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From: TSS ()
Subject: Re: Docket No. FSIS-2006-0011E - Harvard Risk Assessment of Bovine Spongiform Encephalopathy Update; Notice of Availability and Technical Meeting
Date: September 12, 2006 at 6:29 pm PST

In Reply to: Docket No. FSIS-2006-0011E - Harvard Risk Assessment of Bovine Spongiform Encephalopathy (BSE) Update; Notice of Availability and Technical Meeting posted by TSS on September 12, 2006 at 8:49 am:

>>>I hope that you don't need more time to let industry reps try and water this
thing down as much as possible (just my opinion). HOWEVER, if you just look
at was was promised to us on SRMs before, and then the after product, only
then will you see just how industry friendly these regulations are. let's
first take a look at what was first promised ; <<<


no i dont' have a crystal ball, the facts speak for themselves, and yes, they are laughing all the way to the bank, as i said. ...TSS


US Feed Ban May Be Too Costly To Industry
Today 9/12/2006 7:36:00 PM

US Feed Ban May Be Too Costly To Industry

WASHINGTON (Dow Jones)--The U.S. Food and Drug Administration may have underestimated the cost to industry of the government's plan to improve the way mad-cow disease contamination is kept out of livestock feed, Steve Sundlof, director of the FDA Center for Veterinary Medicine, said Tuesday.

Sundlof, in an interview with Dow Jones Newswires, said FDA is now going back over its proposal that seeks to force renderers to remove the brain and spinal cord from all deadstock cattle processed for livestock feed.

The FDA had presumed that the rendering industry would not be hindered greatly when the new feed rule proposal was devised, Sundlof said.

"What we heard back, was that no, that's probably not the case," Sundlof said. Instead, only a minority of companies "would be willing to separate the brain and spinal cord out."

Officials have been taken aback by the industry's response.

The FDA is reviewing previous assumptions and new data from representatives of an industry that provides billions of pounds of protein for the livestock feed industry. The delay, he said, may push publication of the final rule back to "later this year," or beyond that.

The FDA unveiled its proposal to reform the U.S. feedban rule - set in 1997 to try to keep mad-cow disease from spreading in herds if it ever appeared in the U.S. - about a year ago and gave the public 75 days to submit comments.

Many of the 850 responses FDA received said the agency's plan would have a stronger detrimental impact than the government anticipated.

"A lot of comments said that we underestimated considerably the economic impact associated with what we proposed," Sundlof said.

Tom Cook, president of the National Renderers Association, said FDA's proposal would "take the incentive away for rendering of a significant portion of material that needs to be rendered."

He is talking about cattle that die on the farm and are carted off by renderers. Many, he said, would stop collecting the carcasses if FDA's current proposal is implemented.

"Animals that are picked up on the farm represent 2-4 billion pounds of raw material a year," Cook said. "If the renderers can't afford to pick it up ... they're not going to do it anymore."

The FDA banned the practice of feeding bovine material to cattle in 1997 because mad-cow disease, or bovine spongiform encephalopathy, is believed to be spread among cattle if they ingest infected material. Other livestock, though, could continue to be fed all bovine material, including what is considered risky material for BSE infection.

The first BSE-infected cow was found in the U.S. in December 2003. Since then, two more cases in cows have been discovered.

In October 2005, FDA unveiled a plan to require that brains and spinal cords be removed from all deadstock cattle before they are rendered for feed for any animals. The FDA said that simply trying to keep bovine material out of cattle feed was not good enough.

"Cross-contamination" of feed for cattle and feed for other livestock that contained bovine material is a risk that should be avoided, FDA reasoned in its proposal.

The FDA said "it may not be possible to verify that there is zero carryover of feed or feed ingredients in equipment."

That proposal, though, may be so costly that it would remove a cheap protein source from feed manufacturers who rely on rendering cattle carcasses that aren't fit for human consumption.

"Many renderers believe this restriction on dead stock will be the beginning of untenable economic pressure on dead stock collection that could eventually lead to the end of the service for all species," the National Renderers

Association said in a written submission to FDA.

FDA officials continue to review the economics of the proposed changes to the U.S. feedban, Sundlof said. "So, we expect it will be some time before we issue a final rule."

Source: Bill Tomson; Dow Jones Newswires; 202-646-0088; bill.tomson@dowjones.com


http://www.cattlenetwork.com/content.asp?contentid=67844

STRICTLY PRIVATE AND CONFIDENTIAL 25, AUGUST 1995

snip...

To minimise the risk of farmers' claims for compensation from feed
compounders.

To minimise the potential damage to compound feed markets through adverse publicity.

To maximise freedom of action for feed compounders, notably by
maintaining the availability of meat and bone meal as a raw
material in animal feeds, and ensuring time is available to make any
changes which may be required.

snip...

THE FUTURE

4..........

MAFF remains under pressure in Brussels and is not skilled at
handling potentially explosive issues.

5. Tests _may_ show that ruminant feeds have been sold which
contain illegal traces of ruminant protein. More likely, a few positive
test results will turn up but proof that a particular feed mill knowingly
supplied it to a particular farm will be difficult if not impossible.

6. The threat remains real and it will be some years before feed
compounders are free of it. The longer we can avoid any direct
linkage between feed milling _practices_ and actual BSE cases,
the more likely it is that serious damage can be avoided. ...

SEE full text ;

http://www.bseinquiry.gov.uk/files/yb/1995/08/24002001.pdf


TSS




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