A 75-day comment period ended February 24, 2005, and the Canadian and U.S. rendering industries took the opportunity to respond to the proposed amendments, pointing out that such regulations are not justified and only minimal potential risk reduction will be achieved at an enormous cost.
Under current Canadian regulations, meat and bone meal derived from ruminant and mixed ruminant material cannot be included in feed rations intended for ruminant animals. Existing regulation allows rendering ruminant and non-ruminant material in the same processing line provided that approved flushing procedures are adhered to between processing runs.
But in order to keep markets open for non-ruminant rendered products after Canada’s first case of BSE was discovered in May 2003, Canadian renderers have, where possible, resorted to trucking between facilities to achieve separation between ruminant and non-ruminant products. Canadian renderers feel this move has enhanced the effectiveness of the existing feed ban.
In their response to CFIA’s proposed amendments, the Canadian Renderers Association (CRA), whose membership represents more than 95 percent of Canada’s independent renderers, said that, “proposed amendments to the feed ban contemplate levels of separation already achieved in many instances. However, the requirements to separate specified risk materials (SRMs) from other ruminant material, and to dispose of SRMs in a prescribed manner, will impose difficulties of a practical nature which cannot be resolved without the construction of new processing facilities and without the designation of appropriate disposal sites.” CRA submitted a diagram that illustrates current processing practices and processing as proposed by CFIA.
CRA also “anticipates unwanted environmental consequences and compliance issues to flow from the amendments together with severe economic consequences to the beef industry as a whole.” The association expects incremental costs associated with the proposal to remove SRMs from feed, which are attributed to loss in value of rendered finished products and estimated disposal costs, to range from two dollars per head for cattle under 30 months of age slaughtered in facilities with separation (large facilities) to $20 per head for cattle slaughtered in facilities without separation (smaller facilities).
In its response, CRA stated that although science suggests that SRMs are the most highly infective part of an animal found to harbor the BSE prion, science also shows that infected material included in feed for non-ruminants poses no dangers to the health of non-ruminants.
“The problem with requiring that all SRMs be destroyed is that material currently considered safe for use in non-ruminant animal feed will suddenly be regarded as “toxic and dangerous” and the current scientific approach to the eradication of BSE will be replaced by the precautionary principal which could result in further unnecessary and extremely costly [to the public] amendments to the feed ban without any commensurate improvement in food or feed safety,” CRA states.
With regards to CFIA’s proposed amendment that “a fat that contains more than 0.15 percent insoluble impurities and that is or may contain a fat of ruminant origin” may not be used in animal feed, CRA has requested that the Canadian government acknowledge that all fat, regardless of source material, including SRMs, is indistinguishable providing it meets the requirement that it contain less than 0.15 percent insoluble impurities, which would be comparable to international standards.
CRA also recommended that any proposed amendments for Canada correspond to similar amendments being contemplated by the U.S. government.
The National Renderers Association (NRA), whose membership represents more than 98 percent of the rendering capacity in both Canada and the United States, and the Animal Protein Producers Industry (APPI) submitted joint comments that stated, “CFIA’s preliminary conclusion to remove SRMs and condemned and deadstock cattle and other ruminants from all animal feed and pet food is not warranted, and this and other BSE prevention measures proposed by CFIA are not scientifically, economically justified or environmentally friendly.” The NRA/APPI comments coincide with CRA’s, but provide additional support for the industry’s opposition to CFIA’s proposed amendments, including a detailed economic study by Informa Economics on the impacts of the Food and Drug Administration (FDA) advanced notice of proposed rulemaking issued in July 2004. The comments also referenced data from the Harvard Center for Risk Analysis that removing SRMs from all animal feed only reduced the number of new BSE cases from 3.5 to 3.1 over 20 years in a model that assumed an original introduction of 10 cases. The comments went on to say that when the removal of deadstock was added, the number of new cases dropped from 3.1 to 0.7.
All three organizations recognize the importance of BSE prevention measures to protect both cattle and public health and share CFIA’s and FDA’s commitment to strong BSE risk control programs based on scientific facts and practical justification that can be implemented effectively and consistently. However, the industry is concerned that control measures now proposed by CFIA might cause significant unintended consequences adversely impacting animal health.
Both sets of comments addressed other proposed amendments by CFIA.The complete response from CRA is available by clicking here, with NRA's/APPI's response available here. Both files are in pdf format.
International Report - April 2005 Render