There are good reasons for the FDA to leave it alone. For starters, the National Renderers Association (NRA) submitted very extensive comments backed up with an industry commissioned study that countered the proposed rule in several areas, such as the FDA grossly underestimating the costs associated with the proposal. To their credit, FDA officials have acknowledged the NRA study’s findings and have undertaken another economic study of their own. An FDA official told an industry gathering recently that while the agency thinks the renderers’ numbers are high, the new numbers being evaluated are closer to the industry’s claims than to those in the proposed rule.
The FDA received over 850 comments on the proposed rule, many of which said the agency’s plan would be more detrimental than the government anticipates. Since the publishing of the proposed rule and the closing of the comment period in late 2005, not much, if anything, has occurred to further justify the implementation of the rule.
In fact, the expanded bovine spongiform encephalopathy (BSE) surveillance program by the U.S. Department of Agriculture (USDA)/Animal and Plant Health Inspection Service that began in June 2004 has provided test results from 785,639 cattle revealing only two positives. Without debating the a-typical nature of those two cases, and lack of connection to animal protein supplements in their feed, the expanded testing shows the incidence of BSE in this country to be very near zero.
U.S. Agriculture Secretary Mike Johanns recently announced that USDA would transition to a BSE surveillance program that corresponds to the extremely low prevalence of the disease in the United States, saying, “It’s time that our surveillance efforts reflect what we now know is a very, very low level of BSE in the United States.” By all indications, it is not likely that there will be any action on the proposed rule before the end of this year.
Of course this is good news to renderers, but the lack of a decision does cause uncertainty in the industry as it affects business planning such as badly needed plant expansions, essential technology upgrades, and financial backing. NRA will continue to monitor the rulemaking process and provide input to the appropriate government agencies to make sure the industry’s interests are heard.
Interesting Times on the Hill
Congress has adjourned so members can go home and seek reelection. It is building up to be an interesting election. The politicians and political pundits are predicting a wide range of outcomes, from a Democratic landslide whereby they take back control of either the House or the Senate, or both, to the Republicans holding on to the majorities of both chambers. There are a lot of races that could go either way. In most cases, the incumbent has the advantage, but there appears to be more incumbents facing stiffer challenges than usual this year.
The new 110th Congress will have several issues on its plate when it convenes in January 2007. Of special interest to the agricultural community will be the making and passing of a new farm bill. Competing thoughts on a new farm bill include those who want a major revision to U.S. agricultural policies. This is most threatening to the major commodities that are subsidized. Secretary Johanns has traveled the country conducting listening sessions on future farm policy and has gotten an earful. It will be interesting what the administration proposes. In the past, Congress has been very proprietary in its development of farm bills and past administrations have often been bystanders.
Then there is the side that simply wants an extension of the current programs. They argue that with the apparent collapse of the Doha Round of multilateral trade negotiations, now is not the time to dismantle U.S. farm programs. To do so will take away any leverage the United States might need in future trade negotiations.
In the past, a new farm bill meant addressing the big commodity support programs. However, recent farm bill rewrites have included numerous titles beyond the supported commodities. It does authorize, or reauthorizes, other programs as well. One good example for renderers is the Market Access Program, which has provided funds for the NRA to promote rendered products in the export market throughout the world.
The next farm bill will most certainly include an energy title. In fact, I recently heard someone refer to the upcoming legislation as the “fuel bill” instead of the farm bill. Expect other issues such as horse slaughter, country of origin labeling, animal identification, packer concentration, animal welfare, and the list could go on and on, to be debated.
It will be interesting.
From the Association - October 2006 Render