The Food and Drug Administration (FDA) has finally drawn the curtain on the enhanced feed rule and it did not turn out as the industry would have liked. The final rule became effective on April 27, 2009. The caveat, if there is one, is that FDA will not begin enforcement of the rule until October 26, 2009.
The FDA announced in early April its intention to delay the rule for 60 days, providing a short comment period on this intended delay. They received over 400 comments both for and against the delay. The National Renderers Association (NRA) had hoped for the opportunity to comment one more time on the merits and consequences of the rule during the 60-day delay period, but FDA maneuvered a combined delay and finality to the rule in a single action.
Most of the comments in favor of the delay were from affected industries that realized they were not prepared to handle materials for disposal that renderers would no longer collect once the rule was implemented. Livestock producers, state veterinarians, livestock markets, and renderers were vocal in their support to delay the rule. The opposition to delaying the rule included mostly consumers who expressed fear of bovine spongiform encephalopathy. There were some industry interests that also opposed the delay.
Renderers are now making individual decisions as to how they will comply with the new rule. Some will continue to service their areas the best they can, working with the affected industries, while others will simply quit collecting dead cattle that are over 30 months of age. Some renderers are exploring ways to remove the brains and spinal cords of animals over 30 months, but it is too soon to know if this will be economically viable. And then there are those renderers who will simply discontinue collecting all dead animals, and those who will offer to collect the dead stock and dispose of them other than rendering. All these options will come at a higher cost to the producer. However renderers decide, it is pretty apparent that less fallen animals will be collected at farms, dairies, feedlots, and livestock markets with this new rule.
During the six months prior to enforcement, FDA plans to confer with affected industries to determine their disposal needs if rendering is not an option. These affected groups continue to explore their options. Some have considered legal action, but they appear to be waiting to see just how the new rule will impact them.
The NRA worked hard to persuade the government’s policymakers that this rule was unnecessary and would be costly. There were times during the three-plus years it lingered with no action that we thought we were successfully making our points. However, in the end, forces beyond our control prevailed. The NRA will continue to pursue whatever options might be possible, but whatever we do, the association will continue to have the best interests of the rendering industry in mind.
Renderers are committed to complying with this enhanced feed rule just as they have been during the past 12 years with the original feed rule. The industry’s reputation is very good and we intend to keep it that way.
Convention Registration Underway Online
The NRA 76th Annual Convention is in the planning stages, with registration and reservation information available on our Web site by early June at http://nationalrenderers.org. Convention packets will not be mailed out this year so we ask that you go to the Web site and download any information you require about the convention.
The meeting this year will be in San Francisco, CA, October 19-23, 2009. It has been since 1996 that we met in San Francisco and attendees to that venue remember an excellent convention. I hope you are making plans to attend this year as we intend to replicate an outstanding convention once again.
As you receive this issue of Render, NRA will be conducting its ninth annual Washington fly-in. The interest this year is high with more renderers participating than ever before. With the new administration and many new members of Congress, the fly-in continues to be important for the industry. Our congressional visits do not bring instant results, but are an investment in our endeavor to expose more policy influencers to the merits and contributions of the rendering industry. NRA members will visit over 100 congressional offices in a short period of time. After these contacts are made, they are followed up throughout the year by NRA members and staff. We have become a reliable source of information for them.
In early May, the NRA office’s entire phone and data system went down for most of the day. We don’t know why it happened, but it brought about the strong reality of just how dependent we have become on our computers, e-mails, and telephones to do business these days. While we adjusted, may I suggest that you have your own to-do list that is not dependent on today’s marvels of technology for when your system goes down.
From the Association – June 2009 RENDER | back