I was once informed that over three million people in the United States see the circus for the first time every year. So what’s that got to do with rendering? It reminds me every day that we continually have to make sure the right people are informed about the rendering industry.
This was brought home this summer when communicating with people in the office of U.S. Department of Agriculture (USDA) Secretary Mike Johanns about the proposed changes to the existing animal feed regulations and a subsequent meeting with him and his staff.
It was in late summer of 2005 when a group of renderers came to Washington, DC, to meet with officials of the Food and Drug Administration (FDA) and Office of Management and Budget (OMB) to discuss the consequences of making changes to the existing feed rule. At the time, we did not think it necessary to take the same message to USDA. The focus was on the people who were specifically responsible in drafting the proposal and USDA was not officially in the loop as it was under the jurisdiction of FDA. Of course, the National Renderers Association (NRA) staff was in regular communications with USDA officials keeping them informed of our concerns.
It is going on almost two years since the comment period closed on the proposed rule. FDA officials have publicly admitted that the comments submitted by the NRA and the accompanying Informa Economics study caused them to reevaluate their numbers and assessment of the impact of the proposed rule.
We do not know the exact status of the proposed rule but it has been confirmed that the draft rule changes have left FDA’s Center for Veterinary Medicine and have informally been conveyed to the secretary’s office at the Department of Health and Human Services (HHS). Once cleared by HHS, it would go to OMB for up to a 90-day review before being cleared for publication in the Federal Register. There is no timeline or deadline within the administration to finalize changes to the feed rule.
However, Johanns has expressed an interest as to the status of the proposal and was briefed by the FDA. The rumor mill has it that he wondered why it had not yet been finalized. Supposedly, his interest was because Japanese trade officials have regularly brought up the lack of a finalized feed rule in their negotiations over beef. I contacted Johanns office and requested a meeting, which was readily accepted and scheduled.
NRA representatives met with Johanns August 30, 2007, to present the rendering industry’s views on the proposed changes to FDA’s existing feed regulations. Representing NRA were David Kaluzny, Mike Reiser, Mike Langenhorst, Mark Myers, Bob Griffin, Ross Hamilton, Steve Kopperud, and myself. In addition to Johanns, also present at the meeting were his chief of staff and deputy chief of staff, a USDA liaison to FDA/HHS, and the USDA general counsel.
It is very important that USDA be aware of the potential consequences the FDA rule, if finalized as proposed, would impose on USDA programs and responsibilities. The importance of the existing animal pick-up/disposal infrastructure with independent renderers servicing farms, feedlots, dairies, small processors, and butchers was re-emphasized to Johanns at the meeting. The NRA Informa Economics study was cited, indicating that if changes to the FDA feed rule were implemented as proposed, there would be a decline of at least 67 percent in on-farm pick-ups of dead livestock, including non-ruminant livestock and poultry. The secretary was told if the pick-up/disposal infrastructure disappears because of the FDA rulemaking, it would be extremely difficult to reinstate the system in the event of a U.S. outbreak of livestock or poultry disease.
Johanns stated while he does not have the final say on the FDA rulemaking, he would have opportunity for input before it’s finalized and published. It was clear the secretary and his staff found the meeting valuable.
USDA has worked tirelessly to reopen lost overseas markets for beef and other products because of bovine spongiform encephalopathy (BSE). While Johanns acknowledged a final FDA rule publication – whatever it might include – would be helpful for the U.S. negotiating position, the rule is not a major hindrance to trade discussions. He said U.S. trading partners continue to use BSE as a trade barrier with an ever-changing list of reasons.
I sincerely hope U.S. government officials are not influenced by the nuances of the Japanese. The status of the proposed rule should have nothing to do with U.S. trade negotiations on beef with Japan. It is absurd to have to respond on this to a country that has had over 30 cases of BSE.
NRA will continue to monitor the status of the FDA rulemaking. We believe these meetings are very helpful in telling the industry’s story.
The NRA is fortunate to have members who are so willing to give of their time and expertise on behalf of the industry. These meetings almost always give us a new audience.
From the Association – October 2007 RENDER | back