chip’s] warehouse floor it is so clean, and of course vermin control plays a big role as well.”
David Mitson, the owner of Science Supplements, said they have invested in a £1.1m new research and development plus production facility in Northamptonshire: “Part of which is a fully ‘enclosed’ system that prevents any external contamination from occurring”.
While Lauren Harrold, with Feedmark, explained that her company makes sure that: “any products that contain FEI prohibited substances (such as Devil’s Claw) are mixed and packaged in an isolated area of the production department to reduce the risk of cross-contamination.”
Most of the companies who responded said that they have been risk-assessing cross-contamination and testing products for longer than the BETA NOPS scheme has been in effect, but told us that the biggest change over the past 10 years has been close audits of the entire supply chain.
This is a good thing, for both feed companies and horse owners, as Stott explained: “Testing is not an efficient way of managing the risk; ensuring the risk is managed right across the supply chain from the raw materials growing in the field through to the feed stored in the feed room and eventually placed in the stable is the best way to help avoid a NOPS positive test.”
The scheme lays out strict standards and practices, which companies like Aviform say has facilitated a clean, safe production process. Their nutritionist, Judy Starke, told us: “Such schemes have made our job easier to be compliant as our production processes have been structured and built around the requirements.” Aviform is not currently part of the BETA NOPS scheme, but is currently working towards being so.
Below are the detailed responses given by the feed and supplement manufacturers:
Science Supplements: Science Supplements made the decision to join both the NOPS scheme and UFAS scheme (Universal Feed Assurance Scheme) from its inception.
With the entire product range being used by many international riders it is vital to ensure our customers can see the high level of certification and measures we take to ensure the quality of our products. Many owners and riders are still unaware of the lengths and procedures a manufacturer has to follow to gain certification. Full traceability of ingredients, laboratory testing and externally audited procedures and processes are just the start of what is required.
While NOPS specifically relates to prohibited substances, the principles apply to a certified companies entire manufacturing facility and the quality of ingredients used.
As a company we have recently invested £1.1m into a new research and development plus production facility, part of which is a fully “enclosed” system that prevents any external contamination from occurring.
NAF: As one of the first supplement companies to gain BETA NOPS accreditation, we take Clean Sport extremely seriously and we take every measure we can to prevent contamination by harmful substances. Adherence to the code starts right at the beginning of our production, with purchasing. We require all suppliers to complete the NOPS questionnaire and we will only purchase from those that meet those requirements. Inevitably this means we can’t buy from some of the cheaper suppliers, but we feel it’s a price worth paying for quality products and peace of mind. Once raw materials arrive, we test all batches of all raw materials, and also every batch of every completed product. Throughout the production process our HACCP procedures ensure that best practice is adhered to in all areas, our production staff all receive BETA NOPS training, and there are regular reminders around the factory.
Really these were procedures we were doing prior to BETA NOPS, but the scheme has helped us to highlight those areas which need particular attention, and has helped us to raise our standards of vigilance and testing, such that we now believe we have one of the most extensive testing programmes in the industry.
One specific change has been an entirely separate dedicated production line for our Devils Relief product, which was brought in after Devil’s Claw was added to the FEI prohibited list.
Saracen: To comply with the requirements of the BETA NOPS code, Saracen Horse Feeds only purchases raw materials from approved suppliers, who are assured and have been risk assessed to safeguard against the risk of possible contamination with NOPS. Additionally all raw materials are only delivered to Saracen Horse Feeds on approved and risk assessed hauliers.
Saracen Horse Feeds tests for the presence of NOPS contaminants. Using an analytical schedule the potential NOPS hazards are considered and products are selected for testing. Samples are then taken from the selected products using an automated sampling machine, which takes a sample from every other bag ensuring that the sample is homogeneous. These samples are then sent to the LGC Laboratory in Newmarket for analysis using mass spectrometry to test for NOPS contaminants.
Baileys: All companies that sign up to the BETA NOPS code are audited against that code, every 12 months, and this includes a number of procedures that must be adhered to, by all manufacturers. The key ones start right back at the selection of the ingredients and raw materials used in Baileys products, when we not only assess them for their nutritional properties but also the possibility of containing any naturally occurring prohibited substances (NOPS).
Should there be any possibility that an ingredient contains a recognised prohibited substance, it is rejected as an ingredient so never enters the feed mill. Similarly, all ingredient suppliers are regularly assessed and audited, to ensure that what they supply to Baileys is of the highest standard. The supply chain they use is also risk-assessed to avoid accidental cross contamination with raw materials that could pose a risk for NOPS. This includes assessing where materials are stored, transport used and any processing plants.
Baileys operate a policy that every ingredient used in the mill, whether for racing and performance feeds or leisure feeds, is risk assessed for NOPS. No ingredients on the BETA NOPS Code “excluded” list are permitted on our site, therefore, avoiding the risk of cross contamination in our feed mill. We place great emphasis on training our staff, from lorry drivers to the production team, to ensure their awareness of NOPS and their understanding of procedures.
In addition to the supplier and ingredient selection process, raw materials and finished feeds are subject to a robust analytical testing schedule, whereby they are regularly tested by an independent laboratory for all the substances on the recognised list of feed-related NOPS, such as caffeine, theobromine, morphine etc. These substances are prohibited in affiliated sport and racing because they have the potential to enhance or affect performance and not necessarily because they are harmful to the horse.
There are systems in place so that, should the laboratory identify any problem with raw materials or finished feeds, we would be notified in a timely manner and could take any necessary further steps. The industry itself also has procedures to notify all manufacturers, if any problem is identified along the supply chain, in order to help limit any industry-wide implications.
The introduction of the NOPS scheme has not significantly changed any of our production processes, over the last 10 years, but has resulted in more rigorous selection and auditing of suppliers as well as increased education and training of the members of staff to ensure they remain aware of the NOPS scheme and importance to our overall business. We have also increased spending on routine analysis, as part of the overall quality assurance programme.
Spillers (part of Mars Horsecare): At Mars Horsecare we take the risk of NOPS and the BETA code very seriously. As part of every associate’s induction they are taken through the risk of NOPS and the importance to the business, this training is then followed up every two years so it remains at the forefront of everybody’s mind. We then use the HACCP (Hazard Analysis of Critical Control Points) model to risk assess every stage of our process from the sourcing of raw materials to the manufacturing and dispatching of finished products for the risk of prohibited substances contamination. In addition to this we have a NOPS testing programme in place. Finally we audit our processes randomly throughout the year using our in-house Product Related Incident Management Programme to ensure we can effectively handle a NOPS incident in the unfortunate event that it occurs.
The BETA scheme has helped formalise and standardise our approach to managing the NOPS risk. The biggest shift is the emphasis is now heavily on supplier assurance rather than testing. Testing is not an efficient way of managing the risk; ensuring the risk is managed right across the supply chain from the raw materials growing in the field through to the feed stored in the feed room and eventually placed in the stable is the best way to help avoid a NOPS positive test.
Blue Chip: Being part of BETA NOPS requires us at Blue Chip Feed to evaluate the risk of NOPS contamination throughout the entire manufacturing process. At every stage from raw materials being harvested, manufacturing, packing, storage and transport we are accountable for ensuring that the best practices are put in place to ensure that contamination can’t happen.
As we rely on our suppliers for raw materials and transport for example we have procedures in place to regularly audit them to satisfy ourselves that they have strict NOPS codes of conduct and at no point is there a chink in the chain where contamination could happen. In addition we also carry out regular internal audits and have strict processes for damages which are quarantined and disposed of specially to further minimise the risk of any possible contamination with stock in storage – you could literally eat your dinner off our warehouse floor it is so clean and of course vermin control plays a big role as well.
With so many horses competing at affiliated levels, as well as in racing, using Blue Chip Feed Balancers where strict control is placed on naturally occurring prohibited substances it is of vital importance that we take every possible measure to prevent any contamination from occurring.
Nupafeed: Nupafeed supplements are made at the pharmaceutical factories at Verla-Pharm in Germany. They are made according to Good Manufacturing Practice (GMP), which has different requirements to NOPS.
Every batch is subject to a guaranteed analysis, which is signed off by the supervising pharmacist (meaning that we are one of very few supplement companies who can guarantee accurate labelling information).
NOPS is a brilliant standard for the feed companies and allows smaller companies to build trust by demonstrating a good manufacturing standard. For most supplement companies it is less relevant; typically they simply buy in raw material from a pharmaceutical supplier. Therefore, as long as they are not also handling prohibited substances, they reach the NOPS standard very easily, something which the customer will view as an indication of quality regardless of the knowledge, formulating and mixing which follows.
Aviform: Aviform conducts stringent controls using HACCP and good manufacturing practices as laid out in UFAS guidelines. As part of this process anything likely to cause an issue within horse products is stored in isolation; this also applies to allergens that could affect other products we manufacture. Our equine products are manufactured in an entirely separate area and never blended when other supplements are in production. Our clean down procedures are intensive and thorough and samples are retained for every batch, which are held for several years. The finished products are tested by an independent laboratory for naturally occurring prohibited substances and this is something that we have done for many years as we recognise the importance of this for our customers; particularly for those professional competitive riders who use our supplements, including GB team members, FEI competitors and an Olympic medallist.
We also test for salmonella and microbial loadings as, although this would be extremely rare given the nature of our ingredients, we take the quality of our finished equine products extremely seriously and consistently monitor them for any form of contamination. We only purchase ingredients from FEMAS accredited suppliers and we ensure that the components are assured. Furthermore, we source human food grade ingredients of the highest purity and never use bulkers or fillers.
Aviform is UFAS accredited, and as you are probably aware, we have to comply with stringent parameters as well as outside audits to maintain this. We believe that schemes such as BETA NOPS, UFAS and FEMAS are excellent schemes to keep horses safe from harmful substances and promote fairness in competition. Such schemes have made our job easier to be compliant as our production processes have been structured and built around the requirements and we believe that this sets companies like ours above the more unregulated manufacturers and suppliers of equine supplements.
Feedmark: Here at Feedmark, we follow the BETA NOPS code to ensure we are doing everything we can to reduce the risk of naturally occurring prohibited substances contaminating our supplements. Throughout the year, we routinely test both individual ingredients and finished products for the presence of NOPS. We ensure full traceability from the ingredient’s source right through to the consumer, which is vital in the rare event of an issue arising.
In terms of manufacturing, any products that contain FEI prohibited substances (such as Devil’s Claw) are mixed and packaged in an isolated area of the production department to reduce the risk of cross-contamination.
All of our suppliers are accredited under UFAS and have an awareness of NOPS, so we can be confident that only the best quality ingredients are used in our supplements.
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