Species Test - What is Tolerable or Acceptable?

By Martin Alm, First Vice President, World Renderers Organization

The global rendering industry can be a bit comparable to the new coffee hype. For centuries, people only drank coffee with or without milk and/or sugar. Today, no one wonders when someone orders a medium double-espresso-half-fat-soy latte with hazelnut flavor and sweetener. Tempora mutantur: Times change! As they do in the rendering industry. For decades, the rendering and feed industries knew only a few products:
• tallow, choice white grease, animal fat, poultry fat, yellow/brown grease, and used cooking oil, and
• meat and bone meal (MBM), feather meal, blood meal, and poultry by-product meal.

Today there is a broad range of different products, especially on the protein side. This development was mainly driven by the bovine spongiform encephalopathy (BSE) crisis that began in the United Kingdom in 1986. One of the first reactions toward controlling BSE was a ban on ruminant protein meal in ruminant diets and the removal of specified risk material from the feed chain. Additionally, the European Union (EU) implemented a new regulation that separates animal by-products into three different risk categories. Concerned by this new non-classical infection route via prions, the EU also took the precautionary measure of forbidding species-to-species feeding (i.e., no poultry-based protein to poultry, etc.). There was no scientific basis for this decision except the precautionary principle. Fortunately, countries outside of Europe have not followed this approach as the benefits are obvious. Poultry meal and feather meal, for example, provide the exact amino acid profile needed in poultry diets. It does not have to be artificially composed of from other protein sources.

Over the last seven years, the European feed and export bans for proteins were successively, but not yet fully, repealed. Since July 1, 2017, the EU allows the export of ruminant processed animal proteins (PAPs). Yet in non-European countries the request for pure poultry or pork proteins or ruminant-free proteins has increased. Some countries are even asking for pork-free PAPs. Nevertheless, in Europe two feed bans remain: the World Organization for Animal Health (OIE)-based globally applicable ruminant-to-ruminant ban and the European species-to-species ban.

However, the question arose, what does this ban mean? Some speak about “zero tolerance,” which is a contradiction in itself. Does zero mean zero as in no single particle? If so, what particle? Is there a tolerance above zero? The European Union Reference Laboratory for animal proteins in Gembloux, Belgium, developed and validated for over 10 years the DNA-based polymerase chain reaction method to detect certain species in feed. This past July at the Australian Renderers Association symposium on the Gold Coast of Australia, Dr. Kate Griffins from the National Measurement Institute confirmed that the European test methods give reliable and reproducible results. The published method so far for ruminant detection is a qualitative test and is positive for ruminant DNA content above 0.1 percent. Unfortunately, the average detection level is far lower than 0.1 percent. A quantitative testing is not possible and thus normally non-relevant positives below 0.1 percent have appeared. The European rendering and feed industries alerted the European Commission that the tests are too sensitive. Even with strict cleaning procedures, dedicated transports, and single-species clients, the tests do sometimes confirm a positive result.

Due to the industry’s ongoing objections, the European Commission sent a request in October to the European Food Safety Authority (EFSA) to conduct a risk assessment. They will review and update the input data and, if necessary, the basis, assumptions, and structure of the current EFSA quantitative risk assessment PAP model for the introduction of an “action limit” above the current one. The focus is to estimate the cattle BSE risk posed by the possible contamination of feed with BSE-infected bovine-derived PAP. The envisaged deadline is June 30, 2018. It is assumed the EU will apply the results of this risk assessment for ruminant PAP in ruminant feed toward the thresholds of the species-to-species ban. The infection of poultry via a poultry agent is pure speculation as no parameters are known and cannot be calculated. The same applies for pork. Therefore the transfer of the BSE results to poultry and pork is not based on science.

As mentioned before, there is no scientific proof that there are other non-classical animal diseases that could be transferred by animal proteins. Contrariwise, classical disease pathogens are sufficiently destroyed during the sanitation process in rendering. Therefore, the ruminant-to-ruminant ban, which is defined and mandated by OIE, is the only ban that falls under risk perception. A threshold for this should be thoroughly and regularly assessed based on the current BSE risk prevalence to define which threshold/unavoidable inclusion of ruminant PAP is tolerable. This tolerance is thus a safety issue.

Contrary to the safety issue of ruminant proteins, all other issues are not risk based and should be considered a quality issue. Quality is always a matter that must be agreed upon between seller and buyer. The buyer defines what he is willing to accept and how to measure it. For example, a common quality specification in a contract is the protein content in meal or free fatty acid in fat. The species purity or the product being free of a certain species falls under the same rule. Pet food producers, for example, need a certain standard for labeling/declaration of ingredients. Yet taking into account that animal meals are only a portion of the diet and that labeling allows for certain deviations, an agreed purity of 99.99 percent would be an unnecessary request. A similar guarantee would never be asked of other natural ingredients as no one knows how many insects, reptiles, rodents, rabbits, birds, or even roes are co-harvested and end up in grain and corn. Audits and a communicative customer relationship are therefore a good basis for reliable quality.

This is relevant for the feeding of farmed animals as well. The total MBM feed ban in Europe was not a reaction to the ongoing MBM production but the possible cross-contamination in feed mills and on the farm. In fact, both feed mills and farms cannot be run like a sterile and clean laboratory, which means an exorbitant specification for rendered product can hardly be justified. If labs today can test species DNA per mill, in a few years they may be able to test DNA per million, billion, or trillion. Yet, will this be relevant for a business? On the other hand, livestock traditionally eat their own protein materials (i.e., feather picking by poultry, tail biting by pigs, and licking of newborn offspring by ruminants) so what is natural and what is not?

Therefore, a 99.99 percent pure pork or poultry protein is a clear quality requirement. The extra effort to produce it will have a higher price like low ash products or refined fats. Clients define what is acceptable.

With regard to ruminant or ruminant-free products, the whole feed chain must be considered. Cross-contamination at all stages must be taken into account, not just for one imported product. The EU is currently not in a position to control ruminant feed at all stages to allow ruminant PAPs back into non-ruminant feed. Contrary to the EU, countries worldwide are obviously more effective at checking ruminant feed for ruminant PAPs and at protecting their ruminant population even without a feed ban. Ruminant PAPs can be used in non-ruminant feed without harm. If non-ruminant PAPs are to be used in ruminant feed, competent authorities need to set a threshold and define what is tolerable because it was assessed as safe.

December 2017 RENDER | back