NRA Issues Talking Points on FDA's Proposed Feed Rule Changes

November 1, 2005 - The Food and Drug Administration (FDA) is proposing to change the 1997 feed rule to ban all cattle brains and spinal cords from all animal feed (see FDA Proposes Additional Feed Regulations). If brains and spinal cords are not removed from dead and downed cattle before rendering, these entire carcasses will also be banned from all animal feed.

Independent renderers now pick up many dead and downer cattle and calves from beef and dairy operations, as well as poultry, swine, and horses. Since the 1997 restrictions on feeding of ruminant proteins, the decrease in value of by-products from dead animals has necessitated pick-up charges to farmers and feedlots.

Under the proposed rule, renderers would have to invest in equipment to remove and keep separate brains and spinal cords. In hot or cold weather, or in remote locations, many dead cattle will not be in a condition good enough to achieve the required brain and spinal cord removal.

The National Renderers Association (NRA) believes that FDA has underestimated the effects of the proposed rule — that additional regulatory restrictions will have important negative environmental and economic impacts. New rules will likely:

• cause many renderers to cease pick-up of dead cattle;

• cause renderers to increase pick-up charges causing farmers to seek alternative disposal;

• increase the incidences of inappropriate disposal;

• cause the economics of many pick-up routes to be so poor that other species will also cease to be picked up.

Renderers also pick up offal from custom slaughter and locker plants as well as small packing plants. New rules will likely:

• require these operations to separate brains and spinal cord from offal going to rendering;

• cause renderers to increase pick-up charges causing plant operators to seek alternative disposal;

• increase the incidences of inappropriate disposal.

The increased inappropriate disposal of dead animals and offal will lead to environmental and animal health problems that are not accounted for in the FDA proposal. In trying to rid the United States of an extremely small risk of spreading bovine spongiform encephalopathy (BSE) in cattle, the proposed FDA regulation could increase the real risk of many other animal diseases.

NRA will be submitting comments to FDA on their proposed rule changes by the December 20, 2005, deadline and encourages others to also respond.

For more information, contact:

Tom Cook at (703) 683-4983, or tcook@nationalrenderers.com.
Dr. David Meeker at (703) 683-2633, or dmeeker@nationalrenderers.com.


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