In early October, the U.S. Food and Drug Administration released its latest proposals regarding the what rendered animal byproducts should be banned from animal feeds. The public comment period ends on December 19. Then FDA will make its final ruling.
A quick refresher course: FDA enacted the "1997 feed rule," banning the feeding of "ruminant-derived protein" to ruminant animals in 1997 after England's mad cow debacle.
The impact on the feed industry was immediate, with meat and bone meal of ruminant origin plummeting in economic value, even though the products still could be fed to non-ruminant animals such as swine, poultry and pets. Ever since then, the livestock industry has had a 'gut feeling' that more restrictive rulings were coming down.
Last year, FDA suggested it was indeed preparing a highly restrictive ruling that would put further bans on rendered slaughter products, plate waste (primarily recycled restaurant scraps), poultry litter and cattle blood products (blood meal and others). The potential loss of these feedstuffs would affect many cattle producers.
What FDA proposes
Revisions to the 1997 feed rule are major, but not the worst-case scenario. The following materials would be prohibited from all animal feed, including pet food:
- Brain and spinal cords from cattle 30 months of age and older.
- Brains and spinal cords from cattle of any age not inspected and passed for human consumption.
- The entire carcass of cattle not inspected and passed for human consumption if the brains and spinal cord haven't been removed.
- Tallow derived from the materials prohibited by this proposed rule if the tallow contains more than 0.15% insoluble impurities.
- Mechanically separated beef derived from the materials is prohibited by this proposed rule.
- The proposal isn't as restrictive as expected. It doesn't, for example, ban ruminant blood and blood products, poultry litter or restaurant scraps.
Byproduct processors also expected the new regulations to insist on separate dedicated equipment for the manufacture of ruminant versus non-ruminant feed. That requirement would have drastically increased production costs and been a logistical nightmare.
In making their decision, FDA apparently has closely watched USDA's expanded animal testing program. Since June 1, 2004, almost 485,000 animals considered "high risk" for bovine spongiform encephalopathy have been tested.
Only one US-born animal tested positive for BSE. That led FDA Center for Veterinary Medicine Director Dr. Stephen Sundlof to make the understatement of the year: "There appears to be very little BSE infectivity in the U.S." FDA delayed its decision until the testing program ran its course for over a year to see the magnitude of the BSE threat in this country.
Industry reactions mixed
Public comment on the proposed ruling has been mixed. The National Grain and Feed Association and the Pet Food Institute supported the ruling as an important, needed safeguard. Food safety advocates and consumer groups felt the new rulings weren't tough enough to protect the consuming public.
The National Renderers Association and the American Feed Ingredient Association expressed concern that handling and disposal of dead stock and "downers" will become a problem. The expected decline in demand for meat and bone meal will depress a significant part of the rendering business and may create a huge disposal problem.
Following the December 19 deadline for comments, FDA is expected to act quickly and publish the final ruling.
Bottom line: It's virtually certain that it will become more costly to dispose of dead and downer animals. Renderers will have no incentive to pick up at the farm. How much cattle prices will be impacted (based on reduced byproduct value and increased expenses) remains to be seen.