The saying that you have many irons in the fire was never truer than right now. The rendering industry is faced with numerous issues that it must address. Some are real opportunities and others represent real challenges to the industry.
More Regulations Looming?
Bovine spongiform encephalopathy (BSE) continues to provide challenges to the industry. One would think the recent Harvard Center for Risk Analysis study would have answered many concerns. The study flat out said that there was a very low risk (researchers will never say zero) of BSE ever existing in the United States. The firewalls put in place by the government and industry have done a very good job of preventing the introduction of BSE.
With this said, both the Food and Drug Administration (FDA) and U.S. Department of Agriculture (USDA) are each now undertaking what is called an “advanced notice of proposed rulemaking (ANPR)” to potentially further impose restrictions on the use of rendered products and feed ingredients.
The FDA is reviewing the current feed ban and considering a revision of the list of exemptions. This is a continuation of the field hearing held last fall in Kansas City. The USDA is considering further restrictions on the use of rendered products from animals that die on the farm.
An ANPR is a very preliminary move in the development of proposing and developing a regulation. The purpose is to gather information relative to an issue before proceeding to write a rule. It often serves a useful purpose in making sure that all of the right questions are asked and to ultimately determine whether a rule is actually necessary. The National Renderers Association (NRA) is working with the USDA to make sure they have the necessary information as they proceed. We want to make sure they comprehend the magnitude of what they might be proposing.
The Transmissible Spongiform Encephalopathy Coalition has commissioned Sparks Companies to do a study on livestock mortalities and their potential costs and methods of disposal. This study will provide the kind of information we will need to proceed with our position. I think it will also be welcome information for the government agencies that are responsible for reviewing and developing any proposed regulations.
The General Accounting Office (GAO) just released their report on the steps taken by the government to prevent the introduction of BSE in this country. The GAO is the investigative arm of Congress. While the report did make certain recommendations that will be addressed, it is fraught with misinformation and inaccuracies. It essentially ignores the Harvard study. The USDA provided the GAO in its initial response several instances where the report was factually incorrect both scientifically and technically. The GAO chose not to correct its own report.
Senator Richard Durbin (D-IL) released a statement following the release of the GAO report that he will introduce legislation to address the recommendations of the report. NRA representatives have met with Senator Durbin’s staff to express the industry position. The legislation is being revised and not much is expected for several months. We will monitor this activity along with a coalition of other organizations that share our views.
Push Still On for Biodiesel Inclusion
Congress is actively looking at alternative fuels, including biodiesel, in several different pieces of proposed legislation. The farm bill will address bioenergy as both the House and Senate have their versions. The House bill calls for the inclusion of rendered fats and greases in any bioenergy program administered by the USDA. The Senate has an energy title that encourages the development of alternative fuels. We are working hard to make sure that rendered fats and greases, including yellow grease, are included in any definition that addresses biodiesel.
The American Soybean Association (ASA) is seeking tax incentives for biodiesel. In the February issue of Render, I reported that the ASA was seeking our support of the legislation in return for the inclusion of our products in the definition of biodiesel. They have since decided to go it alone without our help. This means we will aggressively seek ways to be included in their legislative efforts by going directly to members of Congress.
If Congress decides to provide incentives for the production of alternative fuels, it should be for all providers. A tax incentive for soybean producers for the production of biodiesel is a disincentive for renderers to even consider this potential market. We will simply ask for fairness.
Environmental Irons
We are also making progress in our efforts to have the Environmental Protection Agency (EPA) recognize the use of yellow grease and other rendered animal fats and greases as a fuel. We have petitioned the EPA to produce a guidance paper on fuel switching that will assist local and state agencies in issuing permits in a more timely and uniform manner.
The EPA recently published its proposed rule on effluent limitations guidelines and new source performance standards for meat and poultry products point source. This rule includes rendering facilities that render in excess of 10 million pounds per year. The 85-plus-page document is being digested and interpreted at this time. Renderers were required to provide survey information to the EPA in 2001. NRA will prepare a response to the proposed rule. If you would like a copy of the document, please let us know.
Other irons in the fire include our efforts to open new export markets and address the various rules and regulations of our customers in foreign markets. “International Report” in this issue of Render will tell you about the NRA leadership trip to Brussels, Belgium, to meet with European Union leaders and trade impediments we are trying to overcome.
Second Annual Fly-In
The second Congressional Fly-In will be June 10-12, 2002. We expect 30 to 40 renderers to come to Washington to carry our message to Congress and the administration.
These are just a few of the irons in the fire. I will continue to keep you up to date on these and other issues currently affecting our industry.
From the Association - April 2002 Render