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From: TSS ()
Subject: Risk Reduction Strategies for Potential BSE Pathways Involving Downer Cattle and Dead Sock of Cattle and Other Species NRA TO USDA-APHIS 01/21/2003
Date: June 22, 2005 at 7:08 pm PST

National Renderers Association Public Response to USDA-APHIS
ANPR “Risk Reduction Strategies for Potential BSE Pathways Involving Downer Cattle and Dead Sock of Cattle and Other Species”

Docket No. 01-68-1, Federal Register, Vol.68, No.13: 2703 – 2711, 01/21/2003




The United States boasts a highly developed agriculture, with poultry and livestock sectors making for one of the largest (#1 in poultry and beef and #2 in pork meat) producers in the world. In 2002 our nation processed 35.7 million head of cattle, 100.3 million pigs and almost 8.8 billion chickens and turkeys, yielding 85.5 billion pounds (38.8 million metric tons) of meat, an increase of 3.3% over 2001

The efficient production of such staggering number of animals is based on well-established practices of modern husbandry, sophisticated genetics, optimum nutrition, animal disease programs and animal welfare safeguards, all within the well-integrated animal agribusiness system. What is often neglected is the important fact that each animal slaughtered normally generates significant amounts of by-product, which must be dealt with in some fashion. Table 1 shows the proportions of raw material used for human consumption and the ones available for by-product processing for each of the four major farmed animal categories. Applied to the above statistics they reveal the tremendous volumes of by-products of animal provenance the society is left to deal with.

In spite of the concerted efforts by all participants in animal production, there are, and always will be, a significant number of on-farm mortalities. While the vast majority of livestock enter the food chain, a small portion die due to various non-infectious (accidents, injuries, etc.) causes and infectious, including major zoonotic, conditions or is condemned at time of slaughter. Add to these the already huge amounts of animal material derived from normal processing. Animals that succumb to either disease or accident prior to slaughter, making them unfit for human consumption, and living animals in a condition that doesn’t meet certain minimum standards are diverted away from the food chain. The data in Tables 3 – 12, gathered by the Sparks Companies (ref.36) on behalf of NRA, are revealing. In the year 2000 for example, the combined

poultry and livestock mortalities in the U.S. amounted to 105,345,700 heads, with a total weight of more than 3.3 billion pounds. There is also a significant volume of animal by-

products coming from various sectors of food processing, retail and catering business, as well as from free-roaming wildlife. The effective and safe utilization of these by-products is important to the overall food animal production, processing and consumption cycle.


From this background rendering emerges as a crucial, albeit hardly publicized, player. Seemingly obscure to general public awareness its fundamental significance remains unappreciated. The rendering industry however forms an indispensable mechanism for safe disposal and responsible recycling of animals in all industrialized societies -- a fact which should be kept in mind by all pertinent regulatory bodies. The indispensability of the rendering industry is reflected in its versatile functions:

Environmental Sanitation & Anthropozoonotic Safeguard: The nature and degradation of animal tissues can serve as an ideal matrix for transmission and perpetuation of disease-causing pathogens, many of (anthropo) zoonotic significance, with serious consequences to exposed susceptible populations -- animal and/or human (ref.16). Unprocessed, non-cooled animal tissue decomposes quite rapidly providing an excellent media for explosive multiplication of microorganisms and chemical alterations of the proteinaceous components.

A study carried out by University of Illinois (ref.40) at 17 rendering facilities in

Midwestern United States demonstrated that raw animal by-products sampled just

prior to the entry into the cooker contained high concentrations of all five classes

of food-borne pathogens: Listeria monocytogenes, Campylobacter jejuni,

Salmonella spp., Escherichia coli and Clostridium perfringens.

If allowed to accumulate and decompose unrestrained, these tissues would

become a substantial biohazard: promoting contagion, attracting and harboring

rodents, insects, scavengers and other known disease vectors and attracting

predator animals into densely populated areas.

Volume Reduction & Land Conservation Mechanism: The unprocessed animal by-products contain large (90% in blood, 40% in fat trim, 55% in bones and 70% in offal) amounts of water. Rendering is basically a heating and desiccation which reduces the raw material volume by more than 60% -- waste minimization par excellence. The US rendering industry procures roughly between 40% - 45%

of the total on-farm mortality (National By-Products Company, personal

communication). With this in mind, and considering only mammalian species

(Table 5), rendering reduces the initial raw material volume of roughly 33 billion

lbs (15,000,000 metric tons) down to 1,980,000,000 lbs (6,000,000 metric tons)

rendered product. All species combined, the current amount of raw material

generated annually approximates 50-54 billion pounds!

Put in perspective, this massive volume of raw material raises the specter

of Interstate 80, stretching 2,946 miles from Newark, NJ to San Francisco, CA,

filled to capacity with trucks loaded with that material. Should all those trucks

deposit their cargo in US landfills, approximately one-third of all current sites

would be occupied … each year! (ref.29). Rendering removes the need to

dispose of byproducts in landfills or by methods that might pose potential

health hazards or strain existing space (ref.35). The economic value of

such sanitation and land conservation service is certainly high, but difficult to

gauge. The problematic nature of land filling, as a method for disposal of animal

tissues, will be reviewed further in this response.

Manufacturing of Value-Added Ingredients of Animal Feeds: Rendering adds nearly $1.0 billion value to the United States livestock production sector in the form of proteinaceous feed ingredients alone (ref.35). This value approaches $3.0 billion, when contributions from rendered fats and greases are considered. Animal proteins have been traditional sources of essential amino acids and nutrients for livestock, poultry and aquatic species in the United States and their acceptance in Latin America and Asia is a growing trend. Total domestic use of meat and bone meal in animal feeds is approximately 5.7 million pounds (ref.35) per year. However, due to the BSE “crisis” overseas, the domestic use of animal protein ingredients has been decreasing (Table 14). Annual exports account for approximately 15% of animal protein [mostly meat and bone (MBM) and feather meals] and 35% of tallow and grease production.

The poultry industry uses the largest portion of domestic MBM, followed by the pet industry. Smaller amounts are used in swine and ruminant feed. While there are no restrictions on feeding MBM to poultry and hogs, cattle and other ruminants are fed MBM that is strictly of non-ruminant origin. Usage patterns for blood products differ in that ruminants are fed most of the blood (usually as blood meal) products. Spray-dried products, such as plasma proteins, are used predominantly in the swine industry.

The continued use of animal proteins as feed ingredients is largely due to the rendering industry’s ongoing commitment to improving their quality and nutritional value.

For example, new methods, improved equipment and greater understanding of time vs. temperature effects and processing regimen on amino acid availability have yielded significant improvements in the digestibility of animal proteins.

Better insights on how best to use animal proteins in commercial diets and improved feed formulation procedures have helped enhance their utilization value, but on the other hand resulted in decline in their actual rate of use.

Manufacturing of Value-Added Non-Feed Type Commodities: Fats, oils and grease products from rendering constitute about 24% of the lipid or triglyceride resources in the world. They have wide industrial applications, including: soaps, biodiesel, antifreeze, soaps, cleaners and polishers, concrete, corrosion prevention, lubricants, resins, paints, coatings, cosmetics, dental creams, pharmaceuticals, explosives, plastics, textiles, photography, to name a few. Rendered protein by-products have limited other application beside their use as feed ingredients. Thus, the rendering industry adds enormous value to the economy through its “original recycler” function.

Homeland Bio-Security / Safety: The recent geopolitical trends dictate coordinated homeland security policies and institutionalizing protection of the national food resources (ref.39). A defensive posture against potential bio-terrorism -- foot and mouth disease (FMD), African swine fever, anthrax, botulism, avian influenza, VVND and host of other contagious diseases come to mind – is in this sense axiomatic. For example, the natural outbreak of FMD during 1997 in Taiwan caused losses estimated at US$378.6 million. On the other hand, the efforts to control the 2001 FMD outbreak in the United Kingdom resulted in the slaughter of more than 3.9 million animals. With a much larger size, the US animal industry losses from a similar outbreak due to bio-terrorist act can be staggering. The scale of economic and emotional disruption is further magnified by the enormity of animal disposal and the vast problems – environmental, human health and ethical - related to it. As a result of the mentioned FMD outbreak, which spread eventually to the Continent, the Europeans discovered first-hand the crucial role of rendering in the control of zoonotic diseases. It was quickly realized that an intact, well-organized and effective national rendering infrastructure is crucial. From this prospective, an animal disposal system focused singly on TSE’s may hinder the swift and safe disposal of large number of carcasses resulting from nation-wide emergencies. The specter of such eventuality is not as hypothetical as used to be and must be seriously considered.

Regarding animal disposal choices, contextual to national bio-safety,

careful thought must be devoted to logistics, practicalities, degree of

preparedness, latitude of action, ability to eliminate given biohazards

and economics of scale, among others. The preferred role of rendering as

a proven and safe method for animal disposal, both on an ongoing basis and in

case of animal disease contingencies, will be made obvious in due

course. It not only adds great value to the animal production cycle but, through

its environmental and public health functions, provides a number of indispensable

biosafety services.

Dead Stock

The reader is made aware that the causation of farm animal mortality is multi-factorial. In this respect CNS diseases leading to death constitute a minute etiology.

The latter cannot be attributed exclusively to TSE. Nonetheless the Agency seemingly endorses such an assumption. Arguably, CNS disease is overwhelmingly bacterial (listeriosis, botulism, etc.), viral, rickettsial, parasitic, neoplastic, metabolic, etc. in nature. The chance of underlying TSE infinitesimal, a targeted surveillance of fallen stock, as we know it in the United States, should act as effective barrier to prionic material from accidentally entering the ruminant feed chain.

Another important aspect of on-farm mortalities is the age distribution, especially of large animals (Table 8). Close to quarter of on-farm, dairy and beef cattle combined, mortalities in 2000 concerned animals older than 24 months. Mature cattle tend to decompose slowly, generate substantial amounts of biological run-off, and their thick hides often remain even after the rest of the carcass has been reduced to compost, soil, or ash. To accelerate decomposition the carcass must be cut into smaller pieces, resulting in higher labor costs to the livestock producer! For these reasons on farm-incineration and composting (see further) tend to be impractical, particularly in the absence of large, expensive and specialized facilities (ref.36).

Where service is available, we are reminded, rendering is usually the method of choice for dead stock (ref.5). In some areas the ANPR contends it is unavailable or as costly for pick-up as to be prohibitive. In reality rendering services can be made available everywhere, except in remote range and mountains locations. With the above, and the demonstrable superiority of rendering as general method for animal disposal in mind, a policy encouraging rendering of as large as a possible number of dead stock may be prove to be a logical choice.


Methods of Animal and Animal Material Disposal

1. Basic considerations: The general criteria for evaluating disposal options are discussed in the following contexts (ref.11):

Ability to inactivate TSE “agents”
Location and volume of material
Duration of disposal
Time constraints
Geographical factor
Proximity to human settlement
Lead time for delivery / construction of facility
Weather /climate
Availability of know-how, equipment and chemicals
Health and safety impacts
Environmental consideration

Table 16 demonstrates that no single option for disposal is ideal for TSE under each scenario, that none of the processes are 100% effective in removing TSE infectivity and that there will be some residual post-treatment infectivity. Some (Table 15) also involve risks (chemicals) to people or the environment (ash, dioxins, etc.). It is noteworthy however that stand-alone rendering as a means for TSE inactivation rivals the only two more effective (but also more extreme) methods – incineration and rendering followed by incineration.

The UK Food Standards Agency guidelines for minimizing risk to public health from slaughter and disposal of animals affected by foot and mouth disease (FMD) rank the routes of disposal in the following preferential order (ref.43):

Sheep, pigs and younger cattle: Rendering à Incineration à Landfill à Burning à Burial

Older cattle: Rendering (with MBM/tallow incinerated) à Incineration à Pyre burning

Rendering is viewed as the method of choice for disposal of animal carcasses. The FMD case is illustrative of a national emergency where a large number of animal carcasses have to be dealt with. In retrospect, the British authorities would have readily resorted to rendering as the most feasible option, but the industry’s available capacity was determined to be limited for addressing such a massive epidemic. The UK example should serve as warning to prevent shrinking the number of rendering facilities through unwarranted policies.

2. Major Animal Disposal Options:


Alongside the above listed aspects of animal disposal, rendering has, especially in the context of BSE, many other advantages, i.e.:

* Traceability

* Timely processing

* Safety

* Well-established infrastructure

* Regulatory oversight

Except for incineration, which is cost prohibitive and environmentally problematic, most of the alternatives to rendering do not account for the origin and ultimate disposition of the animal byproducts and mortalities, i.e., lack traceability. This is objectionable when

attempting to prevent, control or eradicate disease. Rendering companies on the other hand are held accountable and required to document and maintain written records suitable for governmental agencies to retrospectively trace raw by-products back to their source

and finished products forward to their disposal or use. Animal byproduct traceability was provided when the FDA implemented a ban on feeding ruminant-derived proteins back to cattle and other ruminants. One of the provisions is:

“To maintain records sufficient to track the materials throughout their receipt, processing and distribution and make the copies available for inspection and copying by FDA”

Even firms processing materials exempt from the mentioned ruling, such as those derived exclusively from non-ruminant animals, must maintain records providing traceability. These firms are also subjected to FDA inspection and must demonstrate that their products lack materials of ruminant provenance.

Another major facet is timely processing of to be disposed materials. Because of the equipment and processing conditions used in modern rendering facilities, bacteria and viruses (prions aside) are quickly killed and not allowed to reproduce and spread. This is

critical to contain, prevent or eradicate disease. Alternative procedures may also kill pathogens -- incineration provides a quick, although in the case of prions incomplete, pathogen destruction, however other methods are based on tissue decomposition and may take months to complete the process.

Unprocessed animal tissues and mortalities contain a large number of microorganisms. Hereunder we provide a list (far from complete!) of animal and human pathogens relevant to raw animal by-products:

Table 1

Agent Type Hazard

Animal Human

Cryptosporidium spp. Protozoan yes yes

Giardia spp. “ yes yes

Toxoplasma gondii “ yes yes

Bacillus anthracis* Bacterium yes yes

Clostridium spp.* “ yes yes

Salmonella spp. “ yes yes

Escherichia coli “ yes yes

Yersinia spp. “ yes yes

Erysipelothrix rhusiopathiae “ yes yes

Listeria monocytogenes “ yes yes

Brucella abortus “ yes yes

Campylobacter spp. “ yes yes

Leptospira spp. “ yes yes


tuberculosis var. bovis “ yes yes

Foot and Mouth Virus yes no

Pseudorabies “ yes no

Rabies “ yes yes


(Scrapie, CWD, BSE) proteins yes not ascertained

* sporeforming microorganisms

Temperatures between 2400 and 2950 F (1150 to 1460 C) used during rendering are more than sufficient to kill bacteria, viruses and many other microorganisms, resulting in by-products that are free of potential biohazards and environmental threats. As reported by Trout at al. (ref.40) Clostridium perfringens,

Listeria spp. and Salmonella spp. were isolated from more than 70% of the samples taken prior to rendering. All samples taken after heat processing were negative for these and other pathogens. The data affirm that rendering is an effective tool for controlling

pathogenic bacteria and underscore the safety of rendering.

The value of the rendering process as a mechanism to control microbial pathogens, as well as other hazards, was firmly validated in the United Kingdom Department of Health study (ref.42) whose results are shown in the following table:

Table 2: Exposure of Humans to Hazards from Each Method of Handling Animal By-products

Disease/Hazardous Rendering Incineration Landfill Pyre Burial

Campylobacter, E.coli vs vs m vs high

Salmonella, B.anthracis,

C. botulinum, Leptospira,

M. tuberculosis var.bovis,


Cryptosporidium, Giardia vs vs m vs high

Clostridium tetani vs vs m vs high

Prions (BSE & Scrapie) m vs m m high

Methane, CO2 vs vs m vs high

Fuel-specific chemicals

& metal salts vs vs vs high vs

Particulates, SO2,

NO2 & nitrous particles vs m vs high vs

PAHs & dioxins vs m vs high vs

Disinfectants &

Detergents vs vs m m high

Hydrogen sulfide vs vs m vs high

Radiation vs m vs m m

Legend: vs = very small; m = moderate

Risks of human exposure to biological hazards were found negligible for rendering, incineration or pyre. However, incineration and pyres were reported to cause moderate to high exposure to chemical hazards associated with burning. Only rendered materials presented negligible biological and chemical hazards! The BSE agent was the only exception, but it was found to pose a negligible risk to humans when the solids from rendering were subsequently incinerated. The information presented in the recent fiduciary study carried out by Det Norske Veritas (DNV) on behalf of the Canadian Feed Industry Association (refr.11) shows that the efficacy of routine rendering for inactivation of TSE infectivity was reported to be 200 to 1,000 fold, but DNV chose for the, more conservative, 200 fold rate of inactivation.

The rendering industry is closely regulated by state and federal agencies, which routinely inspect facilities for compliance with applicable regulations and finished product safety tolerances. FDA inspects rendering facilities for compliance to BSE related regulation. APHIS issues export certificates and supervises compliance with restrictions imposed by importing countries. State Feed Control Officials inspect and

test finished products as they enforce quality, adulteration and feed safety policies.

Other state agencies also regulate the industry thorough issuance of air and water quality permits and feed and rendering licenses. The industry has voluntarily adopted internal biosecurity and stringent Code of Practices, namely:

GMPs. Good Manufacturing Practices are used to minimize product safety hazards by instituting basic controls or conditions favorable for producing a safe product. GMPs form the necessary prerequisite for hazard analysis control point programs (HACCP).

HACCP. HACCP programs form an important component of biosecurity and food safety measures during rendering. These require: (1) evaluation of the entire

rendering process; (2) identification of potential biological, physical or chemical hazards; (3) identification of critical points in the process where the hazard(s) can be controlled and (4) development of procedures to control these processes and insure the hazard is destroyed or reduced to acceptable levels.

Processing temperature and particle size are two central critical points, because the transfer of heat through the material at temperatures sufficient to kill biohazards within a given transit time depends on the interaction between processing temperature and particle size. Any material not meeting these standards is reprocessed!

Rendering, as we know it, was established in the United States more than 100 years ago. The industry has undergone significant consolidation during the past 30 years and most areas in the United States continue to be serviced by one or more renderers. Nonetheless statistics indicate that while in 1960 there were roughly 1,000 (mostly independent / non-captive) plants, in 2002 there were 260 facilities. The negative effects of this “shrinkage” were discussed elsewhere in our response.

The overall infrastructure includes industry organizations aimed to provide technical support and education in quality assurance and safety. The Animal Protein Producers Industry (APPI) administers industry-wide biosafety programs, HACCP training and certification, Salmonella reduction, continuing education and third-party certification for compliance with BSE regulations. The Fats and Proteins Research Foundation (FPRF) is engaged with industry and university research to address pertinent biosecurity, non-feed product, e.g. biodiesel, value, etc. issues.

Concluding, the rendering industry is uniquely positioned to provide critical components necessary to handle all raw materials safely and responsibly, including those that are considered, by science or perception, to be unsuitable for use in animal feeds.


Incineration is considered to be effective for destroying pathogenic organisms in hazardous waste. It is a superior method for inactivation of “prionic infectivity” (table 16). Incinerators can take a variety of forms from small animal incinerators to large commercial operations or even power station furnaces used in some cases to dispose of the products of rendering. Given large industrial incinerators are available it can offer an adequate scale of animal tissue disposal. That is not always the case.

Small capacity incinerators are fitted to handle carcasses up to about 40 pounds. The method is suited for poultry, companion animals, sheep but less so for cattle. The burning of carcasses in (large industrial) incinerators may be desirable in enzootics but there are a number of obstacles for their routine use (ref.5, 14, 38):

Availability of incinerator capacity is a serious limitation. An infrastructure for incinerating raw animal tissue material is not available currently!

Incineration is usually quite costly because the energy requirements are large. Bagley (ref.5) estimates that the cost of incineration is roughly 3 – 5 cents/pound, excluding transportation costs. Sander et al. (ref.31) stated that, depending on the local cost of propane fuel, the cost of incineration is close to 4.3 – 10.75 cents/pound. Moreover a 500 pound capacity incinerator costs approximately $3,000.00 and lasts about 4 years.

There are also a number of risks associated particularly with small (operating at less than 110 lbs/hour) incinerators. On January 16 – 17, 2003 the European Union Scientific Steering Committee (SSC) reported on the assessment of risks due to incineration of bovine tissue and opted against its use (ref.14).

An earlier 2001 report by Det Norske Veritas prepared for the British MAFF (now DEFRA) assessed the risks from small incinerators that receive bovine Specified Risk Material. DNV found disposal of ash and management (few facilities have specialists in incineration) as problems. Particulates, SO2, NO2, nitrous particles and deposition of dioxins into the food chain were quoted to be potential human risk.

Incineration produces air pollution (smoke and odor) and therefore poses environmental concerns. It also is known to cause more public nuisance complaints than other disposal methods.


Landfill disposal methods, despite the existing limitations, will continue to be important and necessary method for municipal waste disposal, but remains a poor choice for the disposal of animal carcasses and other products of animal origin (ref.20). In sharp contrast to rendering land filling does not allow disposal volume minimization. Amendments such as saw dust (one part saw dust to 3 parts by-product) must be added to compensate for the high moisture content of animal tissues when preparing for land fill. As a result the total volume would be increased by approximately one third. Thus treated the volume of animal by-products and mortalities in one year would occupy up to 25% of the existing landfill space at an estimated cost of $105.00 per ton (ref.35). The latter was regarded as conservative and did not include transportation costs.

If a landfill is to be used, the carcasses must be covered to hide them from public view and then hauled in a way to prevent leakage of carcass fluids. In other words a specialized hauler must be drafted as is already the case with rendering pick-up services. Landfill may not be open when needed plus many landfills may be reluctant to receive such material, which will increase considerably their burden (ref.5, 30, 37).

Decomposition of animal tissues proceeds in landfills slowly and at relatively low (1300 – 1500 F) temperatures, which limit pathogen destruction. The latter is important for couple of reasons:

There is an imminent risk that the exposure of landfill workers to pathogenic microorganisms will increase as more infectious material in the form of dead animal carcasses increases. In addition, the workers will be exposed to pathogenic microorganisms to which they have not been previously exposed (ref.20).
It has been calculated that the contribution to pathogen loads at landfills is

greatest for animals. While municipal solid waste, infectious waste from hospitals

(autoclaved prior to disposal), pet feces and soiled diapers combined make for

0.4% of the total infectious waste, 99.6% comes from animals (ref.20).

The exposure risk to animals, such as birds, insects and rodents would also be expected to increase (ref.20). Dependent on season birds are abundant at landfills and they may act as vectors in transmission of pathogens or their toxic metabolites. Rotting animal carcasses will serve to further attract birds to landfills increasing their exposure and risk to disease. For example, Ortiz and Smith (quoted in ref.20) linked the considerable mortality of seagulls in the UK to landfills which the bird frequent. The organism, Clostridium botulinum, was found in 63% of the landfills examined.

The information in Table 13 demonstrates that landfilling is inappropriate for disposal of prionic tissues. This is all the more significant considering the approach taken to CWD-suspect deer and elk disposal in Wisconsin, an issue which merits a more detailed discussion.

The Wisconsin Department of Natural Resources (WIDNR) opted for sanitary landfilling of cervid carcasses from their CWD Eradication Zone (ref.47, 48). There were an estimated 10,000 to 20,000 deer to be disposed of from the eradication area over a 6-months period. WIDNR assumed that, each deer averaging 150 pounds, an estimated 750 – 1,500 tons of deer carcasses will be placed in land fills for disposal. In a Briefing Paper (ref.47) issued on June 6, 2002, the WIDNR offered a remarkable line of reasoning, quote (cursive ours):

“While there are no absolutes with any risk assessment and risk management decision, the Department believes, given the known science of CWD, the risk of spreading the disease to healthy animals or the environment from the disposal of deer in sanitary landfill is miniscule.”

“Landfills generate a certain amount of liquid termed leachate, which is collected and processed…. The leachate is collected at the base of the waste just above the liner. In most instances the leachate is transferred to a wastewater treatment plant (WWTP) for treatment. Less commonly, some landfills may recirculate a portion of the leachate. At the WWTP, the leachate is processed along with waste water. Solids are separated from the water portion. This material, termed “sludge” or bioslids is commonly applied to farm fields or landfill.”

“The prion [protein is a hydrophobic material. This biochemical property makes it attach to other molecules, particularly solids and particulate material, in general (Gale et al., 1998). Because landfills are composed primarily of solid waste, the prion protein will have affinity for this solid material and remain tightly bound to the solid waste, cover material and other solid particles in the landfill.

“In the only experiment to examine the fate of PrP-res in an outdoor environment, Brown and Gajdusek (1991) buried perforate Petri dishes containing hamster scrapie in a residual garden for three years. They found that approximately 1% of the original infectivity in the original location survived this term. Examining surrounding soil layers, no infectivity was found above the original location, a small infectivity was found in the 4 cm soil layer below the dish. The authors conclude that the hamster scrapie agent used in this experiment can persist in contaminated soil for three years under natural environmental conditions, but there is little leaching to surrounded soil layers. To date there has been no further work that specifically examines the fate of TSE agents in the soil/solid waste environment.”

The above line of reasoning is not only spurious, because it relies on flimsy evidence and extrapolations, but more importantly because it flies in the face of huge body of scientific evidence about the extraordinary resistance of prionic proteins (ref. 28, 38). The methodology on which WIDNR is relying may not achieve the ultimate purpose of elimination of prionic contagion and, as further argued, it may disseminate contagion in the larger environment. On the one hand, we have regulatory authorities focused on non-existent risk as far as BSE is concerned while, on the other, an entire state is basically spreading proven TSE material around, somehow escaping critical scrutiny by the same regulators. It is particularly disturbing when two firms offered their services to render (primary processing) the deer carcasses and then dispose of the final product by additional safe treatment (combustion).

The meticulous research performed by Det Norske Veritas (ref.11) is a solid rebuttal to the laissez faire approach of direct land filling CWD-suspected animals, quote:

“Neither deep burial or landfilling are allowed within the EU for disposal of potentially contaminated materials. Landfilling is currently used in the EU as means of disposal for low risk material, which has undergone primary processing. These have no inactivation capacity other than natural decay, dilution and leaching.”

“If burial or landfilling are to be considered as a disposal option, a site specific risk assessment must be undertaken to ensure that there are no watercourses that can become contaminated by the material being buried.”

“There is little data on the possible degradation of the BSE infective agent in the environment over time. The one report study is that of Brown and Gajdusek (1991)

… This one experiment indicated a reduction in infectivity of between 98 and 99.8% over three years. There is no basis on which to extrapolate this result over a longer time period or to carcasses or pre-treated material.”

In other words, if one had only paid the needed attention to the events in Wisconsin, then the following realization would have emerged:

* Landfilling is not allowed for TSE infectious material to start with.

* The state bluntly, but rather unjustifiably, refused to consider primary treatment through rendering.

* While we don’t know over how many licensed (lined with HDP plastic) landfills the 1,500 tons of deer carcasses were spread, the volume of leachate accumulated from those, while admitting that in the process there would have been some further prionic material dilution, cannot be dismissed as insignificant.

* The routine WWTP treatment of leachate can not conceivably reduce prion infectivity.

* Even worse, as proposed by WIDNR, the biosolids (with the hydrophobic prions comfortably attached!) were to be concentrated and then spread onto farm lands. In other words, non-inactivated and with an unproven rate of natural degradation of prionic material, is applied onto (farm) landscape. The incorporation of this concentrated protein material into plants can only be speculated, but the oral ingestion of protein particles attached to plants by cattle and, more importantly, susceptible deer through grazing can not brushed aside.

The above stated is even more pertinent considering the WIDNR statement, i.e.

“In contrast to interspecies transmission of CWD from deer to human, there is good evidence that deer and elk can contact CWD by animal-to-animal contact as well as by contact of a susceptible animal with contaminated environment.”

The WIDNR approach could not have mitigated the CWD contagion. To the contrary, if what was suggested did indeed take place, it actually helped to concentrate and propagate prions downstream. Concluding, do we want to repeat the Wisconsin public policy debacle?


Composting is an approved method of disposal in most states, although strict regulations are often in place regarding the site, structure, size and type and the amount of livestock that can be composted at a single location (ref. 16, 25, 36). The method is considered par excellence suited for disposal of hatchery offal and cull / dead poultry. Composting is an aerobic process for controlled biological decomposition and conversion of solid organic material into a humus-like substance called compost. The other products of composting are water, vapor, carbon dioxide and heat. According to Sander et al. (ref.31) the costs of

composting approximate 2.1 to 8.4 cents per pound (not including transportation?). There are several important principles to be followed in order to maintain successful composting, which make composting a method requiring intensive management oversight and unsuitable to initiate during certain seasons (ref.5, 25):

* Aeration: It demands periodic “turning” of the compost or providing air tubes within the pile.

* Carbon to Nitrogen Ratio (ideally 25:1): The carcasses provide the nitrogen, whereas plant material such as sawdust, wood shavings or rice hulls. For every pound of mortality usually a pound of sawdust is required, which increase the cost of composting. The presence of too much nitrogen, especially ammonia, may result in odor problems. The presence of too much carbon will result in very slow composting process.

* Moisture: 40% - 60% moisture is essential, because too much results in odor problems and too little in slow or incomplete composting.

* Temperature: Bin compost can be maintained at 1350 – 1450 F, with animals less than 300 pounds. A single large pile will reach only 1000 F. However, heat is one of the major problems of composting because at least 1310 F is needed to destroy disease causing microorganisms. Large animals, such as mature cattle, must be cut into small pieces prior to placing into composting bin (labor!). It takes for example 9 – 10 months on the average to compost intact pig and cattle carcasses (ref.31). The thick hides of cattle tend to be unsuitable for composting and require additional cycles to complete the process. The extremely heat-resistant TSE prions cannot be destroyed by temperatures achieved even when composting is done properly (ref.13, 38). While finished compost can be spread on crop ground as fertilizer, if prions are present and the compost is used as fertilizer prions can re-enter the food chain through grazing plants and hay and straw obtained from those. Thus, composting should not be used to dispose of CWD deer and elk, sheep and goats with scrapie or cattle with BSE. Composting is especially unsuitable for specified risk materials, especially neural tissues (skull and spinal cord) encased in bones (ref.11). The indiscriminate use of composting and spreading its by-products on agricultural land is inconsistent with the FDA feed rule, would dilute its integrity and invalidate all existing BSE/TSE risk assessment models (ref.8). This is similar to what may have transpired with the CWD material, given the WIDNR disposal policy (refer to 2.3. Controlled Land Fill) was indeed implemented.

Composting does not destroy bacterial (anthrax, clostridial, etc.) spores. When carried out improperly or incompletely it is unable to destroy even vegetative forms of bacteria (ref.10). Thus the compost per se could, under many circumstances, become a source for spreading pathogens, such as coliforms, salmonellae, pseudomands, etc. (ref.27).

Notwithstanding its advantages and popularity, especially in the Mid-West, composting is rather finicky process and requires substantial supervision and know-how, both of which are not a given under all circumstances. Because of these intensive management requirements, many producers and other generators of raw materials claim to use composting as a disposal method, when in fact the materials are not composted, but left to rot (R. Hamilton, personal communication).

Flies, mosquitoes (West Nile encephalitis vectors), rats, wildlife, etc. are often attracted to compost and act as reservoirs for spread of contagion. Thus while composting appears to serve the need for disposal of certain forms of solid waste, it poses severe limits in addressing the challenges of animal and animal by-products disposal (ref.16).


Individual burial is allowed in some locations, but prohibited in others, even on the producer’s own land. Soil type, topography, distance to wells, depth of groundwater, available equipment, weather, and climate are few of the variables that influence whether this option can or should even be considered for individual producers (ref.36).

Where allowed there may be specific restrictions on the number of pounds buried per acre per year. For instance, Missouri has a maximum loading rate of 7 cattle, 44 hogs or 47 sheep on any given acre of land per year, where ground water pollution is not a concern. Burial is not a viable option in many states because of demographics and/or potential for contamination of (high water table) ground and surface water. It does require the use of large equipment, since for cattle and horse carcasses a trench 7 feet wide by 9 feet deep is typically required. A mature cow requires 14 square feet trench floor space (ref.5). Burial may be an option for the small producer but large operations, such as dairy and hog farms, quickly run out of space, a major limiting factor to this method.

Besides there are other major objections to burial, especially when dealing with carcasses and other materials that might contain BSE/TSE infected material (ref.15):

Buried organic material is normally decomposed by microbial and chemical processes, but not a method amenable to control measures;

There is little reliable information on the extent and rate of BSE/TSE infectivity reduction following burial. A 1991 study by Brown and Gajdusek
(ref.7) assumed a reduction of 98% over 3 years. However, it is noted that the rate of degradation can vary considerably from site to site;

Burial sites may have a thriving animal population and uncovering risk material that is not deeply buried is therefore possible.

The Sparks study investigated the labor and costs required for this method of organic material disposal and reported that:

20 minutes will be needed to bury a 500 pounds size cattle, 10 minutes for calves, weaned pigs and other mature livestock and 10 minutes for each group of pre-weaned pigs
labor costs were estimated at $10.00/hour and equipment (rental or depreciation of a backhoe) at $35.00/hour

the assumptions made suggested a total annual cost to livestock sector, if burial were employed for all livestock mortalities, of $109,900,000.

Nonetheless, when the cost/hundred weight of raw material disposal was compared for all options – enzymatic digestion, landfill, composting, incineration, burial, rendering for disposal and rendering for “feed grade” – burial costs were the lowest and very close to the cheapest, i.e., rendering for “feed grade” (ref.31, 35, 36). The low costs of this method are offset by a profound disadvantage – lack of accountability / traceability, which is major impediment to surveillance of infectious diseases in cases of major concentrations of livestock, such as in the US. Therefore, rare exceptions aside, burial as a method of animal disposal should not be allowed on a routine basis or even considered seriously as an option.

The environmental and public health risks related to uncontrolled animal burial are further exemplified by two diseases: anthrax and cryptosporidiosis.

A disease like anthrax provides a fitting semblance of the concerns associated with environmental contamination in the process of burial, if proper controls are not carefully enforced (ref.16, 17). Regardless of the environmental and physical conditions required to perpetuate contagion on a premise the following chain of events

Organism à susceptible host à disease à death à dissemination of organisms

is the standard anthrax transmission cycle. The Bacillus anthracis spore is impervious to physical inactivation by environmental heat, cold, desiccation and highly resistant to chemical inactivation with disinfectants. Thus there is a need to establish the role of soil contamination as an important source of spread of the disease.

Cryptosporidium is a parasite commonly found in lakes and rivers, especially when the water is contaminated with sewage and animal material. This parasite is very resistant to disinfection, and even a well-operated water treatment system cannot ensure that drinking water will be completely free of it. Waterborne cryptosporidiosis is a major public health problem and of particular importance for severely immunocompromised individuals.

In 1993, Cryptosporidium caused 400,000 people in Wisconsin to experience intestinal disease. Over the past several years there have also been cryptosporidiosis outbreaks in Nevada, Oregon and Georgia, in which animal disposal and resulting soil and ground water contamination were implicated (ref.45, 46).


This method concerns to either alkaline hydrolysis, whereby the use of heat and strong alkali are used to leave peptide under pressure, or proteolytic enzyme digestion using enzymes such as pronase, proteinase K and QuaigenTM (ref.11).

Their applicability to large scale disposal operations is questionable for various reasons. Capacity is serious impediment. The US manufacturer of the alkaline hydrolysis equipment, WR2, speaks of small and very small slaughterhouse application (ref.3).

In view of the TSE’s the proteolytic enzyme treatment cannot be regarded as a reliable method of prionic inactivation. The alkaline hydrolysis procedure has been tested in Europe and it was found that after 3 hours there was detectable infectivity, but not after 6 hours. The conclusion was reached that by-products from this treatment could contain BSE/TSE infectivity. Besides, the direct discharge of the liquid residues to a sewer is not appropriate without additional treatment (ref.11). The latter add to the already high costs of this method.

The use of potentially hazardous materials, relatively high start up and substantial operating costs are important operational handicaps of the alkaline procedure. Also, its throughput and capacity are limited, the current largest system being approximately 4 metric tones per day.

The State of Nebraska has considered provisions to legislate enzymatic digestion of livestock (R. Hamilton, personal communication). However, only livestock carcasses weighing up to 30 pounds may be utilized for the purpose. While the method is clearly in its very early R & D stages, it is improbable that it can be used for routine purposes.

The so-called biosphere process, based on autoclaving at 1990 C and 12 bars pressure,

is also mentioned as a means for organic material disposal. The method may be suited for treating limited volumes of BSE infected specified risk material, but start-up costs are relatively high and no vessels are available for immediate use. The throughput (30 metric tons / day, based on 5 metric tons/cycle and 4 hour cycle time) is clearly a major limitation (ref.11).


Comment: Tables 1 & 2 are incorporated into the text of the main response. Tables 3 through 16 are shown in this appendix

Table 3: U.S. Cattle & Calves Population per January, 2001

(Source: ref.36)

Classification Approximate Age 1999 2001

Cows & Heifers that have calved 24+ months 42,878,000 42,603,000

Beef Cows 33,745,000 33,400,000

Milk Cows 9,133,000 9,203,000

Heifers, that had not calved, 500+lbs 7 – 24 months 19,774,000 19,775,000

- Beef Cow replacers 5,535,000 5,588,000

- Milk Cow replacers 4,069,000 4,047,000

- For slaughter 10,170,000 10,140,000

Steers 500+lbs 7 - 24 months 16,891,000 16,438,000

Bulls 500+lbs 7+ months 2,281,000 2,272,000

Total Cattle, 500+lbs 7+months 81,824,000 81,008,000

Average Annual Calf Crop 37,796,000 38,400,000

Calves < 500lbs per January, 01 0 – 6 months 17,290,000 16,221,000

Cattle on Feed per January, 01 13,219,000 14,199,000

Table 4: Average Edible & Byproduct % Yield Estimated by Weight

(Source: Darling International, Inc.)

Bovine Ovine Porcine Avian


Edible meat % yield 47.2 42.9 56.7 67.5

By-products % yield 43.8 42.6 38.5 22.0


Table 5: Livestock Mortalities in the United States in 2000

(Source: ref.36)

Farm Mortalities % of Farm Mortalities

Total Mammalian

Species Number (‘000) Weight (‘000lbs) Number Weight Number Weight

% %

Dairy Cattle 804 449,227.3 0.8 13.5 3.5 15.1

Beef Cattle 3,327.8 1,482,952.5 3.2 44.6 14.5 49.8

Hogs 17,927.7 981,655.2 17.0 29.5 78.3 33.0

Sheep 281.5 21,957.0 0.3 0.7 1.2 0.7

Lambs 486.2 37,923.6 0.5 1.1 2.1 1.3

Goats 65.0 4,225.0 0.1 0.1 0.3 0.1



Mammalian 22,892.2 2,977,940.6 21.7 89.6 100.0 100.0


Chicken 50,507.0 154,950.7 47.9 4.7

Turkey 31,946.5 191,679.0 30.3 5.8


Grand Total 105,345.7 3,324,570.4 100.0 100.0 100.0 100.0

Table 6: Cattle Mortalities in the United States, 1999 – 2000

(Source: ref.36)

1999 2000

Cattle 1,659,000 1,721,800

Calves (<500lbs) 2,454,800 2,410,000

Total 4,113,800 4,131,800

Table 7: Estimated Age Distribution of Cattle Mortalities in 2000

(Source: ref.36)

Dairy Beef Total

Age (months) Number % Number % Number %

0 – 6 513,300 12.42 1,896,000 45.90 2,410,000 58.33

7 – 12 30,700 0.74 337,300 8.16 368,000 8.91

13 – 24 60,800 1.47 352,700 8.54 413,500 10.01

25 – 48 123,200 2.98 338,200 8.19 461,400 11.17

49 – 72 61,000 1.48 283,600 6.86 344,600 8.34

73 and > 15,000 0.36 119,300 2.89 134,300 3.25

Total 804,000 19.46 3,327,800 80.54 4,131,800 100.00


% = Percent of combined Dairy & Beef numbers

Table 8: Estimated Age Distribution Cattle Mortalities by Weight in 2000

(Source: ref.36)


Dairy Beef Total

Age (months) Volume (lbs) % Volume (lbs) % Volume (lbs) %

0 - 6 100,918,500 5.22 286,136,500 14.81 387,054,900 20.03

7 – 12 19,821,800 1.03 195,174,400 10.10 214,996,200 11.13

13 – 24 61,559,300 3.19 272,452,900 14.10 334,012,200 17.29

25 – 48 156,493,200 8.10 313,378,700 16.22 469,872,000 24.32

49 - 72 88,004,700 4.55 292,668,100 15.15 380,672,800 19.70

73 and > 22,429,800 1.16 123,142,000 6.37 145,571,800 7.53

Total 449,227,300 23.25 1,482,952,500 76.75 1,932,179,800 100.00

% = Percent of combined Dairy and Beef numbers

Table 9: Number & Weight of Hog Mortalities in the United States (Source: ref.36)


1999 2000


Number Weight (lbs) Number Weight (lbs)

Market Hogs 5,584,300 635,986,300 6,132,700 660,691,600

Breeding Hogs 690,700 241,751,100 727,300 254,557,400

Weaned Total 6,275,000 877,737,400 6,860,000 915,249,200

Pre-Weaned Hogs1 11,291,800 67,750,600 11,067,700 66,406,200

Total Loss 17,566,800 945,488,000 17,927,700 981,655,200


1assuming about 9.7% annual losses for all hog farrowings

Table 10: Number & Weight of Sheep, Lamb & Goat Mortalities in the U.S.,

1999 – 2000 (Source: ref.36)

1999 2000

Number Weight (lbs) Number Weight (lbs)


Sheep 260,800 20,324,400 281,500 21,957,000

Lambs 481,900 37,588,200 486,200 37,923,600

Goats 67,500 4,387,500 65,000 4,225,000

Total 810,200 62,318,100 842,700 64,105,600

Table 11: Number & Weight of Poultry Mortalities in the United States

(Source: ref.36)

1999 2000

Number Weight (lbs) Number Weight (lbs)

Chickens 54,951,000 162,218,600 50,507,000 154,950,700

Turkeys 32,186,300 193,117,700 31,946,500 191,679,000

Total 87,137,000 355,336,300 82,453,500 346,629,700

Table 12: Estimated Number of Dead Stock Rendered in the United States in 2000 (Source: ref.36)


Species Dead Stock (lbs) % of Deaths Meat and Bone Meal (lbs)1

Cattle 869,480,910 45.0 241,715,690

Pre-weaned Hogs 35,261,690 53.1 9,802,750

Weaned Hogs 622,369,300 68.0 173,018,700

Sheep, Lamb & Goats 32,052,800 45.0 8,910,680


Total 1,559,164,800 lbs 52.4% 433,447,790 lbs


1 assumes MBM yield of 27%

Table 13: U.S. Production of Rendered Products (Source: ref.44)


1998 1999 2000 20011 20021

Production (million pounds)



Inedible Tallow & Greases 6,575.0 7,075.8 7,149.4 6,870.0 7,214.8

Inedible Tallow 3,611.6 3,859.1 3,889.9 3,757.2 3,772.8

Greases 2,927.6 3,171.8 3,221.2 3,176.8 3,442.4

Edible Tallow 1,536.8 1,729.3 1,840.4 1,845.0 1,968.0

Lard2 544.3 535.9 517.9 403.2 386.1

Subtotal 8,656.1 9,341.0 9,507.7 9,118.2 9,568.9

Meat Meal & Tankage 5,535.1 6,058.7 5,759.4 5,530.8 5,542.9

Meat & Bone Meal 4,236.0 4,713.7 4,399.8 4,325.9 4,463.4

Dry Rendered Tankage 1,260.6 1,285.1 1,311.5 1,194.3 1,080.3

Feather Meal 807.2 836.1 810.5 779.6 798.2

All Other Inedibles3 2,287.7 2,531.3 2,723.6 2,772.8 2,908.3

Total 17,286.1 18,767.1 18,801.2 18,201.4 18,818.3

1 = Preliminary data compiled by summing information from M311K reports; subject to change.

2 = Not included in the Census report; estimated by adding reported lard consumption and exports.

3 = Includes only poultry fat and by-products meal, blood meal and raw products for pet foods.

Table 14: Feed Mill’s Usage (Average %) of Selected Animal Diet Ingredients in the United States, 1998 – 2002 (Source: ref.24)


1998 1999 2000 2001 2002

Meat and Bone Meal 67.7 73.2 55.6 42.7 39.3

Dried Plasma 48.3 43.7 36.5 46.3 20.2

Porcine Byproduct 43.5 25.4 27.0 43.9 28.6

Poultry Byproduct 24.1 18.3 23.8 22.0 36.9

Feather Meal 40.3 40.8 39.7 37.8 29.8

Total Average: 44.78% 30.96%


A total of 400 feed US mills, commercial and integrated, were surveyed. In 2002 only 40% of the US feed mills report using animal protein ingredients. This compared with 76.2% in 1997 and 73.0% in 1999, respectively.

Table 15: Methods of Animal Disposal & Related Public Health Risks

(Source: ref.42)


Disposal Method Potential Public Health Risk

Rendering None identified

Incineration None identified

Licensed Landfill Leaching unlikely, but leachate may

include additional components

(biosolids) from animal carcasses

Mass Burial * Lined sites: see Licensed Landfill

* Unlined sites: Contamination of ground

water sources

On-Farm Burial * Contamination of ground water sources

* Prion retentiona

* Anthrax

Pyres * Air pollutants: NO2, SO2, particles, PAH

dioxins, furans and PCB’s

* Potential dioxin entering in the food chain

* Potential for carcass ash retaining prions

Carcasses awaiting

disposal Ground water contamination depending
on state of purification and type of ground

a especially sheep, goats and cattle older than 5 years

Table 16: Comparative Efficacy of Animal / Animal Byproducts Disposal Methods

for TSE Agent Inactivation (Source: ref.11)


Development Method Inactivation Scale of Application


Proven Incineration +++ +++

Rendering & MBM incineration +++ +++

Rendering only ++ +++

Rendering & burial ++ +++

Rendering & biodiesel (tallow) +++ +++

Burial ? +++

Digestion (alkaline) & burial +++? ++

Landfill ? +++

Burning (biodiesel) +++ +++

Promising Biosphere ? ++

Brooks gasification ? ++

Under research Proteolytic digestion ? ?

Miscellaneous Radiation - ?

SDS detergents ++ ?

Sodium hypochlorite +++ ?

Organic solvents - ?

Unknown Composting - / ? +++

- negligible or no prion inactivation; ++ moderate prion inactivation & scale of use

+++ high degree of prion inactivation & large scale of use



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