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U.S. Department of Health and Human Services

Animal & Veterinary

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by Jon F. Scheid
FDA Veterinarian Newsletter September/October 1998 Volume XIII, No V

BSE Teleconference PanelThe June 24 joint CVM-industry interactive satellite teleconference on the new mammalian feed rules brought in questions ranging from what should the label warning look like, to what records must be kept. While the rule is straight forward, the show proved that, as far as the implementation goes, the "devil is in the details."

What makes implementation of the rule on bovine spongiform encephalopathy (BSE) tough is the complexity of the U.S. feed industry. While feed manufacturers are willing to follow the rules, in many cases they are not sure how.

The solution was a satellite teleconference, produced by CVM, in cooperation with State feed control officials and feed industry trade associations. It was designed specifically to explain the BSE rules to members of the feed industry.

The show was broadcast live. It featured a panel that included CVM and State officials who have a hand in enforcing the rules. Because the show was live, anyone watching the show not only heard from the CVM and State experts about the rule, but also had a chance to call during the show via a toll-free number and ask the panelists questions about how the rule was to be implemented.

The panel also included industry representatives, who made sure that the points made during the show were expressed in terms that were clear to feed mill operators and pointed out practical aspects of complying with the rule.

The broadcast was via satellite, which made it available to virtually anyone in a rural feed mill, or in a corporate office in a major city. The coordinates used to "downlink" the broadcast were publicized for a month before the conference. The nearly two-and-a-half-hour show was free to anyone with access to a "steerable" satellite dish.

The show was a success, with more than 225 downlink sites confirmed in more than 34 States. In addition, since the show aired, there have been dozens of requests for copies of the video. The feed industry trade groups are distributing the tapes, for a charge of $15 each, which covers the cost of reproducing the tape and shipping it.

The CVM panelists were Richard Geyer, Deputy Director of the Office of Surveillance and Compliance, and Gloria Dunnavan, Director of the Division of Compliance. CVM officials were joined on the panel by Herschel Pendell, President of the Association of American Feed Control Officials (AAFCO). He is a State feed control official from Oregon.

The supporting cast from CVM included Dr. Dan McChesney, leader of the Feed Safety Team, and Dr. John Honstead, a Veterinary Medical Officer on the Team.

Representing FDA were Richard Barnes, Office of Regulatory Affairs; Ricky Rodriguez of the Dallas District Office, and coordinator of BSE enforcement for the entire U.S.; and Mike Rogers, Director of FDA’s Kansas City Office.

Also on the show were Richard Sellers of the American Feed Industry Association (AFIA) and Randy Gordon of the National Grain and Feed Association (NGFA). Those two feed groups represent virtually all feed manufacturing companies in the U.S.

The show also featured a taped presentation by CVM Director Dr. Stephen Sundlof, who gave an overview of the rule, explained the reason it was written the way it is, and why the rule is needed.

The broadcast also included a tape made by Dr. Will Hueston, Professor and Chair of the Department of Veterinary Medicine, University of Maryland, and Associate Dean for the Maryland Campus of the Virginia-Maryland Regional College of Veterinary Medicine. Dr. Hueston is also a world-renowned expert in the causes and spread of BSE. He explained how BSE can be transmitted to cattle via feed.

Also, because it is so important for CVM to capture the attention and interest of the commercial feed industry, the broadcast included a tape of introductory comments by David Bossman, president of AFIA, and Kendell Keith, president of NGFA, who explained that the groups they represent support the rule and CVM’s efforts to enforce it. If BSE were to appear in the U.S., the consequences would be devastating for consumers, the cattle industry, and feed producers, they said. They both cited the example of the U.K. Officials there, even after they knew about the disease, did not enforce BSE prevention rules in time to stop the spread of the disease. At the peak in the U.K., 1,000 new cases of BSE in cattle were diagnosed weekly. The U.K.’s beef industry has not fully recovered yet, they said.

Its provisions seem simple. Protein derived from mammalian sources is prohibited in feed for ruminants. Further, all feed or ingredients that contain or may contain mammalian proteins must be labeled with the cautionary statement, "Do not feed to cattle or other ruminants," Dr. Sundlof explained. The rule went into effect in August 1997, although then-existing stocks of product and labels could be used until October 1997.

One of the important exceptions to the rule is that pure porcine (hog) or equine (horse) material, although from mammalian sources, can be used in ruminant feed.

Another complicating factor has to do with the definition of protein. For instance, bone and hide are prohibited from cattle, but tallow is not, because it is not protein.

Feed that contains or might contain mammalian protein is considered prohibited material unless the protein qualifies for one of the exceptions. If prohibited material gets mixed with non-prohibited material, all of the mix must be considered prohibited. Thus, one key question asked and answered during the broadcast was how a feed mill operator can be sure a feed mixer is properly cleaned after a prohibited material has been passed through it. No specific amount or even manner for the cleanout was given. Instead, the answer is that a feed mill operator must determine how to clean his mixer out, and be able to show a State or Federal inspector that the cleanout process is sufficient.

Here is a sampling of some of the questions and answers from the show.

Q: The BSE rule was put in place by CVM. Where does AAFCO fit in?

A: In many areas, the States have the inspectors who will actually be doing the feed mill visits. The State officials have better knowledge of the feed manufacturers in their States, and therefore, can be effective in contacting them all and explaining and enforcing the rule.

Q: The feed industry uses a catch-all term on labels of feed products that identify a type of feed ingredient, without limiting the feed to just one specific ingredient. In that way, a feed manufacturer can switch ingredients and not have to change the feed label. One such term is "animal protein product." Can such terms still be used?

A: Yes, but the use of such terms cause some difficulty for the inspector, who must be sure that the feed is either free of prohibited material, or has the cautionary statement on it. The inspector can’t tell from the term whether the feed contains prohibited material. Therefore, he may have to do a trace back to the source of the animal protein to verify that the feed mill is in compliance.

Q: Where should the cautionary statement be placed on the feed?

A: It must be clearly visible on each feed label for bagged feed. In addition, it should be on the invoice or other document that accompanies any bulk feed shipment.

Q: What should the cautionary statement look like on the label?

A: The statement must be conspicuous. Ms. Dunnavan said during the broadcast, "Remember, the whole point is that the user sees the cautionary statement before using the feed." The label can be in larger type and printed in a different color than the rest of the print on the label. Mr. Pendell said the AAFCO requirements say the cautionary statement should follow the list of ingredients on the label.

Q: If a feed manufacturer uses prohibited material to produce a feed that is meant for swine, which are not ruminants, is the manufacturer subject to the requirements to have a cautionary statement on the feed?

A: Yes. The reason for the cautionary statements is to prevent the feed from being used for ruminants. Without the cautionary statement, a cattle producer might use the feed by mistake.

Q: A key part of the rule is record keeping. Because there is no test for prohibited material, feed manufacturers must keep complete records for the inspector. What records are required?

A: The records must contain information on:

  • Date of receipt or purchase.
  • Date of sale or delivery.
  • Name and address of seller.
  • Name and address of consignee.
  • Identification of product.
  • Quantity of product.

The records must be kept for at least one year.

Q: If a mill does not deal with prohibited material, does it have to maintain records?

A: Not according to the rule. However, a feed manufacturer may have to prove to the satisfaction of an inspector that the mill does not deal with prohibited material. Records would help prove that.

A record of all the questions asked during the broadcast, with answers, will soon be posted on CVM’s Home Page. Also, copies of the tape made from the broadcast are available through the participating trade associations, to members and non-members alike.

To order a tape, contact AFIA at (703) 524-0810, 1500 Wilson Blvd.,