Quite frankly, the biggest impact to international trade occurred in December 2003 when the first case of BSE was found in the state of Washington. At that point, most markets for rendered products closed as had happened to Canada when they announced their first case of BSE in the spring of 2003. From that time forward, most export markets treated both the United States and Canada as having indigenous cases of BSE. The National Renderers Association (NRA) focused its attention on working towards opening markets to products that should not face trade restrictions such as animal fats and greases (including protein free tallow), and non-ruminant proteins. There was also an effort put forth in reviewing the World Organization for Animal Health (OIE) Terrestrial Animal Health Code Chapter on BSE to try and keep it as trade friendly as possible while still keeping it based on sound science.
Over the course of 2004 NRA was successful working in coordination with the USDA, Animal and Plant Health Inspection Service (APHIS), and the Foreign Agricultural Service in gaining access to many important markets for non-ruminant proteins and fats and greases and, rightfully so, that these products, according to the OIE, should not be banned. In fact, nearly all importers of tallow and other animal fats and greases resumed importing with the exception of China.
In regards to meat and bone meal in 2004, the United States lost export markets valued at over $100 million, and Canada over $15 million. Only a handful of countries still have import bans in place on non-ruminant proteins; however, until this new case was announced, all but Indonesia and Honduras had banned ruminant meat and bone meal.
The most significant impact to U.S. exports from the most recently reported case of BSE was that Indonesia closed its doors to imports of meat and bone meal. The NRA will have to work with APHIS to renegotiate import requirements. On the positive side, it does appear that the Indonesian officials are willing to come to the table. On the negative side, initially they are asking for the removal of specified risk materials and for the product to be cooked to a temperature of not less than 133 degrees Celsius for a minimum of 20 minutes at an absolute pressure of three bar, but hopefully they can be persuaded otherwise. Aside from Indonesia, the NRA is not aware of any further market closings.
OIE Changes in Category Complicate Matters
Another concern is where the United States and Canada will fall in the new classification system in the OIE BSE chapter. The latest BSE code chapter was recently approved at the OIE general session in May. Following is a synopsis of the changes made to the chapter.
The five-tier country categorization changes to the following three-tier system:
• Negligible risk
• Controlled risk
• Unknown risk
“Negligible risk” countries will be countries that met the prior provisions to be “BSE free” and “provisionally free.” These countries have not had an indigenous case of BSE. “Controlled risk” will be countries that have had an indigenous case of BSE but have mitigating measures in place. “Unknown risk” countries are those who do not have a surveillance program and/or mitigating measures. The United States and Canada would most likely fall under “controlled risk.” The dilemma that this creates is that according to the OIE standards, countries in this category should not export meat and bone meal for seven years since the last reported case of BSE. Also, the OIE chapter recommends the following procedures for meat and bone meal to reduce the infectivity of a potential BSE:
1. The raw material should be reduced to a maximum particle size of 50 millimeters before heating.
2. The raw material should be heated under saturated steam conditions to a temperature of not less than 133 degrees Celsius for a minimum of 20 minutes at an absolute pressure of three bar.
There were further changes in the chapter with regards to surveillance testing. Furthermore, blood and blood products, and de-boned skeletal muscle (as long as it meets certain requirements) are now commodities that can be traded regardless of the BSE status of a country. In addition, hides and skin from the head make it back on the list as well.
Importing countries like to utilize the OIE standards in drafting their own regulations. This worked to the benefit of exporters of tallow because the OIE deemed protein free tallow as safe and tradable regardless of BSE status and many importing nations wrote this into their regulations. Hence, the OIE standard suggesting meat and bone meal should not be exported from countries with “controlled risk” and “unknown risk” will make negotiations very difficult. However, in looking at overall risk, North America has a strong argument to make.
First of all, the OIE chapter, while being drafted with safety in mind, was also based around the extreme risk that existed within the European Union (EU) and was skewed, in many ways, towards zero risk, hence the ban on the export of meat and bone meal. This ban might make sense for the EU, which has reported approximately 200,000 cases of BSE and was known to export the disease. However, North America has had strong mitigating measures in place for approximately 20 years and the feed rule for eight years. Also, the results of the increased surveillance program have shown extremely minimal risk.
Of most importance for importing nations is having an enforceable ruminant-to-ruminant feed ban in place and that the imported meat and bone meal be destined for non-ruminant rations. It is hoped that in the future the OIE code will consider such language in the BSE chapter. Meat and bone meal destined for poultry or aquaculture rations is safe, and should be allowed to be traded.
The new OIE chapter can be found on the Internet at www.oie.int/downld/SC/2005/bse_2005.pdf.
International Report - August 2005 Render