The first few months of this year have been like a rollercoaster ride for the rendering industry, ever since the first U.S. case of bovine spongiform encephalopathy (BSE) was discovered in an imported cow in Washington in December 2003. Surprisingly, though, we’ve still got our heads above water. It has been a waiting game, as we waited for the U.S. Department of Agriculture (USDA) to come forth with its plans for an accelerated surveillance program for BSE and for the Food and Drug Administration (FDA) to publish its two previously announced interim final rules.
The BSE surveillance program administered by the USDA has targeted a so called “at risk” population of cattle to obtain a sufficient number of samples to meet international requirements and to truly determine whether BSE exists in the United States. In fiscal years 2002 and 2003, 20,000 samples were taken. These numbers far exceeded Office International des Epizooties, now the World Organization for Animal Health, requirements.
However, it did not satisfy critics who wanted more samples taken. They simply doubted the statistical calculations of certainty in sampling only 20,000 head out of approxi-mately 35 million head slaughtered annually. In fact, initially, in order to regain the U.S. beef export market to Japan, the Japanese government insisted the United States test every animal slaughtered for BSE. This dispute has not yet been resolved.
The USDA had decided to increase the surveillance number to 40,000 head annually for 2004. The at risk population fall into a category of animals that are considered to be most likely to have the disease if it were present. These are animals over 30 months of age showing neurologi-cal disorders or are non-ambulatory animals often referred to as downers.
However, in mid-March, USDA announced a dramatic increase in the number of animals to be sampled with a very ambitious program. Over a 12 to 18 month period, the goal is to test as many cattle in the targeted at risk population as possible – perhaps as many as 250,000 animals.
The increased surveillance program will require the participation of renderers. USDA has reached out to the National Renderers Association (NRA) seeking assurances that renderers will cooperate. The industry has stated its willingness to participate; however, many questions remain unanswered. How will the tests be administered? Will there be a quick test? How long will the renderer have to hold the animal waiting for the test results? What will it cost? Who will pay for it? Will USDA assist the farmer with transportation costs for the deadstock? The government and the livestock industry, including renderers, will be investing heavily in an accelerated BSE surveillance program to determine whether the disease exists in the United States.
Many of these questions were answered with USDA’s announcement. Seventy million dollars has been earmarked to fund this program, which will cover transportation and other costs incurred by industries participating in the surveillance. NRA is organizing meetings between renderers and the USDA/Animal and Plant Health Inspection Service officials to work out the details during the implementation period prior to the program’s start, which is anticipated for June 1, 2004.
We are still waiting for the FDA to publish their interim final rules subsequent to their January 26, 2004, announcement (see “Newsline,” February 2004 Render). FDA’s first interim final rule addresses products for human dietary supplements and cosmetics. As proposed, it could have a very negative effect on the tallow market. It would make only edible tallow available for the cosmetics industry. We believe this proposal overlooks the safety of tallow as well as the additional processing the oleochemical industry does to tallow at very high temperatures and under pressure before it is used in soaps and cosmetics.
The second interim rule restricts the use of ruminant blood as a ruminant feed, removes the exemption of plate waste from the feed rule, prohibits the use of poultry litter as a feed for ruminants, and imposes additional rules to prevent cross contamination.
In mid-February, the NRA, Fats and Proteins Research Foundation, and Animal Protein Producers Industry leadership met with acting FDA Commissioner Dr. Lester Crawford to express our concerns with several of the provisions in the January 26th announcement. Crawford listened tentatively as we presented the rendering industry’s position on the various points. He asked us to follow up the meeting with a letter further detailing these concerns. The letter, with the help and input from many people, was sent to Crawford and we are now waiting for the interim final rules to be published, hopeful with the industry’s concerns taken into consideration.
We’ve seen no new regulations or legislation since December 23, 2003, but some will most likely occur. We will continue to monitor the situation and meet with regulators and congressional members and staff to tell our story.
From the Association - April 2004 Render