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Renderers say industry not prepared for FDA feed ban rule

flounder

Well-known member
-------------------- [email protected] --------------------


Two recent articles caught my eye ;

Renderers say industry not prepared for FDA feed ban rule

Food Chemical News

February 2, 2009

and

BSE, rendering relate to human safety

Emma Struve 02/17/2009

To enhance protection of the human food supply, the Food and Drug Administration (FDA) will institute a new rule April 27, 2009. This rule prohibits brain and spinal corn material from cattle over 30 months of age from entering the animal food supply.

Ultimately, the goal is to further decrease the likelihood that cattle may become infected with Bovine Spongiform Encephalopathy (BSE) thereby reducing the risk that infected animals will enter the human food chain.

An additional consequence stemming from implementation of the rule is that livestock producers will have a more difficult time disposing of carcasses.

Crawford County Supervisor John Lawler said of the disposal issue, "We've got a problem here, we all know about this, with these cattle."

At this point policy makers and livestock producers are examining available information to formulate a plan for how to adopt changes necessary to comply with the rule.

What is Bovine Spongiform

Encephalopathy (BSE)?

BSE is an infectious disease of cattle that causes physical deterioration of the brain and spinal tissues resulting in a "wasting" appearance of the animal, according to the USDA Animal and Plant Health Inspection Service (APHIS) overview of BSE.

Through research, scientists have found that the most common manner of infection is when a healthy animal consumes feed that contains protein rendered from an infected ruminant animal.

A BSE related human prion disease called variant Creutzfeldt-Jakob disease (vCJD) became scientifically known in 1996. Those afflicted with vCJD are assumed to have acquired the disease by consuming food containing protein from BSE infected cattle.

Some current regulations concerning BSE materials in the United States

In 1997 the FDA prohibited the use of mammalian protein in feeds given to ruminants (cattle, sheep, and goats).

The Food and Drug Administration (FDA) along with the Food Safety and Inspection Service (FSIS) instituted rules that removed from the human food supply risk materials where prions (infective proteins) might be found.

Since 1990 APHIS has conducted BSE surveillance and about 800,000 animals in the United States have been tested since the program started. Three cases of BSE have been identified.

What is the new regulation?

On April 25, 2008 the FDA published a rule to prohibit the use of some materials of cattle origin in animal food. The rule will take effect April 27, 2009 and can be found in its entirety at

www.fda.gov/OHRMS/DOCKETS/98fr/08-1180.htm.

Who is affected by the new regulation?

Companies that render deceased cattle over 30 months of age will be required to modify their procedures in order to assure and prove the brain and spinal cord material of these animals did not enter the final product, typically meat and bone meal.

David Kirstein, representative for Darling International, a rendering company that serves Iowa livestock producers, stated that the company is not yet sure how to handle the issue.

"Darling has a lot of facilities across the United States...different plants with different capabilities," Kirstein continued.

Simply removing the material after collecting the whole animal is "not an easy task" for renderers. Customers of Darling can expect to be contacted in writing with changes planned for the very near future.

Livestock producers, especially those with beef producing cow herds or dairies, may have to find an alternative carcass disposal method if renderers cannot handle the banned materials.

Are there viable alternative methods of disposal?

Dr. David Schmitt, Iowa Department of Agriculture (IDA) and Land Stewardship State Veterinarian suggested four alternative carcass disposal methods: incineration, burial, landfill, and composting.

"Biosecurity is very important," Schmitt insisted. He stressed the need for proper disposal and people to be responsible.

What are the applicable local regulations regarding disposal?

Incineration, Schmitt said, can only be done by approved enclosed facilities. Open burning is prohibited.

Burial sites for livestock carcasses must be located specified distances from water sources and, in well drained soil, no deeper than six feet with at least 30 inches of cover, and with a maximum density of seven carcasses per acre. A full listing of rules is provided by the DNR at

www.iowadnr.gov/afo/disposal.html.

The rules for burials were designed to protect public and private water sources from the potentially harmful materials released during decomposition, explained Schmitt.

To accept carcasses is at the discretion of each individual landfill. Marry Wittry, director of the Carroll County Solid Waste Management Commission, said that the Carroll landfill board of directors that makes the final policy determinations has not "taken a position on whether or not they will accept cows."

Dr. Thomas Glanville, Iowa State University professor in the Department of Agricultural and Biosystems Engineering, conducted a three-year composting study and found that carcasses, except large bones, were decomposed in less than a year. An in-depth discussion of Glanville's research is available at www3.abe.iastate.edu/cattlecomposting/index.asp.

There is no permit required to compost livestock on the farm that owned them, although a solid waste disposal permit is required, and may be obtained through the DNR, to start a communal compost pile or business.

Additional assistance is available from local USDA's Natural Resources Conservation Service (NRCS) offices in planning to construct an animal mortality composting facility and determining its suitable site and size. Financial assistance may also be available through the Environmental Quality Incentives Program (EQIP).

http://www.dbrnews.com/site/news.cfm?newsid=20263994&BRD=2703&PAG=461&dept_id=555123&rfi=6

BOO-HOO-HOO pity them $$$ all they way too the bank.

they have flouted TSE regulations for too long.

Déjà-vu, the renderers have been fighting BSE/TSE regulations from day one $$$



snip...


same old song and dance, just different day. it will be interesting to know what the final decision of Agricultural Secretary Tom Vilsack will be on this same old song and dance $$$



see full text ;



Saturday, February 21, 2009 Renderers say industry not prepared for FDA feed ban rule ??? WHAT, IT'S 2009 FOR PETE'S SAKE $$$ Two recent articles caught my eye ;

Renderers say industry not prepared for FDA feed ban rule

Food Chemical News

February 2, 2009

and

BSE, rendering relate to human safety

Emma Struve 02/17/2009


http://madcowfeed.blogspot.com/2009/02/renderers-say-industry-not-prepared-for.html




-------------------- [email protected] --------------------
 

flounder

Well-known member
The TSE (Transmissible Spongiform Encephalopathy) Committee discussed the impending FDA feed rule, including recommending a supplier certification form drafted by lawyers for Valley Proteins. Michael Koewler, Sacramento Rendering Company, said the California Department of Food and Agriculture has been proactively working with his company to develop inspection parameters to comply with the rule, and highly suggested contacting the dairy industry to educate them on the impact of the new rule. Jim Hodges, American Meat Institute, said the rule will only affect about 15 percent Convention Continued from page 11 Randy Blach, Cattle-Fax, tackled explaining the effect lower financial markets are having on agriculture commodity prices. It wasn’t all doom and gloom as these renderers enjoyed reminiscing. From left is Howard Murray, Sanimax/Kendallville Fertilizer, James Otto and Roger Zehe, Ohio By-Products (both retired), and Richard Stradtman, Florida By Products. of total U.S. cattle slaughter, but that the burden will fall on cow slaughterers. Spinal cord removal is not a concern as it has been removed all along, but removal of the brains will be more challenging. Hodges said the big issue is lingering questions about what constitutes compliance. While very few questions were answered, renderers took turns voicing their continued opposition to and concern over FDA’s new rule. Dr. Don Franco, past president, APPI, said there is no evidence that the infectious bovine spongiform encephalopathy (BSE) agent exists in the U.S. cattle population, that of the three cases detected in the country since December 2003, one was in an imported animal from Canada and the other two were atypical cases and not related to feed. Franco also pointed out the industry has a consistent 95 percent or better compliance rate with the feed rule put in place in 1997.

Clearing Up the Confusion of the New Feed Rule

As the calendar inches closer to April 27, 2009, renderers, meat packers, feed manufacturers, farmers, and other related industries are trying to sort out exactly how the new Food and Drug Administration (FDA) enhanced feed rule will affect them. In an effort to help meat packers and renderers sort it all out, the National Renderers Association (NRA), FDA, and the American Meat Institute (AMI) co-sponsored a webinar in mid-November.

FDA’s Burt Pritchett, Division of Animal Feeds, said the agency’s guidance document, of which a draft was published in the November 26, 2008, Federal Register (see page 31), will answer many questions the industry has on how to comply with the new rule, but that the guidance document is not prescriptive. Pritchett said the new rule expands safeguards against bovine spongiform encephalopathy (BSE) already put in place by FDA’s 1997 feed rule, and used Canada’s investigation of that country’s thirteenth BSE case discovered in June 2008 as an example of why further safeguards are needed. The Canadian Food Inspection Agency determined cross-contaminated feed was most likely the reason a cow born in 2003 became infected with the disease. The United States has diagnosed only two native animals with the disease in June 2005 and March 2006, both of which were atypical cases. A third case diagnosed in December 2003 was in an imported animal from Canada. The new rule requires certain cattle material be prohibited in animal feed (CMPAF), and defines the material as:

• brains and spinal cords from cattle over 30 months of age;

• entire carcasses of cattle not inspected (ante mortem) and passed for human consumption

- unless shown to be less than 30 months of age, or

- brain and spinal cord are removed;

• entire carcasses of BSE-positive cattle;

• tallow derived from BSE-positive cattle;

• tallow from CMPAF if containing impurities greater than 0.15 percent; and

• mechanically separated beef made from CMPAF.

Currently, under 21 Code of Federal Regulations (CFR) 589.2000, mammalian material is prohibited in ruminant feed but can be used in other animal feeds and that rule will still apply going forward. The 2008 rule adds a new section to the CFR, 589.2001.

Cattle slaughterers already remove the brain and spinal cord in accordance with existing U.S. Department of Agriculture regulations that require removal of specified risk materials (SRMs) in cattle 30 months of age and older processed for human food. Under the new FDA feed rule, slaughter facilities will need to separate the brain and spinal cord from the rest of the SRMs if the animal is 30 months of age or older and the material is going to be rendered. FDA is not specifying what methods must be followed to remove the brain and spinal cord, just what the slaughter industry currently has in place. According to AMI’s Jim Hodges, most packers use a vacuum system for removal of both the brain and spinal cord. Even though slaughter facilities are not regulated and inspected by FDA, renderers are and should require their suppliers to have procedures and records in place to meet the new FDA requirements to ensure they are in compliance.

Downer animals are prohibited from entering the food chain but can continue to be rendered under the new rule, provided they are either under 30 months of age or the brain and spinal cord have been removed if 30 months of age and older. The same applies to dead stock received from farms. As for methods to determine the age of cattle, again FDA is not prescribing a particular method, just what industry standards are in place, such as animal identification, dairy herd records, dentition, body weight, or feedlot origin. Hodges said the packing industry primarily uses dentition to determine an animal’s age. Again, written procedures will need to be in place so renderers are assured suppliers are in compliance with the FDA rule. If suppliers prefer not to separate CMPAF, renderers must consider all material collected as CMPAF.

Under the new rule, all tallow from non-CMPAF sources may be used in non-ruminant feed, whereas tallow from non- CMPAF sources can only be used in ruminant feed if it contains no more than 0.15 percent insoluble impurities. Tallow from CMPAF can only be used in ruminant and other animal feed if it contains no more than 0.15 percent insoluble impurities. Specific analytical methods to determine those insoluble impurities include the American Oil Chemists’ Society Ca 3a- 46, or another method equivalent in accuracy, precision, and sensitivity. The rule states that tallow should be sampled at the point where it is ready to go into distribution.

The rule allows foreign countries such as Australia and New Zealand who are declared “negligible” for BSE by international organizations to petition the FDA for exemption from the rule requirements. Otherwise, all countries must comply with FDA’s new rule for those rendered products being exported to the United States. All countries must continue to comply with the 1997 feed rule.

As for the amount of material affected, FDA expects 28 million pounds of CMPAF from slaughter facilities will initially be disposed of in landfills. The agency is forecasting a 26 to 41 percent decrease in cattle mortalities being sent to rendering, translating to 363 million to 577 million pounds of material being disposed of by means other than rendering. This translates to a tremendous economic impact to the rendering industry, estimated by FDA to be anywhere from $64 million to $80.5 million per year. The agency estimates the cost to cattle producers will be from $28 million to $39 million per year due to lower cattle prices to offset segregation and disposal costs at slaughter, loss for cattle no longer rendered, and increased dead stock collection fees. The new rule also raises a big concern among the livestock industry about improper carcass disposal, which FDA does not regulate.

14 December 2008 • Render www.rendermagazine.com

Compliance Up to Renderers

It was agreed by all the webinar presenters that the burden of the new regulation will fall on renderers, with Shannon Jordre, FDA’s Division of Compliance, admitting the rule is directed at renderers. Inspections won’t begin until after April 27, 2009, and products in the channels of trade after that date must be in compliance. David Meeker, NRA, said some renderers who will be handling CMPAF will need to have their systems clear of the prohibited material by late January so suppliers need to check the deadline of the particular rendering facility they work with.

FDA estimates that less than 150 U.S. rendering facilities in about 30 to 32 states will be subject to the new rule. Jordre emphasized that enforcement of the new rule isn’t expected to be any different than current enforcement of the 1997 rule and that inspectors have already been trained in the new rule with another training session scheduled for spring 2009. So how do renderers comply with the rule, especially since there is no practical way of testing for brain and spinal cord in raw material, rendered products, or finished feed? Documentation, documentation, documentation.

Under the new rule, renderers who collect cattle material for animal feed must have documentation from each supplier that CMPAF has been removed and separated. NRA is recommending renderers use an “Annual Raw Material Supplier Certification/Undertaking” form that allows suppliers to verify they are complying with the rule if they are handling CMPAF material. The form specifies the type of plant collecting from, type of materials the plant handles, age of cattle material processed, and whether the supplier’s plant removes CMPAF from cattle 30 months of age or older.

Renderers should request a copy of a supplier’s written procedures to determine age of cattle and procedure to remove CMPAF. They should also ask suppliers how CMPAF or SRMs are being disposed of if not being collected for rendering – just for their own records. Suppliers need to be aware that they could be held criminally liable for false information provided to renderers.

How frequently raw material documentation needs to be updated will depend on the supplier’s operation and type of supplier, but documents should be updated at least once a year. Renderers who collect dead stock should request documentation on each collection. Documentation will provide renderers a “warranty” that suppliers are complying with the new regulation. The rule allows and even encourages use of a third-party certification, especially for slaughter facilities supplying to renderers.

The new rule also puts in place “marking” procedures intended to make clear to feed manufacturers that material containing CMPAF cannot be fed to any animals. Raw material that contains CMPAF must be marked by an agent visible to the naked eye, unless the material is to be rendered for the tallow. If the material is rendered, tallow exceeding 0.15 percent insoluble impurities and meat and bone meal must be marked. FDA is recommending one of several marking procedures used in Europe and Canada. Product intended for export must be labeled and marked in compliance with the importing country’s regulations.

For more information on the new rule, log on to www.fda.gov/cvm/bsetoc.html. R

14 December 2008 • Render www.rendermagazine.com



http://rendermagazine.com/assets/Dec08Render.pdf




>>>Dr. Don Franco, past president, APPI, said there is no evidence that the infectious bovine spongiform encephalopathy (BSE) agent exists in the U.S. cattle population, that of the three cases detected in the country since December 2003, one was in an imported animal from Canada and the other two were atypical cases and not related to feed. Franco also pointed out the industry has a consistent 95 percent or better compliance rate with the feed rule put in place in 1997.>>>



that's what i call living in a dream world. ...TSS


FACTS ;



http://madcowfeed.blogspot.com/2009/02/renderers-say-industry-not-prepared-for.html
 

PORKER

Well-known member
Cattle rendering can be done by composting. Its Cheaper.

Currently, under 21 Code of Federal Regulations (CFR) 589.2000, mammalian material is prohibited in ruminant feed but can be used in other animal feeds and that rule will still apply going forward. The 2008 rule adds a new section to the CFR, 589.2001.

Cattle slaughterers already remove the brain and spinal cord in accordance with existing U.S. Department of Agriculture regulations that require removal of specified risk materials (SRMs) in cattle 30 months of age and older processed for human food. Under the new FDA feed rule, slaughter facilities will need to separate the brain and spinal cord from the rest of the SRMs if the animal is 30 months of age or older and the material is going to be rendered. FDA is not specifying what methods must be followed to remove the brain and spinal cord, just what the slaughter industry currently has in place. According to AMI’s Jim Hodges, most packers use a vacuum system for removal of both the brain and spinal cord. Even though slaughter facilities are not regulated and inspected by FDA, renderers are and should require their suppliers to have procedures and records in place to meet the new FDA requirements to ensure they are in compliance.
 

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