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From: TSS (
Subject: Cattle and feed coalition concerned about FDA's SRM feed ban ''alternative solutions'' $$$
Date: August 9, 2004 at 6:53 am PST

-------- Original Message --------
Subject: Cattle and feed coalition concerned about FDA's SRM feed ban ''alternative solutions''
Date: Mon, 9 Aug 2004 08:50:39 -0500
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy

Legal/Regulatory News
Cattle and feed coalition concerned about FDA's SRM feed ban

by Brendan O'Neill on 8/9/04 for

Expressing concern that "FDA's advanced notice of proposed rulemaking
(ANPRM) on BSE mitigation reflects a significant shift in agency
philosophy," a coalition of organizations representing both the cattle
and feed industries sent a letter to the U.S. Food and Drug
Administration this week, according to a news release.

The letter explained that the "implementation challenges in this
approach may actually limit its effective implementation" while also
causing "significant unintended consequences that adversely impact
animal health."

The members of the coalition include the American Meat Institute,
American Feed Industry Association, American Sheep Industry Association,
National Cattlemen's Beef Association, National Grain and Feed
Association, National Meat Association, National Milk Producers
Federation and National Renderers Association.

The coalition suggested that there may be alternative solutions to
consider other than the removal of all SRMs from animal foods. In the
letter, it urged FDA to conduct appropriate risk/benefit and
cost/benefit analyses that would evaluate various policies that include
options other than a complete ban on SRMs in animal feed, according to

In the letter, the group suggested that in lieu of requiring the removal
of all SRMs from animal feed, the FDA propose "a more integrated systems
approach that is informed by the results of USDA's enhanced surveillance
program and grounded in an appropriate risk/benefit and cost/benefit
analysis of various policy options."

AFIA Hosts Coalition Meeting on FDA BSE Feed Proposal

[ ]

AFIA invited over 15 organizations to its offices July 13 to discuss and
develop a consensus on the FDA's recently announced advanced notice of
proposed rulemaking (ANPRM) for the BSE feed rule. Published July 14 in
the Federal Register jointly with the Animal and Plant Health Inspection
Service (APHIS), the ANPRM consists of 32 questions (23 exclusively to
FDA). FDA's portion requests comments within 30 days.

The primary thrust of FDA's approach is to propose banning specified
risk materials (SRMs), which are those materials known to harbor
potential BSE infectivity (e.g. brain, spinal cord, vertebral column,
distalileum, and others). The agency believes such an approach will
negate the need to take other measures Ă’downstream.Ă“ Many of the
questions posed are predicated on the removal of SRMs from all feed and
pet food, an approach nearly universally opposed by animal agriculture.

AFIA announced at the meeting it would request a 60-day extension on the
comment period, since that action is consistent with the comment period
allowed on FDA's last ANPRM for BSE in November 2002. AFIA sent a draft
to all groups after the meeting asking for each to sign on. The letter
was filed on July 15.

Much of the meeting concerned producing a general consensus approach to
the ANPRM, and it was agreed that the American Meat Institute (AMI)
would draft a letter informing FDA that is premature to propose a ban on
SRMs while a major BSE surveillance project is on-going here by USDA.
The letter will be followed up at the next meeting of the working group
on July 19. Also, at that meeting, attempts will be made to reach a
consensus on many of the questions FDA is asking.

Whether FDA will or can grant an extension is unclear. The large number
of issues raised by FDA, some of which will require outside studies and
consultants, is reason enough to grant the extension.

For a copy of the letter of FDA's notice or questions on this issue,
contact AFIA's Richard Sellers .


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