Industry Responds to Possible Additional Government Regulations

September 30, 2004 - The Food and Drug Administration (FDA) and the U.S. Department of Agriculture’s (USDA’s) Animal and Plant Health Inspection Service (APHIS) and Food Safety and Inspection Service (FSIS) released a joint advance notice of proposed rulemaking (ANPR) in July 2004 seeking comments and scientific information on several additional measures under consideration related to animal feed to help prevent the spread of bovine spongiform encephalopathy (BSE) in the United States.

Although the rendering industry recognizes the importance of BSE prevention measures to protect both cattle and public health and is committed to a strong BSE risk control program based on scientific facts and practical justification that can be implemented effectively and consistently, the National Renderers Association (NRA) and its members believe sufficient regulations are currently in place and are concerned that control measures proposed in FDA’s ANPR may cause significant unintended consequences adversely impacting animal health, economic dislocation throughout the rendering and livestock industry, and environmental concerns that are unresolved.

With a deadline of mid-August to FDA, and mid-September to APHIS and FSIS, comments from NRA, the Animal Protein Producers Industry, individual rendering companies, along with a study by Informa Economics (formerly Sparks Companies) commissioned by NRA, have been submitted. Thirty questions in the ANPR had to be answered with scientifically based evidence and the affects further regulations would have on the economy of the rendering industry. NRA and APPI submitted a 19-page response to FDA and five page responses to both APHIS and FSIS. Accompanying all responses was a copy of Informa’s 25-page study on the economic and environmental affect of removing specified risk materials (SRMs) and cattle mortalities from existing markets. (Click on any of the above links for access to the responses.)


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