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From: TSS (
Subject: Industry Speaks Against BSE Feed Ban Rules
Date: August 25, 2004 at 2:19 pm PST

-------- Original Message --------
Subject: Industry Speaks Against BSE Feed Ban Rules
Date: Tue, 24 Aug 2004 21:20:18 -0500
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy

######## Bovine Spongiform Encephalopathy #########

8/24/2004 2:55:47 PM

Industry Speaks Against BSE Feed Ban Rules

KANSAS CITY (Dow Jones)--While the interim final rule removing specified
risk materials from certain beef carcasses and keeping them out of
animal feed may sound good to the uninitiated, a blanket restriction is
unnecessary and expensive, industry groups are saying.

The U.S. Department of Agriculture's Food Safety and Inspection Service,
its Animal and Plant Health Inspection Service, and the Food and Drug
Administration jointly made the ruling on July 9. The idea was to
strengthen safeguards for consumers against bovine spongiform
encephalopathy, or mad-cow disease, following the discovery of an
imported cow with the disease in Washington state in December.

Government agencies are seeking comments on the proposed rules, but the
one that would keep specified risk materials out of all animal feed to
control the risk of cross-contamination through feed manufacture and
distribution is drawing industry ire.

Kansas Secretary of Agriculture Adrian Polansky on Friday submitted
comments to the FDA on the proposed change in feed regulations,
according to an Extension Service release.

In his letter, Polansky told the FDA that, absent other actions,
including an outright ban on specified risk materials, he supports
banning blood and blood products, plate waste and poultry litter from
cattle feed. He also said he would support requiring dedicated
equipment, production lines and feed facilities to prevent inadvertent
feed contamination if specified risk materials are allowed in some
animal feeds.

The National Cattlemen's Beef Association is very concerned that the FDA
"has tentatively concluded that it should propose to remove SRMs from
all animal feed and is currently working on a proposal to accomplish
this goal," the NCBA statement said. NCBA comments challenged this
assumption, saying "it does not appear to be grounded in evidence,
science, nor risk analysis."

Along with other industry groups, the NCBA told the FDA it was concerned
that "FDA's advanced notice of proposed rulemaking on BSE mitigation
reflects a significant shift in agency philosophy, one that suggests a
'one-step-cures- all' approach based almost exclusively upon removal of
all specified risk materials from all animal foods. We are concerned
that this approach may actually limit effective implementation while
causing significant unintended consequences that adversely impact animal

The NCBA suggested the agency should be open to alternative actions
"that enable the agency, in concert with industry, to create a system of
enhanced feed controls providing equivalent risk mitigation." The letter
suggested a "more integrated systems approach that is informed by the
results of USDA's enhanced surveillance program" and that the agency
conduct appropriate risk/benefit and cost/benefit analysis of various
policy options.

The letter was signed by NCBA and American Feed Industry Association,
American Meat Institute, American Sheep Industry Association, National
Grain and Feed Association, National Milk Producers Federation and the
National Renderers Association.

The National Renderers Association, which was formed in 1980 to address
biosecurity issues, also voiced its opposition to the proposed feed ban

"NRA and APPI (the Animal Protein Producers Industry) continue to
support scientifically based animal feeding regulations to restrict the
use of certain animal proteins derived from mammalian tissues used in
ruminant feeds," the comment said.

"However, our analysis of the facts make us believe FDA's preliminary
conclusion to remove specified risk material from all animal feed and
pet food is not warranted and that this and other BSE-prevention
measures proposed by FDA are not scientifically or economically justified."

Feed restrictions already in place to block the feeding of ruminant
protein back to ruminants is scientifically justified, but keeping SRMs
out of the entire feed chain is unjustified scientifically, said Tom
Cook, NRA president. This is true even though the infective agent for
BSE has been found in the lower parts of the small intestine in cattle
as young as six months.

If a processor could come up with a way to remove just the infectious
tissue, the NRA would support such a move, but even calls to remove the
entire small intestine go too far because of the massive amounts of
tonnage involved over time, Cook said.

"The decrease in potential human exposure by prohibiting SRM's from
animal feed is extremely small and should be viewed in the larger
context of the costs and environmental harm that is likely to result
from these types of feeding restrictions," the NRA comment said. "Simply
eliminating SRM's from the human diet appears to have reduced the risk
of human exposure to BSE nearly as much as would be expected from a
complete ban on rendering this material, and certainly to levels that
are far below risks to human health associated with any number of daily

An NRA-commissioned Informa Economics study this month provided data
that the annual economic loss to renderers would be $32.4 million from
lost Meat and Bone Meal sales and $59.2 million in lost sales of tallow,
for a total product loss of $91.6 million, the NRA comments said.

In addition, the total cost to dispose of the 1.423 billion pounds of
SRM by-products currently produced in the U.S. would be $74.7 million
per year, the NRA said. This estimate is consistent with a report
published by the European Association for Animal Production showing the
cost of Meat and Bone Meal disposal is nearly twice the value of MBM.

In addition to the $166.3-million annual economic effect, the disposal
of non-rendered dead stock cattle, non-ambulatory disabled cattle, and
SRM's removed at slaughter would create a major environmental problem,
the NRA said. Placing these infectious tissues in landfills would
greatly increase the amount of infectious waste in the environment.

One scientist estimated the primary load of infectious waste received in
landfills currently is about 126,500 tons a year, composed primarily of
human feces from diapers and pet feces. Restricting SRM from animal feed
likely would lead to no pickup of dead stock by renderers, the NRA said.

As a result, there is a high probability more dead animals would be
disposed of improperly with detrimental environmental effects as well as
preventing APHIS' testing of high risk animals for BSE, the NRA comments
said. If SRM and dead and downer cattle were all disposed of in
landfills this would amount to 7 billion pounds or 3.5 million tons
annually, increasing the load of infectious waste by over 27 times.

> An internal challenge was possibly present
> from 1980 to 1990 and was likely to be present
> and growing from 1991 to 2003

> USA, Summary of the GBR Assessment, July 2004 GBR Level : III**
> 1980-1990: Moderate
> 1991-1995: Very High
> 1996-2003: Extremely high
> 1980-2003: Extremely unstable
> Live Cattle imports MBM imports Feeding Rendering SRM-removal BSE
> surveillance
> Any external challenge would have met the
> extremely unstable system and infectivity
> would have been recycled.
> An internal challenge was possibly present
> from 1980 to 1990 and was likely to be present
> and growing from 1991 to 2003

AND still growing if the industry has anything to do with it...


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