[Federal Register: October 6, 2005 (Volume 70, Number 193)]
[Proposed Rules]
[Page 58569-58601]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr06oc05-29]
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Part III
Department of Health and Human Services
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Food and Drug Administration
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21 CFR Part 589
Substances Prohibited From Use in Animal Food or Feed; Proposed Rule
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DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
21 CFR Part 589
[Docket No. 2002N-0273] (formerly Docket No. 02N-0273)
RIN 0910-AF46
Substances Prohibited From Use in Animal Food or Feed
AGENCY: Food and Drug Administration, HHS.
ACTION: Proposed rule.
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SUMMARY: The Food and Drug Administration (FDA) is proposing to amend
the agency's regulations to prohibit the use of certain cattle origin
materials in the food or feed of all animals. These materials include
the following: The brains and spinal cords from cattle 30 months of age
and older, the brains and spinal cords from cattle of any age not
inspected and passed for human consumption, the entire carcass of
cattle not inspected and passed for human consumption if the brains and
spinal cords have not been removed, tallow that is derived from the
materials prohibited by this proposed rule that contains more than 0.15
percent insoluble impurities, and mechanically separated beef that is
derived from the materials prohibited by this proposed rule. These
measures will further strengthen existing safeguards designed to help
prevent the spread of bovine spongiform encephalopathy (BSE) in U.S.
cattle.
DATES: Submit written or electronic comments by December 20, 2005.
Submit written comments on the information collection provisions by
November 7, 2005.
ADDRESSES: You may submit comments, identified by [Docket No. 2002N-
0273 or RIN 0910-AF46], by any of the following methods:
Electronic Submissions
Submit electronic comments in the following ways:
Federal eRulemaking Portal: http://frwebgate.access.gpo.gov/cgi-bin/leaving.cgi?from=leavingFR.html&log=linklog&to=http://www.regulations.gov.
Follow the instructions for submitting comments.
Agency Web site: http://frwebgate.access.gpo.gov/cgi-bin/leaving.cgi?from=leavingFR.html&log=linklog&to=http://www.fda.gov/dockets/ecomments.
Follow the instructions for submitting comments on the agency Web site.
Written Submissions
Submit written submissions in the following ways:
FAX: 301-827-6870.
Mail/Hand delivery/Courier [For paper, disk, or CD-ROM
submissions]: Division of Dockets Management (HFA-305), Food and Drug
Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852.
To ensure more timely processing of comments, FDA is no longer
accepting comments submitted to the agency by e-mail. FDA encourages
you to continue to submit electronic comments by using the Federal
eRulemaking Portal or the agency Web site, as described in the
Electronic Submissions portion of this paragraph.
Instructions: All submissions received must include the agency name
and Docket No(s). or Regulatory Information Number (RIN) for this
rulemaking. All comments received may be posted without change to
http://frwebgate.access.gpo.gov/cgi-bin/leaving.cgi?from=leavingFR.html&log=linklog&to=http://www.fda.gov/ohrms/dockets/default.htm, including any personal
information provided. For detailed instructions on submitting comments
and additional information on the rulemaking process, see the
``Comments'' heading of the SUPPLEMENTARY INFORMATION section of this
document.
Docket: For access to the docket to read background documents or
comments received, go to http://frwebgate.access.gpo.gov/cgi-bin/leaving.cgi?from=leavingFR.html&log=linklog&to=http://www.fda.gov/ohrms/dockets/default.htm
and insert the docket number(s), found in brackets in the heading of
this document, into the ``Search'' box and follow the prompts and/or go
to the Division of Dockets Management, 5630 Fishers Lane, rm. 1061,
Rockville, MD 20852.
FOR FURTHER INFORMATION CONTACT: Burt Pritchett, Center for Veterinary
Medicine (HFV-222), Food and Drug Administration, 7519 Standish Pl.,
Rockville, MD 20855, 240-453-6860, e-mail: burt.pritchett@fda.gov.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Background
A. Bovine Spongiform Encephalopathy
B. Current Animal Feed Safeguards in the United States
C. Risk of BSE in North America
D. Additional Measures Considered to Strengthen Animal Feed
Safeguards
1. Comments on November 6, 2002 Advance Notice of Proposed
Rulemaking (ANPRM)
2. Actions in Response to Washington State Case
3. Comments on July 14, 2004 ANPRM
II. Proposed Measures to Strengthen Animal Feed Safeguards
A. FDA Response to Comments to the 2004 ANPRM
B. Additional Measures to Further Strengthen Feed Protection
C. Basis for Proposing to Apply Additional Measures to All Animal
Food and Feed
D. Cattle Materials Proposed to be Prohibited From Use in All
Animal Food and Feed
E. Disposal of Cattle Materials Prohibited in Animal Feed
III. Description of Proposed Rule and Legal Authority
A. Definitions
B. Proposed Requirements
C. Proposed Recordkeeping and Access Requirements
D. Conforming Changes to 21 CFR 589.2000--Animal Proteins
Prohibited in Ruminant Feed
E. Legal Authority
IV. Analysis of Economic Impacts
A. Summary of Proposed Regulatory Impact Analysis
B. Need for Regulation
C. Benefits
D. Costs
E. Government Costs
F. Sensitivity Analysis
G. Regulatory Flexibility Analysis
V. Paperwork Reduction Act
VI. Environmental Impact
VII. Federalism
VIII. Comments
IX. References
I. Background
A. Bovine Spongiform Encephalopathy
BSE belongs to the family of diseases known as transmissible
spongiform encephalopathies (TSEs). In addition to BSE, TSEs also
include scrapie in sheep and goats, chronic wasting disease (CWD) in
deer and elk, and Creutzfeldt-Jakob disease (CJD) in humans. The agent
that causes BSE and other TSEs has yet to be fully characterized. The
most widely accepted theory in the scientific community is that the
agent is an abnormal form of a normal cellular prion protein. The
abnormal form of the prion protein is less soluble and more resistant
to heat degradation than the normal form. The abnormal prion does not
evoke any demonstrated immune response or inflammatory reaction in host
animals. BSE is diagnosed by postmortem microscopic examination of an
animal's brain tissue and by detection of the abnormal form of the
prion protein in an animal's brain tissue. There is currently no
available test to detect the disease in a live animal.
Since November 1986, there have been more than 180,000 confirmed
cases of BSE in cattle worldwide. Over 95 percent of all BSE cases have
occurred in the United Kingdom, where the epidemic peaked in 1992/1993,
with approximately 1,000 new cases reported
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per week. In addition to the United Kingdom, the disease has been
confirmed in native-born cattle in 22 European countries and in some
nonEuropean countries, including Japan, Israel, Canada, and the United
States.
Epidemiological studies have characterized the outbreak of BSE in
the United Kingdom as a prolonged epidemic arising at various
locations, with all occurrences due to a common source, and have
suggested that feed contaminated by a TSE agent was the cause of the
disease outbreak (Ref. 1). The subsequent spread of BSE was associated
with the feeding of meat-and-bone-meal from rendered BSE-infected
cattle to non-infected cattle (Ref. 1). It appears likely that the BSE
agent was transmitted among cattle at an increasing rate by ruminant-
to-ruminant feeding until the United Kingdom ban on such practices went
into effect in 1988 (Ref. 2).
Agricultural officials in the United Kingdom have taken a series of
actions to eliminate BSE. These actions include making BSE a reportable
disease, banning mammalian meat-and-bone meal in feed for all food-
producing animals, prohibiting the inclusion of animals more than 30
months of age in the animal and human food chains, and destroying all
animals showing signs of BSE. As a result of these actions, most
notably the feed bans, the rate of newly reported cases of BSE in the
United Kingdom has decreased sharply and continues on a downward trend.
In 1996, a newly recognized form of the human disease CJD, referred
to as variant CJD (vCJD), was reported in the United Kingdom.
Scientific and epidemiological studies have linked vCJD to exposure to
the BSE agent, most likely through human consumption of beef products
contaminated with the agent. To date, approximately 150 probable and
confirmed cases of vCJD have been reported in the United Kingdom, where
there had likely been a high level of contamination of beef products.
It is believed that in the United States, where measures to prevent the
introduction and spread of BSE have been in place for some time, there
is far less potential for human exposure to the BSE agent. The Centers
for Disease Control and Prevention (CDC) leads a surveillance system
for vCJD in the United States. To date, CDC, has not detected vCJD in
any resident of the United States that had not lived in or traveled to
the United Kingdom for extended periods of time. In 2002, a probable
case of vCJD was reported in a Florida resident who had lived in the
United Kingdom during the BSE epidemic. Epidemiological data indicate
that the patient likely was exposed to the BSE agent before moving to
the United States.
B. Current Animal Feed Safeguards in the United States
In the Federal Register of June 5, 1997 (62 FR 30936) (the 1997
ruminant feed final rule), FDA published a final rule to provide that
animal protein derived from mammalian tissues is prohibited for use in
ruminant feed. Although BSE had not been identified in the United
States at that time, the 1997 ruminant feed final rule was put in place
to prevent the establishment and amplification of BSE in the United
States through animal feed and thereby minimize risk to humans and
animals. The 1997 ruminant feed final rule created a new Sec. 589.2000
(21 CFR 589.2000), Animal proteins prohibited in ruminant feed, and
established a system of controls to ensure that ruminant feed did not
contain animal protein derived from mammalian tissues. The 1997
ruminant feed final rule set out requirements for persons who
manufacture, process, blend, or distribute certain animal protein
products or ruminant feeds containing such products.
The 1997 ruminant feed final rule (Sec. 589.2000) prohibits the
use of mammalian-derived proteins in ruminant feed, with the exception
of certain proteins believed at that time not to pose a risk of BSE
transmission. These exceptions to the definition of ``protein derived
from mammalian tissues'' included: Blood and blood products; gelatin;
inspected meat products which have been cooked and offered for human
food and further heat processed for feed (such as plate waste and used
cellulosic food casings), referred to herein as ``plate waste'' milk
products (milk and milk protein); and any product whose only mammalian
protein consists entirely of porcine or equine protein. The 1997
ruminant feed final rule does not prohibit ruminant animals from being
fed processed animal proteins derived from nonmammalian species (e.g.,
avian or aquatic animals). The 1997 ruminant feed final rule permits
the manufacture of non-ruminant feed containing prohibited mammalian
protein and ruminant feed on the same premises, provided that separate
equipment is used in the production of ruminant feed or that documented
adequate clean-out procedures are used between production batches.
Following the discovery of a BSE positive cow in Washington State
in December 2003, FDA provided guidance on the use of materials from
BSE positive cattle. In Guidance for Industry, ``Use of Material from
BSE Positive Cattle in Animal Feed,'' published in the Federal Register
in September 2004 (69 FR 58448), FDA stated its view that under section
402(a)(5) of the Federal Food, Drug, and Cosmetic Act (the act) (21
U.S.C. 342(a)(5)), animal feed and feed ingredients containing
materials derived from a BSE-positive animal are considered adulterated
and should be recalled or otherwise removed from the marketplace.
C. Risk of BSE in North America
In April 1998, the United States Department of Agriculture (USDA)
contracted with the Harvard Center for Risk Analysis (HCRA) at Harvard
University and the Center for Computational Epidemiology at Tuskegee
University to conduct a comprehensive investigation of the BSE risk in
the United States. The report, (Ref. 3) widely referred to as the
Harvard Risk Assessment or the Harvard Study, is referred to in this
document as the Harvard-Tuskegee Study. The study was completed in 2001
and released by USDA. Following a peer review of the Harvard-Tuskegee
Study in 2002, the authors released a revised risk assessment in 2003
(Ref. 4).
The Harvard-Tuskegee Study reviewed available scientific
information related to BSE and other TSEs, assessed pathways by which
BSE could potentially occur in the United States, and identified
measures that could be taken to protect human and animal health in the
United States. The assessment concluded that the United States is
highly resistant to any proliferation of BSE, and that measures taken
by the U.S. Government and industry make the United States robust
against the spread of BSE.
The Harvard-Tuskegee Study concluded that the most effective
measures for reducing potential introduction and spread of BSE are as
follows: (1) The ban placed by USDA's Animal and Plant Health
Inspection Service on the importation of live ruminants and ruminant
meat-and-bone meal from the United Kingdom since 1989 and all of Europe
since 1997 and (2) the feed ban instituted in 1997 by FDA to prevent
recycling of potentially infectious cattle tissue. The Harvard-Tuskegee
Study further indicated that, if introduction of BSE had occurred via
importation of live animals from the United Kingdom before 1989,
mitigation measures already in place would have minimized exposure and
begun to eliminate the disease from the cattle
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population even assuming less than complete compliance with the feed
ban.
The Harvard-Tuskegee Study also identified pathways or practices
that, if addressed, would further decrease the already low risk of
spread BSE if it were introduced into the United States. These include
the following: (1) Failing to comply with FDA's ruminant feed
regulations that prohibit the use of certain proteins in feed for
cattle and other ruminants; and (2) rendering of animals that die on
the farm (considered the highest risk cattle), and then incorporating
(through illegal diversion or cross-contamination) the rendered product
in ruminant feed. The Harvard-Tuskegee Study's independent evaluation
of the potential additional risk mitigation measures predicts that a
prohibition against rendering of animals that die on the farm would
reduce potential new cases of BSE in cattle following a hypothetical
introduction of 10 infected animals by 80 percent (from 4.3 to 0.77
cases) as compared to the base case scenario, (i.e., present state of
the U.S. cattle population, along with government regulations and
prevailing agricultural practices, and an assumption of less than
complete compliance with the feed ban) (Ref. 4). Further, the study
evaluated the impact of a specified risk materials (SRMs) ban that
would prohibit high risk materials such as the brain, spinal cord,
vertebral column and animals that die on the farm, from inclusion in
human and animal food. The analysis predicts that this measure would
reduce potential new BSE cases in cattle following a hypothetical
introduction of ten infected animals by 90 percent (from 4.3 to 0.53
cases).
In 2003, following the detection of BSE in a native-born cow in
Canada, the HCRA evaluated the implications of a then-hypothetical
introduction of BSE into the United States (Ref. 5), using the same
simulation model developed for the initial Harvard-Tuskegee Study. The
results of this assessment were consistent with the conclusions of the
earlier study--namely, that the United States presents a very low risk
of establishing or spreading BSE should it be introduced.
On December 23, 2003, USDA announced that a dairy cow in Washington
State had tested positive for BSE. The results were confirmed on
December 25, 2003, by the Veterinary Laboratories Agency in Weybridge,
England. Immediately after the diagnosis was confirmed, USDA, FDA, and
other Federal and State agencies initiated an epidemiological
investigation (Ref. 6), and began working together to trace any
potentially infected cattle, trace potentially contaminated rendered
product, increase BSE surveillance, and take additional measures to
address risks to human and animal health. The epidemiological
investigation and DNA test results confirmed that the infected cow was
born and most likely became infected in Alberta, Canada, before
Canada's 1997 implementation of a ban on feeding mammalian protein to
ruminants.
On January 22 through 24, 2004, the Secretary of Agriculture
convened an international panel of experts on BSE. The panel, referred
to as the International Review Team (IRT), was asked to: (1) Assess the
epidemiological investigation conducted in response to the BSE case in
Washington State, (2) provide expert opinion about when the active
phase of the investigation should be terminated, (3) consider the
response actions of the United States to date, and (4) provide
recommendations about actions that could be taken to provide additional
meaningful human or animal health benefits in light of the North
American experience. The IRT provided its report on February 4, 2004.
In May 2004, USDA contracted with HCRA to update the BSE risk
assessment model to reflect its January 2004 rulemaking to prohibit
SRMs and certain other cattle material in human food. HCRA was also
asked to update the parameters in the model for compliance with FDA's
feed ban. HCRA was also asked to model the impact that the IRT
recommendation would have on the BSE risk to humans and cattle.
In December 2004, Canada announced that a third North American cow
tested positive for BSE. An ongoing epidemiologic investigation found
that this animal, an 8-year-old, nonambulatory dairy cow, originated in
Alberta, Canada and was born before the Canadian feed ban went into
effect in August 1997. Shortly thereafter, in January 2005, another cow
in Alberta was found to be positive for BSE. This case involved a beef
cow born in March 1998, 6 months after the Canadian feed ban went into
effect. Based on preliminary information, Canada believes that the most
likely source of infection in this animal was feed produced before
implementation of Canada's feed ban (Ref. 7).
In June 2005, USDA announced that a 12-year-old beef cow, born and
raised in Texas, was confirmed BSE positive. The BSE-positive cow most
likely became infected before FDA's implementation of the 1997 ruminant
feed final rule. It was determined that no part of the animal entered
the human food or animal feed chains.
D. Additional Measures Considered to Strengthen Animal Feed Safeguards
1. Comments on November 6, 2002, Advance Notice of Proposed Rulemaking
(ANPRM)
In the Federal Register of October 5, 2001 (66 FR 50929), FDA
announced its plan for an October 30, 2001 public hearing in Kansas
City, MO, to solicit comments from the public on the 1997 ruminant feed
regulation. Recognizing that new information had emerged since
publication of the feed rule in 1997, FDA requested comments on whether
changes to the rule or other additional measures were necessary (Ref.
8). Information obtained from the public hearing and from the Harvard-
Tuskegee Study was used in the publication of an ANPRM (2002 ANPRM) in
the Federal Register of November 6, 2002 (67 FR 67572). This ANPRM
sought comment from affected industries and the public on possible ways
to strengthen the 1997 ruminant feed regulation. The ANPRM specifically
asked for comments on a number of questions related to the following
five aspects of the BSE feed regulation: (1) Excluding brain and spinal
cord from rendered animal products, (2) prohibiting the use of poultry
litter in cattle feed, (3) assessing the improper use of pet food as a
feed for ruminants, (4) preventing cross-contamination, and (5)
eliminating the plate waste exemption.
The predominant view of those who submitted comments in response to
the ANPRM was that the BSE risk in the United States was low enough
that no new feed controls were needed. Most said that the current feed
ban provided more than adequate protection against BSE, that there was
no scientific justification for additional regulations, that compliance
with the 1997 ruminant feed final rule was extremely high, and that
over 19,900 USDA surveillance samples in 2002 alone failed to detect
BSE in U.S. cattle. They also cited the Harvard-Tuskegee Study
conclusion that existing control measures made the risk to U.S. cattle
and to U.S. consumers from BSE very low.
In the 2002 ANPRM, FDA said that the Harvard-Tuskegee Study
identified the removal of high-risk bovine tissues, such as brain,
spinal cord, intestine, and eyes, from human food and from rendered
material for all animal feed as a way to reduce the potential exposure
of cattle and humans to the BSE agent. The 2002 ANPRM then asked for
comments on the following three questions related to SRMs: (1) Should
high risk materials be excluded from rendered products?; (2) how
feasible would it be for the rendering industry
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to implement such an exclusion?; and (3) what will be the adverse and
positive economic, environmental, and health impacts from an exclusion?
Comments in support of an SRM ban included one comment from USDA
citing conclusions from the Harvard-Tuskegee Study that this action
would significantly reduce the amount of infectivity in the animal feed
chain, and would reduce risks resulting from ``leaks'' in the feed ban.
Other comments stressed the infectivity of these tissues, and the
recommendation by the World Health Organization (WHO) that countries
exclude these tissues from the animal and human food chain (Ref. 9).
Comments opposing an SRM ban said that the measure would be
redundant because the 1997 ruminant feed final rule already prohibits
this high-risk material in ruminant feed. Therefore, the ban would only
be beneficial if BSE were present in the United States and there were
significant non-compliance with the feed ban. The comments also cited
the conclusions of the Harvard-Tuskegee Study that the risks of BSE in
the United States are low. One comment said that restrictions on SRMs
in animal feed should be decoupled from restrictions for human food
because of the substantial reduction in infectivity obtained during
rendering. Another comment said that an SRM ban would give only the
perception of a risk reduction, not a real reduction, and that it would
send the message to our trading partners that our BSE risks are such
that more controls are needed. Australia asked that, if an SRM ban is
implemented, the ban not apply to Australia because of its widely
recognized status as a low-risk BSE country.
Numerous comments addressed the feasibility and the adverse
economic impacts of an SRM ban. One comment pointed out that it is not
feasible to remove central nervous system (CNS) tissue from decomposing
carcasses. Comments from a trade association said that an SRM ban would
require costly restructuring of facilities that would force many small
rendering plants out of business, depriving some parts of the country
access to rendering as a means of animal disposal. A June 2002 Sparks
Report estimated disposal costs of an SRM ban to be $54 million, based
on the assumption that the ban would apply to all cattle because of the
difficulty of determining the age of cattle at slaughter (Ref. 10).
According to an earlier 1996 Sparks Report, the cost of disposal of 1.7
billion pounds of CNS tissue and dead stock would exceed $400 million.
Another estimate for disposal was $50 million for the beef industry
alone. One comment said that feed costs account for 70 percent of
poultry production cost, and that renderers would pass on the costs of
excluding brains and spinal cords to the poultry industry.
Several comments mentioned the environmental impact of an SRM ban.
One comment stated that a total ban on SRMs in rendered animal products
would create a waste stream with no economic value. Another comment
said that a ban on SRMs would encourage improper disposal of dead stock
because there are no federal regulations on disposal of dead animals.
2. Actions in Response to Washington State Case
In response to the BSE case identified in Washington State, USDA
published an interim final rule in the Federal Register of January 12,
2004 (69 FR 1861), excluding high-risk tissues from human food. The
interim final rule prohibited the use of SRMs and certain other cattle
material in USDA-regulated human food. USDA defined SRMs as brain,
skull, eyes, trigeminal ganglia, spinal cord, vertebral column
(excluding the vertebra of the tail, the transverse processes of the
thoracic and lumbar vertebrae, and the wings of the sacrum), and dorsal
root ganglia (DRG) of cattle 30 months of age and older, and the
tonsils and distal ileum of the small intestine of cattle of all ages.
To ensure effective removal of the distal ileum, USDA requires that the
entire small intestine be removed and disposed of as inedible product.
In its January 12, 2004, interim final rule, USDA took the additional
step of making cattle that are unable to rise from a recumbent
position, referred to in this document as nonambulatory disabled
cattle, ineligible to be slaughtered for human consumption.
On January 26, 2004, FDA announced its intention to implement
additional measures to strengthen existing BSE safeguards for FDA-
regulated products. These measures included the issuance of an interim
final rule to implement additional measures related to animal feed. The
interim final rule would have implemented four specific measures
related to animal feeds. These measures included the elimination of the
exemptions for blood and blood products and ``plate waste'' from the
1997 ruminant feed rule, a prohibition on the use of poultry litter in
ruminant feed, and a requirement for dedicated equipment and facilities
to prevent cross-contamination.
However, on February 4, 2004, IRT released its report on measures
related to BSE in the United States. The report recommendations
included a somewhat different set of measures for reducing the risks
associated with animal feed than the measures FDA had announced that it
intended to implement through an interim final rule. Although FDA
believed its previously announced measures would serve to reduce the
already small risk of BSE spread through animal feed, the broader
measures recommended by the IRT, if implemented, could make some of the
previously announced measures unnecessary. FDA believed that additional
information was needed to determine the best course of action in light
of the IRT recommendations and decided to publish an ANPRM, which
requested comments on the recommendations of the IRT, as well as on
other measures under consideration to protect the animal feed supply.
Consistent with measures implemented by USDA to exclude high-risk
cattle tissues from human food (69 FR 1861), FDA published an interim
final rule on July 14, 2004 (69 FR 42255), prohibiting a similar list
of risk materials from FDA-regulated human food, including dietary
supplements, and cosmetics.
3. Comments on July 14, 2004, ANPRM
In the Federal Register of July 14, 2004 (69 FR 42287), FDA
published an ANPRM (2004 ANPRM) jointly with USDA in which FDA
announced its tentative conclusion that it should propose banning SRMs
in all animal feed. In this ANPRM, FDA asked for comment on this
measure and also on the IRT's recommendations to require dedicated
equipment or facilities for feed manufacture and transport, and its
recommendation to prohibit the use of all mammalian and poultry protein
in ruminant feed. Finally, FDA also asked for comment on the set of
measures that the agency had announced in January 2004. Comments
submitted in response to the 2004 ANPRM that relate to SRMs are
summarized in sections I.D.3a through I.D.3f by general topic area.
a. Need for SRM ban. As with the comments received in response to
the 2002 ANPRM, many comments questioned the need for an SRM ban at the
time of the 2004 ANPRM. Several comments argued that the comparison
made by the IRT between the BSE situations in Europe and the United
States is inappropriate. One reason given for the invalid comparison
was that there were an estimated 3 to 4 million undiagnosed BSE cases
in the United Kingdom, compared to two diagnosed cases in North America
in cattle born before feed restrictions were implemented. Another
comment said
[[Page 58574]]
that the United States did, in fact, learn from the European experience
and implemented controls early so that potential animal exposure to the
BSE agent in the United States remains exceedingly small compared to
the massive exposure in the United Kingdom. One comment submitted by
the agriculture department of a state with a large agriculture industry
said that its findings from 600 inspections do not support the premise
of the IRT's recommendation that an SRM ban is needed to address
problems of cross-contamination and on-farm misfeeding. The state
indicated that, in these inspections, it did not observe any prohibited
materials or feed containing prohibited materials on farms where
ruminant feeds were being mixed.
Other comments said that the reduction in risk obtained through an
SRM ban would be minimal, mostly citing the effectiveness of the
current firewalls in reducing BSE infectivity in the cattle population.
One comment said that the Harvard-Tuskegee Study conclusion that an SRM
ban will reduce potential cattle exposure to BSE infectivity by 88
percent sounds more impressive than it really is. Reducing a very small
risk by 88 percent does not necessarily provide significant risk
reduction.
Finally, many comments questioned FDA's decision to ban SRMs from
animal feed before the results of USDA's enhanced BSE surveillance
program are known. USDA's one-time effort to test as many high-risk
cattle as possible was started on June 1, 2004, and was expected to be
completed by the end of 2005. One comment pointed out that the IRT's
recommendations for defining SRMs are predicated on the outcome of this
aggressive surveillance program.
In support of FDA's tentative conclusion that it should propose to
ban SRMs from all animal feed, many comments cited the conclusion of
the Harvard-Tuskegee Study that an SRM ban will provide additional risk
reduction, and also cited the recommendation of the IRT that SRMs
should be excluded from all animal feed, including pet food. One
comment said that an SRM ban would restore confidence in U.S. beef
exports.
b. Definition of SRMs. SRMs are typically defined as the tissues in
which BSE infectivity has been demonstrated in experimentally or
naturally infected animals. SRMs are further defined by the OIE
Terrestrial Animal Health Code based on the age of the animal and the
BSE risk status of a country. In the 2004 ANPRM, FDA asked how SRMs
should be defined for animal feed, specifically, if the SRM list should
be the same list as for human food. FDA also asked what information is
available to support having two different lists.
Comments from one organization included data from the Harvard-
Tuskegee Report on the relative infectivity of specific tissues. These
data were based on pathogenesis studies carried out in the United
Kingdom and showed the fraction of total infectivity of each tissue to
be: Brain 64.1 percent; spinal cord 25.6 percent; dorsal root ganglia
3.8 percent; trigeminal ganglia 2.6 percent; distal ileum 3.3 percent;
tonsil < 0.1 percent; and eyes < 0.1 percent. The comment used the data
to make the point that 90 percent of infectivity could be removed by
excluding only the brain and spinal cord. A different comment citing
the same data pointed out that the infectivity distribution represents
more than a worst case scenario because, in the pathogenesis study, the
BSE dose administered orally to calves was substantially greater than
would reasonably be expected under field conditions. This second
comment went on to point out that FDA's interim final rule on food and
cosmetics said that in cattle infected under field conditions, BSE
infectivity had been demonstrated only in the brain, spinal cord, and
retina of the eye at the end stages of the disease.
Many comments recommended that the human food list of SRMs be used
to define which SRMs should be excluded from animal feed. Several
comments recommended expanding the list beyond the human food list by
applying it to tissues from cattle 12 months of age or older, or to
tissues from all cattle. Others advocated eliminating bovine or animal
protein from ruminant feed altogether. Reasons given by the comments
for these recommendations were the large risk reduction that could be
achieved and the desirability of being consistent with the requirements
for human food.
Those who submitted comments in support of a more limited SRM list
mostly did so to minimize the volume of material that would require
nonfeed disposal. The comments stated that reducing this volume of
material that would require nonfeed disposal would lessen the adverse
impact of an SRM ban on the livestock, meat, and animal feed
industries. One company used the Harvard model to simulate three
different SRM scenarios and then submitted data showing that limiting
the SRM list to brain and spinal cord (while also prohibiting use of
dead stock and downers over 30 months of age), eliminating vacuum
rendering, and keeping the existing feed ban in place, achieved a risk
reduction equivalent to that obtained by banning the full human list of
SRMs.
The following are other suggestions provided in comments submitted
in response to the 2004 ANPRM for reducing the volume of SRM material
needing alternative disposal: (1) Allow the use of SRMs from animals
that test negative for BSE, (2) designate only the head as an SRM which
reduces by 64 percent the potential BSE infectivity in feed, (3) allow
the use of intestines from veal calves whose carefully controlled diets
consist of low-risk formulas, and (4) allow mechanically separated beef
from pet food plants to be used if SRMs are removed before meat is
mechanically separated from bones.
c. Cattle not inspected and passed for human consumption. The term
``cattle not inspected and passed for human consumption'' is used in
this document to mean cattle that were not inspected and passed for
human consumption by the appropriate regulatory authority. For the
purposes of this document, this term also includes nonambulatory
disabled cattle, i.e., cattle that could not rise from a recumbent
position or that could not walk, including, but not limited to, those
with broken appendages, severed tendons or ligaments, nerve paralysis,
fractured vertebral column, or metabolic conditions. This proposed
definition is consistent with the use of the terms ``inspected and
passed and nonambulatory disabled cattle'' as defined in USDA's interim
final rule on human food (69 FR 1862) and FDA's interim final rule on
human food and cosmetics (69 FR 42255). For the purposes of this
proposed rule, nonambulatory disabled cattle are included in the
definition of cattle not inspected and passed, since nonambulatory
disabled cattle cannot be passed for human consumption.
A number of questions were included in the 2004 ANPRM regarding the
use of materials from cattle not inspected and passed for human
consumption as previously defined. Comments received discussed both the
advantages and disadvantages of excluding these animals from being
rendered for use in animal feed.
Advantages mentioned included the additional risk reduction that
would be provided by the measure. A number of comments cited the
Harvard-Tuskegee Study, which showed that removing dead stock from the
feed chain would reduce potential exposure of cattle to the BSE agent
by 88 percent. However, other comments noted that such a ban would
result in dead stock being disposed of on the farm, impacting USDA's
surveillance program and
[[Page 58575]]
increasing environmental problems due to improper disposal of animal
carcasses. Concerns were also expressed about lack of infrastructure
for non-feed disposal of dead stock, and the serious economic impact of
diverting these animals to alternative disposal.
In response to the question in the 2004 ANPRM about effective
removal of SRMs from dead stock and nonambulatory disabled cattle,
several comments stated that such removal would not be economically or
technically feasible. Other comments stated that SRM material could be
effectively removed because there is no substantial difference between
the processing of dead and nonambulatory animals at rendering
facilities and the processing of healthy cattle at slaughter plants.
One other comment mentioned instances where some USDA-inspected
deboning facilities already remove SRMs from dead cattle at the request
of pet food manufacturers. This comment also said that, based on their
experience, SRMs can be removed from dead cattle in all but the hottest
months of the year when the rate of decomposition increases. Another
comment said that removing SRMs from dead stock may increase exposure
of plant employees to pathogens and zoonotic diseases.
One comment noted that the European experience has shown that
cattle at highest risk for BSE are dead cattle, downer cattle, and
ante-mortem condemned cattle over 30 months of age. This comment said
that, while it is possible to remove the meat from these carcasses for
use in pet food, they are not aware of any way of verifying the removal
of SRMs from dead and nonambulatory cattle (short of active government
oversight) that would allow this material to be rendered for use in
feeds for non-ruminant animals. Another comment suggested that as an
option for reducing the amount of material for disposal, dead stock
under 30 months of age be allowed to be rendered for feed use. This
comment also said that USDA could test dead stock over 30 months of
age, allowing material from negative animals to be used in feed.
d. Small intestine. The 2004 ANPRM also requested information to
evaluate the IRT recommendation that the entire intestine from cattle
of all ages should be excluded from the human and animal food chains.
With publication of its interim final rule on January 12, 2004, USDA
required that the entire small intestine be disposed of as inedible.
Likewise, FDA prohibited the use of the entire small intestine in FDA-
regulated human food and cosmetics, even though the agency only
considers the distal ileum portion of the small intestine to be a
specified risk material (69 FR 42259).
However, based on comments received in response to the FDA interim
final rule on human food and cosmetics, FDA concluded that processors
have the technology to effectively remove the distal ileum portion from
the rest of the small intestine. Thus, FDA amended the human food and
cosmetics interim final rule to state that the small intestine is not
considered prohibited cattle material if the distal ileum is removed by
a procedure that removes at least 80 inches of the uncoiled and trimmed
small intestine as measured from the caeco-colic junction and
progressing proximally towards the jejunum or by a procedure that the
establishment can demonstrate is equally effective in ensuring complete
removal of the distal ileum (70 FR 53063, September 7, 2005). This
amendment is consistent with USDA requirements (70 FR 53043, September
7, 2005).
Many comments in response to the 2004 ANPRM stated that inclusion
of the entire small intestine from cattle less than 30 months of age in
the list of prohibited material would double the volume of SRMs from
slaughter requiring alternative disposal while only marginally
decreasing infectivity. Several comments stated that only the distal
ileum should be included in the list of SRMs and noted that it is
easily identified for separation at slaughter.
One comment questioned the need to designate the intestinal tract
as SRM, pointing out that the distal ileum accounts for only 5 percent
of infectivity, which is reduced by two logs during rendering. Another
comment said that it was unnecessary to designate any portion of the
intestinal tract of cattle less than 30 months of age as SRM because
these animals were born 4 1/2 years after the feed ban was implemented,
and are therefore low risk animals. Several comments said that, if
packers can demonstrate a satisfactory technique, they should be
allowed to remove only the distal ileum rather than the entire small
intestine.
One comment expressing concern about the BSE risk associated with
bovine intestines said that research in the United Kingdom found
positive immunostaining for the resistant form of the prion protein
along the length of the intestine, which provides evidence that the
entire intestine should be considered SRM.
e. Infrastructure for alternative disposal. We received a number of
comments addressing the issue of disposal infrastructure. One comment
noted that the IRT recognized that an infrastructure was not in place
to dispose of SRM material and that the IRT had suggested that a staged
implementation may be necessary to allow this infrastructure to
develop. One comment said that before an SRM ban is implemented a
comprehensive plan for disposal of this material needs to be developed.
Another comment noted that in Texas, SRMs are considered special waste,
and that no landfill in the state is capable of accommodating a large
volume of this material. Additional comments indicated that this
concern was also true for other states, including Nebraska and Utah.
Two organizations submitted slaughter and cattle mortality data to
emphasize the amount of waste that would be generated by regulations
that would exclude this material from being rendered for use in animal
feed. One of these organizations said that it is deeply concerned that
FDA fails to recognize that a suitable disposal infrastructure does not
exist to deal with the very large quantities of SRMs that would be
generated on a daily basis. Its estimate for the volume of waste
generated from slaughter and cattle mortalities was 2 billion pounds
per year. The other organization submitted similar comments saying that
the U.S. system is currently unprepared to manage the waste disposal
challenges certain to arise if significant quantities of livestock
mortalities and slaughter byproducts require disposal by means other
than rendering. The comments further stated that the disposal and
environmental challenges resulting from the ban would be faced
immediately, but the solutions to these challenges would arise only
after significant time and financial investment across the livestock
sector. The comments also said that there is an absence of direct
regulatory control over alternative methods of disposing of the
enormous quantities of this unpleasant material.
Another comment suggested that renderers should be allowed to
dedicate lines to SRM material and SRM-free material within a single
facility. Equipment for receiving, grinding, cooking, processing, and
conveying could be dedicated lines, while the facility itself,
including the utilities, odor control, and wastewater treatment systems
be shared. Further, another comment suggested FDA work with the
rendering industry to develop cleanout procedures that would allow a
plant to process both SRMs and SRM-free material. These procedures
would be helpful to allow for seasonal deer rendering, for cleaning up
after accidental cross-contamination, and for
[[Page 58576]]
converting a facility back to SRM-free rendering.
One comment addressed the use of rendered SRM material as an
alternative fuel source for cement kilns, indicating that ruminant meat
and bone meal and fat are being used as a fuel source in Europe and
Japan. According to the comment, these materials burn efficiently, and
the heat from the kiln leaves virtually no organic residue.
f. Verification of SRM removal and SRM marking. One comment stated
that, in the absence of a practical test for verification of SRM
removal, the documentation required by HACCP plans should be sufficient
to show that SRMs at slaughter are excluded from animal feed channels.
Thus, inspections of records could be used to verify SRM removal. Also,
the comment stated that FDA can verify SRM removal by shifting
resources from inspections of thousands of feed mills and farms to the
much smaller number of slaughter plants and renderers.
One comment stated that rendering plants are capable of keeping raw
materials from various sources separated and capable of using
production, inventory, and shipping records to document the movement of
both SRM and SRM-free materials. Such management practices can be
verified by inspection, much like those conducted at USDA-inspected
cattle slaughter facilities. The comment went on to say that, if a
rendering plant is dedicated to rendering only SRMs, such a plant will
have to be inspected to determine how it disposes of SRMs.
Two comments suggested that raw or SRM-derived rendered materials
can be effectively marked using automatic dosage pumps to dispense
markers like glyceroltriheptanoate (GTH). GTH is a C7 synthetic fatty
acid not found in nature. A gas chromatography (GC) method for its
detection is available. Charcoal was mentioned as another potential
marker for use in rendered products.
II. Proposed Measures to Strengthen Animal Feed Safeguards
A. FDA Response to Comments to the 2004 ANPRM
FDA agrees with the numerous comments saying that it is important
to keep the BSE risk in the United States in proper perspective. FDA
acknowledges that the risk is likely low, and acknowledges that it is
inappropriate to compare the BSE situation in the United States to the
situation in Europe. However, FDA disagrees with comments concluding
that for these reasons no additional measures are needed. Even though
strong control measures have been put in place and compliance with the
current BSE feed regulation is high by renderers, protein blenders and
feed mills, the Agency is concerned, as discussed further below, about
such issues as the presence of high risk material in the non-ruminant
feed supply and cross-contamination of ruminant feed during the
rendering or feed manufacturing process. For example, without fully
dedicated equipment, it may not be possible to verify that there is
zero carryover of feed or feed ingredients in equipment, even where a
firm's cleanout procedures have been judged to be adequate. In
addition, resource constraints limit FDA's ability to assure full
compliance by all segments of the industry that are subject to the
current BSE feed regulation. For example, resources are not available
to the FDA and its state counterparts to fully verify compliance on
over 1 million farms where cattle are being fed.
FDA does not agree with comments that the agency should wait until
USDA completes its enhanced BSE surveillance program before deciding if
additional feed controls are needed. As stated in the July 2004 ANPRM,
FDA had tentatively decided based on clear evidence that the BSE agent
had been introduced into the North American animal feed supply, and
based on the recommendation of the IRT, that SRMs should be removed
from all animal feed. Results from the enhanced surveillance that was
being conducted concurrent with our rulemaking process indicated that
BSE had been introduced into the United States, but was present at a
very low level. These results reinforced FDA's decision that the
measures being proposed are appropriate.
With respect to the definition of SRMs, FDA agrees that prohibiting
the full list of SRMs would achieve greater risk reduction than
prohibiting a partial list, but also agrees with comments saying that
the infrastructure does not currently exist to handle the volume of
material that would require non-feed disposal if the full list of SRMs
were diverted from animal feed use. Therefore, FDA agrees that focusing
on brain and spinal cord is an effective approach for achieving
additional animal and public health protection while minimizing the
economic, environmental, and public health concerns associated with
disposal of the full list of SRMs. FDA, however, seeks comments on
whether a full SRM ban is warranted.
Comments were mixed on the feasibility of removing SRMs from dead
stock. FDA therefore concluded that some firms would elect to remove
SRMs and render the remainder of the carcass, and that this could
lessen difficulties associated with alternative disposal. FDA does not
agree that allowing test-negative animals to be rendered for animal
feed use is appropriate. Unlike Europe, rapid screening tests in the
United States have been used only for surveillance purposes. These
tests have not been used as food or feed safety tests because currently
available tests can detect BSE only in the late stages of disease.
Finally, although FDA agrees that vacuum rendering is less effective at
inactivating TSEs than atmospheric rendering, the Agency disagrees that
vacuum rendering should be prohibited. Modeling results submitted with
the comment showed that such a prohibition would result in an
additional one percent reduction in risk. In light of other measures
being proposed and the fact that few plants use vacuum rendering, FDA
does not believe that prohibiting this rendering process would
appreciably improve animal or public health protection.
B. Additional Measures to Further Strengthen Feed Protection
The United States and Canadian feed regulations implemented in 1997
were necessary because of uncertainty about whether BSE infectivity had
already been introduced into North America before new import
restrictions on live cattle and meat and bone meal from Europe were put
in place. It is now clear from the five North American BSE cases that
the BSE agent was introduced into the North American animal feed supply
at some point in time. While FDA continues to believe that compliance
with the feed regulation has provided strong protection against the
spread of BSE, the agency believes that the recent cases are an
indication that additional animal feed protections are needed to remove
residual infectivity that may be present in the animal feed supply. FDA
also believes that of all the options considered since publication of
the 2002 ANPRM, excluding the highest risk tissues from all animal feed
is the best approach to address the risks of BSE in the United States.
In the 2004 ANPRM, FDA announced its tentative conclusion that it
should propose a prohibition on the use of SRMs in all animal feed.
The decision to propose banning SRMs from all animal feed led to
the following questions: (1) Which material to exclude, (2) what
alternative disposal methods could be used, (3) what the economic and
environmental impacts of diverting material to alternative disposal
would be, and (4) how an SRM ban could be enforced. As the IRT
reported,
[[Page 58577]]
exclusion of large volumes of raw material is a massive burden for all
countries affected by BSE. FDA received valuable information pertaining
to these issues in comments submitted in response to the 2004 ANPRM.
In reaching a decision about what specific additional measures
should be proposed at this time, FDA considered the magnitude of the
BSE risk in the United States. While the recent North American cases
clearly show the BSE agent was introduced, the USDA enhanced BSE
surveillance program indicates that the prevalence of the disease in
the United States is very low. As of July 2005, USDA has tested over
418,000 high-risk cattle under its enhanced BSE surveillance program
(Ref. 11), and has found one positive animal in addition to the cow
identified in Washington State in December 2003. Therefore, FDA
believes that the additional measures being proposed are appropriate at
this time. The agency proposes to prohibit from use in all animal feed
the brains and spinal cords from cattle 30 months of age and older, the
brains and spinal cords from all cattle not inspected and passed for
human consumption, and the entire carcass of cattle not inspected and
passed for human consumption from which brains and spinal cords were
not removed. The agency also proposes to prohibit from use in all
animal feed mechanically separated beef and tallow that are derived
from materials prohibited by the rule. However, the rule proposes to
exempt tallow from this requirement if it contains no more than 0.15
percent insoluble impurities.
C. Basis for Proposing to Apply Additional Measures to All Animal Food
and Feed
The current U.S. ruminant feed regulation prohibits the use of
certain mammalian-origin proteins in ruminant feed, but allows the use
of these materials in feed for non-ruminant species. FDA believes that
the presence of high-risk materials in the non-ruminant feed supply
presents a potential risk of BSE to cattle in the United States.
European experience showed that, in countries with high levels of
circulating BSE infectivity, controls on only ruminant feed were not
sufficient to prevent further transmission of BSE. Until SRMs were
removed from all animal feed, a significant number of new cases
continued to be found in cattle born in the United Kingdom after
implementation of a ruminant-to-ruminant feed ban (Ref. 12). These new
cases were attributed to either cross-contamination during feed
manufacture and transport, or to intentional or unintentional
misfeeding on the farm.
The 1997 ruminant feed regulation requires feed manufacturers and
distributors that handle both ruminant feed and feed ingredients and
materials prohibited in ruminant feed to control cross-contamination by
either: (1) Maintaining separate equipment or facilities or (2) using
adequate clean-out procedures or other means adequate to prevent carry-
over of prohibited material into feed for ruminant animals. FDA has
been concerned about the adequacy of such clean-out procedures and
sought public comment on this issue in the 2002 ANPRM. Although many
firms using the clean-out option have written procedures in place,
evaluating their adequacy is difficult because of wide variation in
equipment and practices used by the feed industry, and because there is
currently no definitive test method to detect prohibited proteins.
Further increasing FDA's concerns about cross-contamination are
preliminary data from an unpublished study showing that the minimum
infectious dose for BSE may be lower than previously thought. Interim
results at approximately 5 years post exposure of an oral challenge
experiment have demonstrated transmission of BSE to 1 out of 15 animals
that received 0.01 gram of brain tissue from a BSE-infected animal
(Ref. 13). The lowest dose previously tested was 1.0 gram of brain
tissue which showed transmission of BSE in 7 out of 10 animals in the
trial group. This finding of a lower minimum infectious dose for BSE
would suggest that the risk from cross-contamination is greater than
previously thought. We seek comment on this interpretation of theses
interim results.
Instances of cattle being exposed to prohibited material through
noncompliance with the 1997 feed bans have been identified in both
Canada and the United States. The investigation by the Canadian Food
Inspection Agency of the BSE case identified in May 2003 found several
instances where cattle might have had access to non-ruminant feed
containing prohibited material. In the United States, FDA inspections
have identified situations where cattle could have been exposed to
material prohibited in ruminant feed as a result of ruminant feed being
contaminated with non-ruminant feed, or non-ruminant feed not being
properly labeled.
In fiscal year 2004 and the first half of fiscal year 2005, federal
and state inspections identified 41 instances (0.4 percent of
inspections) of cross-contamination or commingling problems in firms
that handle animal feeds containing prohibited mammalian protein (Ref.
14). During this same period, inspections identified 165 instances (1.7
percent of inspections) in which non-ruminant feeds containing
prohibited material were not properly labeled with the caution
statement ``Do Not Feed to Cattle or Other Ruminants''. Firms receiving
mislabeled feed would not be aware of the need to take steps to prevent
cross-contamination of ruminant feed with such products. Furthermore,
inspections during this period identified 604 instances (6.3 percent of
inspections) in which firms handling animal feeds containing prohibited
mammalian protein did not meet the recordkeeping requirements. These
instances involved a variety of recordkeeping deficiencies, including
not maintaining sales records for feeds received or distributed, not
establishing written protocols for avoiding commingling, and not fully
documenting clean-out measures utilized. Such deficiencies are
typically corrected by the involved firms without further action by the
agency. However, the occurrence of these deficiencies nonetheless
supports the need for additional measures to address concerns about the
presence of high-risk materials in the non-ruminant feed supply.
Without sales records, it is difficult to verify the source of feed or
feed ingredients or to track distributed feeds when conducting recalls
in response to known instances of product contamination. Without
appropriate documentation of procedures related to commingling or
cross-contamination, it is difficult to verify that workers are
informed of such procedures or that the procedures are adequate.
FDA has issued warning and untitled letters to firms addressing
noncompliance with the current ruminant feed ban regulation and a feed
manufacturer has been permanently enjoined in connection with
noncompliance with the current feed ban regulation.
FDA is also concerned about intentional and unintentional
misfeeding of non-ruminant feed to ruminants on the farm. Financial
incentives for intentional misfeeding could occur any time inexpensive
sources of prohibited protein are locally available to the feeder. The
use of salvaged pet food that contains ruminant meat and bone meal is
an example. There may be other incentives to intentionally feed non-
ruminant feed to cattle. For example, the Florida Department of
Agriculture and Consumer Services issued a statement cautioning against
the misuse of pet
[[Page 58578]]
food as feed for show cattle as a way to increase the shine in the
cattle coat (Ref. 15). Unintentional feeding could occur on the farm
from feeding ruminants and non-ruminant in close proximity to each
other. If intentional or unintentional uses occur, this proposed rule
would protect cattle by removing the highest risk material from the
non-ruminant feed being used in cattle feed. Assuring that misfeeding
does not occur on the farm is particularly difficult due to the large
number of cattle feeding operations in the United States, and FDA's
extremely limited resources to inspect these operations, which number
over 1 million.
Therefore, although overall compliance with the 1997 ruminant feed
rule has been high for renderers, protein blenders, and feed mills,
removal of the highest risk tissues from animal feed channels should
serve to address noncompliance with the rule that could result in
cattle exposure to prohibited material through cross-contamination,
mislabeling, or intentional or unintentional misfeeding.
D. Cattle Materials Proposed to be Prohibited From Use in All Animal
Food and Feed
1. Brain and Spinal Cord From Cattle 30 months of Age and Older
The USDA interim final rule published on January 12, 2004, provides
a full description of the scientific rationale for identifying the list
of tissues and selection of the 30-month age criterion used in its
definition of SRMs. FDA has adopted an identical definition of SRMs in
its interim final rule regarding FDA-regulated human food and
cosmetics. In the preamble of its July 14, 2004 interim final rule
regarding human food, including dietary supplements, and cosmetics, FDA
includes a detailed discussion of its rationale for the SRM definition.
As discussed in the preamble to the USDA and FDA interim final rules,
infectivity is not present in most tissues that harbor BSE infectivity
until more than 30 months after the animal was exposed to the agent.
Although the epidemiological and experimental data indicate that BSE
can develop in animals less than 30 months of age, the evidence
available to date indicates that this was a very rare occurrence, and
was associated with high levels of circulating infectivity at the peak
of the BSE epidemic in the United Kingdom. The agency continues to
believe that the rationale for the 30-month age criterion described
previously for human food and cosmetics is appropriate and proposes
that it be applied to animal feed as well.
In response to a question posed in the 2004 ANPRM as to which
tissues should be defined as SRMs for animal feed, FDA received
suggestions ranging from defining all animal protein as SRMs to
limiting the SRM definition to the head only. FDA considered
prohibiting from animal feed the same materials defined as SRMs that
are currently prohibited from use in food for humans, but decided that
proposing to require the removal of brain and spinal cord is the most
appropriate approach at this time.
In reaching the decision to propose to exclude only the brain and
spinal cord from animal feed, FDA considered information regarding the
tissue distribution of BSE infectivity. Under field conditions, BSE
infectivity has been found in the brain, spinal cord, and retina of the
eye in animals with clinical disease (Ref. 16). The Scientific Steering
Committee (SSC) of the European Union (Ref. 17) has also reported on
the proportion of total infectivity in various tissues.\1\ According to
the report, in an animal with clinical BSE, approximately 64 percent of
the infectivity is in the brain, 26 percent is in the spinal cord, 4
percent is in the dorsal root ganglia, 2.5 percent is in the trigeminal
ganglia, and 3 percent is in the distal ileum. The eyes are estimated
to contain less than 1 percent of the infectivity. Although available
data are limited on the distribution of tissue infectivity, data from
both naturally infected and experimentally infected cattle support the
finding that the brain and spinal cord are the tissues with the highest
level of infectivity.
---------------------------------------------------------------------------
\1\ A more recent report (Comer and Huntly, 2004, Journal of
Risk Research, 7, (5) 523-543) attributes 84.3 percent of
infectivity to brain and spinal cord and 9.6 percent to distal
ileum. We chose not to use the data from this more recent report
because its author (personal communications) explained that the
newer data suggesting that the level of infectivity in the distal
ileum at 6 to 18 months of age is higher than earlier estimates also
suggest that it is lower than earlier estimates at 32 months of age.
---------------------------------------------------------------------------
Because available data indicate that the brain and spinal cord
contain about 90 percent of BSE infectivity (Ref. 17), FDA believes
that the most appropriate course of action is to concentrate efforts on
excluding these highest risk tissues from animal feed. In deciding to
propose to prohibit brain and spinal cord only, rather than the same
list of materials previously defined as SRMs, FDA also considered the
following: (1) Surveillance data indicate the current risk of BSE to
U.S. cattle is very low, (2) the existing ruminant feed regulation
provides strong protection against BSE, and (3) the new measures
considered in this proposed rule represent a secondary level of
protection to address failures in compliance that may occur with the
existing ruminant feed rule. FDA believes that the existing ruminant
feed rule provides the primary line of defense by prohibiting the use
in ruminant feed of all material with potential BSE infectivity. The
measures proposed by this rule will effectively reinforce existing
ruminant feed protection measures by removing the tissues with the
highest infectivity from all animal feed. As a result, these measures
greatly minimize BSE risks if cross-contamination of ruminant feed with
non-ruminant feed, or diversion of non-ruminant feeds to ruminants,
were to occur.
2. Cattle Not Inspected and Passed for Human Consumption
As noted earlier in this document, the term ``cattle not inspected
and passed for human consumption'' includes cattle not inspected and
passed for human consumption by the appropriate regulatory authority as
well as nonambulatory disabled cattle.
European surveillance data indicate that cattle found dead or
culled onsite, where the carcass was submitted to rendering (fallen
stock), and cattle with health-related problems unfit for routine
slaughter (emergency slaughter) have a greater incidence of BSE than
healthy slaughter cattle. Surveillance data in the European Union in
2002 showed that there were 27.95 positive animals per 10,000 emergency
slaughter bovine animals tested and 6.15 positive animals per 10,000
fallen stock bovine animals tested compared to 0.31 positive animals
per 10,000 healthy slaughter animals tested (Ref. 18). In Switzerland,
the odds of finding a BSE case in fallen stock and emergency slaughter
cattle were found to be 49 and 58 times higher, respectively, compared
to the odds of finding a BSE case through passive surveillance (Ref.
19). These findings suggest that cattle not inspected and passed for
human consumption are more likely to test positive for BSE than healthy
cattle that have been inspected and passed for human consumption.
Because cattle not inspected and passed for human consumption are
included in the population of cattle at highest risk for BSE (Refs. 18
and 19), and processes are currently not established in the rendering
industry for verifying the age of such cattle through inspection, the
agency is proposing to define brains and spinal cords from all cattle
not inspected and passed for human consumption, regardless of age, to
be cattle materials prohibited in animal feed. As noted previously, the
[[Page 58579]]
term cattle not inspected and passed for human consumption is defined
in this proposed rule to include nonambulatory disabled cattle as
defined by FDA in its interim final rule on human food and cosmetics
and USDA in its interim final rule on human food. If the brains and
spinal cords are removed from these animals, FDA is proposing that the
remaining material can still be used in animal feed. FDA notes that for
cattle not inspected and passed that are diseased or that die other
than by slaughter, the entire carcass of such animals is adulterated
under section 402(a)(5) of the act. FDA has traditionally exercised
enforcement discretion with regard to the use of such animals in animal
feed. For example, see Compliance Policy Guide 675.400. FDA intends to
continue exercising such discretion for the use in animal feed of the
remaining material from cattle that are diseased or that die other than
by slaughter when the brain and spinal cord are removed. Because
comments to the ANPRM were mixed on the feasibility of removing SRMs
from cattle mortalities, FDA requests further comment on which tissues
should be removed from this class of animals and the feasibility of
removing them.
In deciding to propose to allow these remaining materials to be
used in animal feed, FDA considered the following: (1) brain and spinal
contain about 90 percent of BSE infectivity (Ref. 17), (2) surveillance
data indicate the current risk of BSE to U.S. cattle is very low, (3)
the existing ruminant feed rule provides strong protection against BSE,
and (4) the new measures considered in this proposed rule represent a
secondary level of protection to address failures in compliance that
may occur with the existing ruminant feed rule. FDA believes that the
existing ruminant feed rule provides the primary line of defense by
prohibiting the use in ruminant feed of all material with potential BSE
infectivity. If the brains and spinal cords are not removed from such
animals, FDA proposes that all parts of ``cattle not inspected and
passed for human consumption'' be prohibited.
3. Mechanically-Separated Beef (MS)
Mechanically-separated (MS) beef is a finely comminuted meat food
product resulting from the mechanical separation and removal of most of
the bone from attached skeletal muscle of cattle carcasses and parts of
carcasses. This proposed definition of MS beef is consistent with, but
not identical to, the definition of the term used by USDA in its 2004
interim final rule (69 FR 1862) prohibiting its use in human food and
by FDA in its 2004 interim final rule (69 FR 42255) prohibiting its use
in human food, including dietary supplements and cosmetics. Those
definitions provide that MS beef means a meat food product that meets
the specification in 9 CFR 319.5. This USDA regulation applies to MS
beef for human food use. Because there is MS beef produced solely for
animal feed use that would not fall within the USDA specification, the
definition of MS beef as proposed in this rule is meant to refer to
beef that is the product of the mechanical separation process,
regardless of whether it meets the USDA specifications for MS species
in 9 CFR 319.5. The definition of MS beef is not meant to include
product produced by Advanced Meat Recovery (AMR) systems used in the
meat industry.
Although MS beef was not considered in the 2002 ANPRM, 2004 ANPRM,
or in the IRT report, FDA has included this material in this animal
feed proposed rule to ensure that any such material that is used in
animal feed is not contaminated with the other material prohibited by
this proposed rule. A comment submitted in response to the 2004 ANPRM
said that FDA should allow mechanically separated beef to be used for
pet food if SRMs are removed from material going into the mechanical
deboning equipment that separates meat from bone, because some pet food
operations are very similar to slaughter establishments and are capable
of removing SRMs.
Because the mechanical separation process may result in the
contamination of the MS beef product with spinal cord, FDA proposes to
designate MS beef as cattle materials prohibited in animal feed if it
is derived from carcasses or parts of carcasses from which cattle
materials prohibited in animal feed were not previously removed.
4. Tallow
Tallow is an animal-derived hard fat that has been heat processed;
most tallow is derived from cattle. Any risk of BSE transmission from
tallow is a result of protein that is present as an impurity in the
tallow. Taylor et al. (Refs. 20 and 21) found, in rendering studies
with abnormal prion protein, that the prion protein did not
preferentially migrate into the fat fraction, but remained with the
protein fraction. Therefore, there is no reason to believe that tallow
is likely to contain unusually high amounts of prion protein as a
constituent of the insoluble impurities fraction that remains in tallow
after rendering. Taylor et al. (Refs. 20 and 21) also reported that the
various rendering processes used for tallow production in the United
Kingdom were sufficient to produce tallow that did not result in
infection when injected into the brains of mice, even though the
starting material was highly spiked with the scrapie agent. Wilesmith
et al. (Ref. 22) noted that the geographical variation in the incidence
of BSE in the United Kingdom was not consistent with the use of tallow
in cattle feed and concluded that the most likely source of infection
in cattle was BSE-contaminated meat and bone meal.
The Office International des Epizooties (OIE), the world
organization for animal health, categorizes tallow with insoluble
impurities of no more than 0.15 percent as protein-free tallow. OIE
guidelines recommend that tallow that meets this standard can be safely
traded regardless of the BSE status of the exporting country (Ref. 23).
FDA's Transmissible Spongiform Encephalopathy Advisory Committee
(TSEAC) considered the safety of tallow and tallow derivatives in 1998
(Ref. 24). Members of the committee indicated that tallow is a food
with negligible or no risk of transmitting BSE to humans or animals.
For the purposes of this proposed rule, tallow is defined as the
rendered fat of cattle obtained by pressing or by applying any other
extraction process to tissues derived directly from discrete adipose
tissue masses or to other carcass parts and tissues. The 1997 ruminant
feed final rule did not include tallow, fats, oils, and grease in the
definition of animal proteins prohibited in ruminant feed because they
are not proteins and were not considered to contain BSE infectivity.
The agency said that infectivity studies conducted on some of these
products (e.g., tallow) had demonstrated that they were at low risk of
transmitting the TSE agent and; thus, it was unnecessary to restrict
their use in ruminant feed (62 FR 30935). While the agency is not aware
of any new scientific information suggesting that infectivity is
present in tallow itself, the agency is concerned about potential BSE
risks that tallow poses as a result of protein that is present as an
impurity. These impurities may be of greater concern now because, as
previously noted, new preliminary data suggest that the minimum
infectious dose for BSE may be substantially lower than previously
thought. We seek comment on this interpretation of the preliminary
results.
The agency is proposing to prohibit the use of tallow in animal
food or feed that is derived from cattle materials prohibited in animal
feed. However, the agency proposes to exempt from this requirement
tallow that contains no
[[Page 58580]]
more than 0.15 percent insoluble impurities. The proposal would require
that impurities be measured by the method entitled ``Insoluble
Impurities'' (AOCS Official Method Ca 3a-46), American Oil Chemists'
Society, which is incorporated by reference in accordance with 5 U.S.C.
552(a) and 1 CFR part 51, or another method equivalent in accuracy,
precision, and sensitivity to A.O.C.S. Official Method Ca 3a-46. In
response to the 2004 ANPRM, comments were submitted to the agency
requesting that the primary method for the impurity determination for
tallow be one other than the method in the Food Chemicals Codex.
Comments stated that the domestic tallow industry primarily uses a
method of AOCS to measure insoluble impurities. In comparison to the
Food Chemicals Codex method, comments stated that the AOCS method is
less expensive, requires less solvent, and has lower solvent disposal
costs. In addition, it does not require specialized equipment or
supplies. FDA agrees with these comments, and proposes that the primary
method for the impurity determination for tallow be the method from
AOCS rather than the method in the Food Chemicals Codex.
This proposed requirement for tallow would apply to all animal
feed, including feed for ruminants. Since the existing ruminant feed
rule Sec. 589.2000 (21 CFR 589.2000) does not include provisions
relative to tallow, this proposal represents a new requirement for
ruminant feed as well as for feed for non-ruminants. To make clear that
this proposed requirement would apply to ruminant feed, FDA is
proposing to amend Sec. 589.2000 to include the tallow requirements.
FDA is also proposing to exempt tallow derivatives from the
requirements of this rulemaking. Tallow derivatives are produced by
subjecting tallow to chemical processes (hydrolysis,
transesterification, and saponification) that involve high temperature
and pressure. FDA's TSEAC considered tallow derivatives in 1998 (Ref.
24), and determined that the rigorous conditions of manufacture are
sufficient to reduce the BSE risk in tallow derivatives to
insignificant levels. In addition, according to OIE guidelines tallow
derivatives produced by hydrolysis, saponification, or
transesterification using high temperature and pressure can be safely
traded regardless of the BSE risk status of the country of origin (Ref.
23).
E. Disposal of Cattle Materials Prohibited in Animal Feed
FDA agrees with comments from the affected industry that a
comprehensive plan would be needed to safely dispose of approximately
2.5 billion pounds of material if FDA decided to prohibit all dead
stock and the full list of SRMs, as defined in the USDA interim final
rule (69 FR 1862) and the FDA interim final rule (69 FR 42255), from
being rendered for use in animal feed. The 2.5 billion pounds of cattle
material includes approximately 1.4 billion pounds of material from
cattle slaughtered for human consumption and 1.1 billion pounds of
material from cattle not inspected and passed for human consumption
that are currently being rendered for use in animal feed. FDA is
concerned about the feasibility of establishing a new infrastructure to
safely dispose of this large quantity of material, as well as the time
it would take to implement these processes.
Limiting the list of SRMs as proposed by this rule reduces the
volume of slaughter byproducts that would require alternative disposal.
First, this proposal does not require the diversion from use in animal
feed the small intestine and tonsils from the 28 million head of cattle
under 30 months of age that are slaughtered annually. Second, only the
brain and spinal cord (weighing 1.3 pounds per animal) rather than the
head, spinal column, and small intestine, (weighing 88.5 pounds per
animal) are diverted from the estimated 7 million head of cattle over
30 months of age that are slaughtered annually in the U.S. FDA believes
that this more limited amount of material from slaughter operations can
be disposed of through landfill, incineration, or alkaline digestion.
Based on comments received, FDA acknowledges that there is some
uncertainty regarding the amount of material that will require
alternative disposal as a result of the proposed requirements
pertaining to cattle not inspected and passed for human consumption
(i.e., dead stock and nonambulatory disabled cattle). FDA is including
in this proposed rule the option to remove brain and spinal cord from
cattle not inspected and passed for human consumption so that most of
this material could continue to be rendered for use in animal feed. As
previously noted, FDA intends to continue exercising enforcement
discretion for the use in animal feed of the remaining material from
cattle that are diseased or that die other than by slaughter when the
brain and spinal cord are removed. As discussed in more detail in
Section IV, Analysis of Economic Impacts, FDA acknowledges that while
the proposed rule will result in additional material from these animals
being disposed of by means other than rendering, FDA believes such
increases will be modest. FDA seeks comment and further information on
the feasibility of removing brain and spinal cord from cattle not
inspected and passed for human consumption and on the impact of this
proposed rule on the number of these cattle that would be disposed of
by rendering.
In summary, FDA believes that the measures proposed by this rule
can be more feasibly implemented than a full SRM ban, and can add
substantially to the protection provided by the current BSE feed
regulation. With this approach, the resulting volume of material
requiring special disposal would be manageable in the short term. This
approach is also consistent with the advice of the IRT that a staged
approach may be necessary in implementation of an SRM ban. Further, FDA
believes that other feed controls that FDA previously considered, such
as dedicated facilities, are not needed if these high-risk tissues are
excluded from animal feed channels. Therefore, at this time FDA is not
proposing rulemaking to address other feed control recommendations of
the IRT or the additional planned measures announced by FDA on January
26, 2004.
III. Description of Proposed Rule and Legal Authority
FDA is proposing to establish a new Sec. 589.2001 (21 CFR
259.2001), Cattle materials prohibited in animal food or feed. While
the existing Sec. 589.2000 outlines requirements related to ruminant
feeds only, proposed Sec. 589.2001 outlines requirements intended to
apply to food or feed for all animal species. The terms and
requirements of proposed Sec. 589.2001 are described in section IV.A
of this document.
A. Definitions
The proposed Sec. 589.2001(a) defines the following terms for the
purposes of this regulation:
(1) Cattle materials prohibited in animal feed includes: (i) the
brains and spinal cords of cattle 30 months of age and older; (ii) the
brains and spinal cords of cattle of any age not inspected and passed
for human consumption; (iii) the entire carcass of cattle not inspected
and passed for human consumption from which brains and spinal cords
were not removed; (iv) mechanically separated beef that is derived from
cattle materials prohibited
[[Page 58581]]
under (i), (ii), or (iii) above; and (v) tallow that is derived from
cattle materials prohibited under (i), (ii), or (iii) above. Tallow
that is derived from cattle materials prohibited under (i), (ii), or
(iii) above that contains no more than 0.15 percent insoluble
impurities and tallow derivatives are not considered cattle materials
prohibited in animal feeds.
(2) Cattle not inspected and passed for human consumption means
cattle of any age that were not inspected and passed for human
consumption by the appropriate regulatory authority. This term includes
nonambulatory disabled cattle. Non-ambulatory disabled cattle are
cattle that cannot rise from a recumbent position or that cannot walk,
including, but not limited to, those with broken appendages, severed
tendons or ligaments, nerve paralysis, fractured vertebral column, or
metabolic conditions.
(3) Mechanically separated beef means a meat food product that is
finely comminuted, resulting from the mechanical separation and removal
of most of the bone from attached skeletal muscle of cattle carcasses
and parts of carcasses.
(4) Renderer means any firm or individual that processes slaughter
byproducts, animals unfit for human consumption, or meat scraps. The
term includes persons who collect such materials and subject them to
minimal processing, or distribute them to firms other than renderers
(as defined in paragraph (a)(1)) whose intended use for the products
may include animal feed, industrial use, or other uses. The term
includes renderers that also blend animal protein products.
(5) Tallow means the rendered fat of cattle obtained by pressing or
by applying any other extraction process to tissues derived directly
from discrete adipose tissue masses or to other carcass parts and
tissues.
(6) Tallow derivative means any product obtained through initial
hydrolysis, saponification, or trans-esterification of tallow; chemical
conversion of material obtained by hydrolysis, saponification, or
trans-esterification may be applied to obtain the desired product.
B. Proposed Requirements
Proposed Sec. 589.2001(b)(1) provides that no animal food or feed
shall be manufactured from, processed with, or otherwise contain cattle
materials prohibited in animal feed. Proposed Sec. 589.2001(b)(2)
provides new requirements for renderers that handle cattle material
prohibited in animal feed. Proposed Sec. 589.2001(b)(3) provides new
requirements for renderers that handle any cattle material.
1. Proposed Requirements for Renderers That Manufacture, Process,
Blend, or Distribute Cattle Materials Prohibited in Animal Feed
The proposed Sec. 589.2001(b)(2) requires that renderers that
handle cattle materials prohibited in animal feed use separate
equipment or containers to handle such material once it has been
separated from other cattle materials. This requirement is intended to
ensure that equipment used to manufacture, process, blend, store, or
transport cattle materials prohibited in animal feed or products that
contain or may contain cattle materials prohibited in animal feed do
not serve as a source of cross-contamination for materials intended for
animal feed. In addition, proposed Sec. 589.2001(b)(2) requires
renderers that manufacture, process, blend, or distribute cattle
materials prohibited in animal feed or products that contain or may
contain cattle materials prohibited in animal feed must: (1) Label the
prohibited materials in a conspicuous manner with the statement ``Do
not feed to animals''; (2) mark the prohibited material with an agent
that can be readily detected on visual inspection; and (3) establish
and maintain records sufficient to track the prohibited materials to
ensure such material is not introduced into animal feed, and make the
records available for inspection and copying by FDA. These proposed
requirements are intended to ensure that cattle materials prohibited in
animal feed do not enter the animal feed chain and thus have no
opportunity for inclusion in animal food or feed. FDA believes that
such material must be both labeled and marked to ensure that it does
not enter the feed channels since without such measures this material
would be indistinguishable from cattle materials not prohibited by this
proposed rule. Marking the material will provide a readily detectable
method on visual examination by which all persons in the animal feed
chain can be made aware that the a product is prohibited material or
contains prohibited material. Marking also will serve as a way to make
the status of the material known if, for some reason, the label ``Do
not feed to animals'' is separated from the product.
2. Proposed Requirements for Renderers that Manufacture, Process,
Blend, or Distribute Any Cattle Materials
Proposed Sec. 589.2001(b)(3) requires that renderers that handle
any cattle materials shall: (1) Establish and maintain records
sufficient to demonstrate that material rendered for use in animal feed
was not manufactured from, processed with, or does not otherwise
contain, cattle materials prohibited in animal feed, (2) make copies of
records available for inspection and copying by FDA, and (3) be in
compliance with requirements under Sec. 589.2000 regarding animal
proteins prohibited in ruminant feed.
C. Proposed Recordkeeping and Access Requirements
The proposed recordkeeping requirements associated with this rule
are focused on renderers because FDA believes this is the point at
which cattle material prohibited in animal feed could enter the animal
feed channel. Renderers, as defined in this proposed rule, receive
cattle materials from slaughter facilities or receive entire cattle
carcasses that were not inspected and passed for human consumption and
further process that material so that it may be used in animal feed.
FDA believes this is the critical control point in the feed and feed
ingredient processing channel at which the exclusion of cattle material
prohibited in animal feed must be documented. Once material is removed
from cattle and further processed, we may not be able to obtain the
information necessary to determine whether it is cattle material
prohibited in animal feed. There is currently no way to reliably test
feed or feed ingredients for the presence of the BSE agent or for the
presence of cattle materials prohibited in animal feed.
This proposed rule requires that no animal feed or feed ingredient
be manufactured from, processed with, or otherwise contain cattle
materials prohibited in animal feed. However, FDA does not believe it
is necessary for persons, other than renderers, that are involved in
the manufacture or processing of feed or feed ingredients to maintain
records documenting the exclusion of cattle materials prohibited in
animal feed. FDA believes, for the reasons cited previously, that it is
critical that such records be maintained at the point of the renderer.
However, FDA believes that requiring the maintenance of such records at
all manufacturing and processing points downstream would be redundant
and provide little additional information of value. FDA seeks comments
on the need to require that records be maintained by persons other than
renderers.
Because at this time there is no way to test reliably for the
presence of the BSE agent or the presence of the cattle materials
prohibited in proposed Sec. 589.2001(b)(1), renderers must depend
[[Page 58582]]
on records to ensure that the materials prohibited by this proposed
rule are excluded from material intended for use in animal feed and
that such material is appropriately disposed. Similarly, without
adequate records kept by renderers and access to the records by the
agency, FDA may not know whether renderers have complied with the
requirements. We are proposing in Sec. 589.2001(b)(2)(iv) that
renderers that manufacture, process, blend, or distribute cattle
materials prohibited in animal feed establish and maintain records
sufficient to demonstrate that such material was not introduced into
animal feed. Furthermore, we are proposing in Sec. 589.2001(b)(3)(i)
that renderers that manufacture, process, blend, or distribute cattle
materials establish and maintain records sufficient to demonstrate that
material rendered for use in animal feed was not manufactured from,
processed with, or does not otherwise contain, cattle materials
prohibited in animal feed.
Proposed Sec. 589.2001(d) requires that the records required by
this proposed rule be maintained for a minimum of 1 year. The 1-year
record retention period is consistent with the existing requirements
for ruminant feeds in Sec. 589.2000(h). We believe that for the
purposes of the recordkeeping requirements, 1 year is appropriate in
light of the time that the products will be in the animal feed
production and distribution systems. Extending the record retention
period would have little practical value in determining the source of
BSE in an animal. This is also considering the potentially long time
period from ingestion of the BSE agent in feed to manifestation of
clinical signs and lesions and the lack of a reliable estimate for the
latency period.
The proposed rule does not specify the types of records that would
need to be maintained in order to comply with the recordkeeping
requirements. The agency seeks comments on what type of records would
be appropriate and whether further detail is needed in the regulation
regarding specific record requirements such as the specific data
elements that must be included in such records.
D. Conforming Changes to Sec. 589.2000--Animal Proteins Prohibited in
Ruminant Feed
The requirements related to tallow in the proposed Sec. 589.2001
are intended to apply to all animal feed, including feed for ruminants.
Since the existing ruminant feed rule (Sec. 589.2000) does not include
provisions relative to tallow, this proposal represents a new
requirement for ruminant feed as well as for feed for non-ruminants.
Therefore, due to concerns about protein impurities present in tallow,
FDA is proposing to amend Sec. 589.2000 to include tallow in the
definition of ``protein derived from mammalian tissues'' and to add
language that excludes from the definition of ``protein derived from
mammalian tissues'' tallow containing no more than 0.15 percent
insoluble impurities and tallow derivatives as specified in proposed
Sec. 589.2001.
E. Legal Authority
FDA is issuing this proposed regulation on animal feed under the
food adulteration provisions in sections 402(a)(2)(C), (a)(3), (a)(4),
(a)(5), 409, and 701(a) of the Federal Food, Drug, and Cosmetic Act
(the act) (21 U.S.C. 342(a)(2)(C), (a)(3), (a)(4), (a)(5), 348, and
371(a)). The term ``food'' is defined to include articles used for food
``for man or other animals.'' See section 201 of the act (21 U.S.C.
321(f)). We note that the material that would be prohibited under this
proposed rule from use in animal feed continues to meet the definition
of food. Therefore, this material would be adulterated or misbranded
under the act based on violations of the proposed rule, as well as any
animal feed or feed ingredients that were manufactured from, processed
with, or otherwise contained, the prohibited material.
Under section 402(a)(3) of the act, a food is deemed adulterated
``if it consists in whole or in part of any filthy, putrid, or
decomposed substance, or if it is otherwise unfit for food.''
``Otherwise unfit for food'' is an independent clause in section
402(a)(3). The statute does not require that a food be filthy, putrid,
or decomposed for it to be ``otherwise unfit for food.'' In FDA's
interim final rule on the Use of Materials Derived from Cattle in Human
Food and Cosmetics (69 FR 42256 at 42264), we concluded that a food can
be ``otherwise unfit for food'' based on health risks, and sought
comments on that interpretation. Because of the possibility of
intentional or unintentional use of the materials that would prohibited
under this proposed rule in ruminant feed and the risk of BSE to
ruminants and humans from these materials, we have tentatively
concluded that these materials would be ``otherwise unfit for food''
under section 402(a)(3) of the act. We seek comment on this
interpretation.
Under section 402(a)(4) of the act, a food is deemed adulterated
``if it has been prepared, packed, or held under insanitary conditions
whereby it may have become contaminated with filth, or whereby it may
have been rendered injurious to health.'' The failure to ensure that
animal feed is prepared, packed, or held under conditions in which
cattle materials prohibited in animal feed under this proposed rule do
not contaminate animal feed would constitute an insanitary condition
whereby the feed may have been rendered injurious to health. Thus, this
insanitary condition would render the animal feed adulterated under
section 402(a)(4) of the act.
Under section 402(a)(5) of the act, food is deemed adulterated ``if
it is, in whole or in part, the product * * * of an animal which has
died otherwise than by slaughter.'' Some cattle are not inspected and
passed because they are diseased or have died before slaughter.
Material from these cattle that are diseased or that die otherwise than
by slaughter that is used as animal feed would render that feed
adulterated under section 402(a)(5) of the Act. FDA has traditionally
exercised enforcement discretion with regard to the use of such animals
in animal feed. For example, see Compliance Policy Guide 675.400. FDA
intends to continue exercising such discretion for the use in animal
feed of the remaining material from cattle that are diseased or that
die other than by slaughter when the brain and spinal cord are removed.
We are also relying on the adulteration provision in section
402(a)(2)(C)(i) of the act. Section 402(a)(2)(C)(i) deems a food
adulterated if it is or bears or contains a food additive that is
unsafe under section 409 of the act. Section 201(s) of the act, (21
U.S.C. 321(s)), defines as a food additive any substance whose intended
use results or may reasonably be expected to result in it becoming a
component of food unless, among other things, it is the subject of a
prior sanction (explicit approval for a specific use by USDA or FDA
before September 6, 1958), or is generally recognized as safe (GRAS).
Section 409 of the act provides that a food additive is unsafe unless
it and its use conform to a food additive regulation or an exemption
under section 409(j).
Prior sanctions are described in part 570 (21 CFR part 570). FDA is
not aware of any prior sanctions that relate to the present animal feed
use of the cattle material that would be prohibited in animal feed
under this proposed rule. Any person who intends to assert or rely on
such sanction is required to submit proof of the existence of the
applicable prior sanction. The failure of any person to come forward
with proof of such an applicable prior sanction in response to this
notice will constitute a waiver of
[[Page 58583]]
the right to assert or rely on such sanction at any later time.
A determination that a substance added directly or indirectly to a
food is GRAS, for its intended use is generally based on scientific
information regarding the composition of the substance, its use, method
of preparation, methods for detecting its presence in food, and
information about its functionality in food as determined by experts
qualified by scientific training and experience to evaluate the safety
of such a substance (Sec. 570.30). A substance added to food becomes
GRAS as a result of a common understanding about the substance
throughout the scientific community familiar with the safety of such
substances. The basis of expert views may be either scientific
procedures, or, in the case of a substance used in food before January
1, 1958, experience based on common use in food (Sec. 570.30(a)).
Substances that are GRAS based on use before January 1, 1958, must be
currently recognized as safe based on their pre-1958 use (See United
States v. Naremco, 553 F. 2d 1138 (8th Cir. 1977; compare United States
v. Western Serum, 666 F. 2d 335 (9th Cir. 1982)).
General recognition of safety based upon scientific procedures
requires the same quantity and quality of scientific evidence as is
required to obtain approval of a food additive regulation for the
ingredient (21 CFR 570.30(b)). (See United States v. Naremco, 553 F.2d
at 1143). A substance is not GRAS if there is a genuine dispute among
experts as to its recognition (An Article of Drug * * * Furestrol
Vaginal Suppositories, 294 F. Supp 1307 (N.D. Ga. 1968), aff'd 415 F.2d
390 (5th Cir. 1969)). It is not enough, in attempting to establish that
a substance is GRAS, to establish that there is an absence of
scientific studies that demonstrate the substance to be unsafe; there
must be studies that show the substance to be safe (United States v. An
Article of Food * * * CoCo Rico, 752 F.2d 11 (1st Cir. 1985)).
Conversely, a substance may be ineligible for GRAS status if studies
show that the substance is, or may be, unsafe, or if there is a
conflict in studies.
Expert opinion that cattle materials that would be prohibited in
animal feed under this proposed rule are GRAS would need to be
supported by scientific literature and other sources of data and
information, establishing that there is a reasonable certainty of no
harm from the material under the intended conditions of use. Expert
opinion would need to address topics such as whether BSE infectivity
can be detected, and whether it is reasonably certain that the BSE
agent will not be transmitted through cattle materials that would
prohibited in animal feed under this proposed rule. The burden of
establishing that a substance is GRAS is on the proponent of the
substance. (See CoCo Rico, supra.)
For the reasons discussed in other sections of this document, the
agency is tentatively concluding that cattle materials prohibited in
animal feed under this proposed rule are not GRAS by qualified experts
for use in animal food and, therefore, would be food additives. Section
402(a)(2)(C)(i) and (ii) of the act deems food adulterated ``if it is
or it bears or contains any food additive which is unsafe within the
meaning of section 409 * * * .'' Under section 409(a), a food additive
is unsafe unless a food additive regulation or an exemption is in
effect with respect to its use or its intended use. Therefore, in the
absence of a food additive regulation or an exemption, the cattle
materials that would be prohibited in animal feed under this proposed
rule would be adulterated under section 402(a)(2)(C)(i) of the act
because it bears or contains an unsafe food additive, and their
presence in animal feed would render the food adulterated.
Under section 701(a) of the act, FDA is authorized to issue
regulations for the act's efficient enforcement. The proposed
regulation would require measures to prevent animal food from being
unfit for food, being or bearing an unsafe food additive, being the
product of an animal that died otherwise than by slaughter. The
measures will also be required to prevent animal food from being held
under insanitary conditions whereby it may have been rendered injurious
to health. These proposed measures would allow for the efficient
enforcement of the act. Under the proposed regulations, renderers would
be required to establish and maintain records to track cattle materials
prohibited in animal feed to ensure that such material is not
introduced into animal feed and make such records available to FDA for
inspection and copying. Once material is removed from cattle, we may
not be able to obtain the information necessary to determine whether it
is prohibited cattle material. Because at this time there is no way to
test reliably for the presence of the BSE agent or the presence of the
cattle materials prohibited in proposed Sec. 589.2001(b)(1), renderers
must depend on records to ensure that their products do not contain
cattle materials prohibited from animal feed. In addition, without
adequate records, FDA cannot know whether renderers have complied with
the regulations that prohibit the use of certain cattle material in
rendered products intended for animal feed. For example, we would not
know from examination of a spinal cord whether the source animal was
over 30 months of age at the time of slaughter or whether the cattle
had been inspected and passed. Therefore, the proposed recordkeeping
and records access requirements are necessary for the efficient
enforcement of the proposed rule. Under the proposed rule, failure to
comply with the recordkeeping and records access requirements would
render the cattle material and any animal feed manufactured from,
processed with, or otherwise containing, the cattle material
adulterated under section 402(a)(4) of the act.
Furthermore, the proposed marking provision in Sec. 589.2001 is
necessary for the efficient enforcement of the act. Because there is
currently no reliable method to determine which cattle materials would
be the prohibited materials, marking is necessary to ensure compliance
with the proposed requirement that animal feed is not manufactured
from, processed with, or otherwise contains the prohibited cattle
materials. Under the proposed rule, failure to comply with this marking
requirement would render the cattle material and any animal feed
manufactured from, processed with, or otherwise containing, the cattle
material adulterated under section 402(a)(4) of the act.
FDA is issuing the proposed labeling requirement under sections
403(a)(1) and 201(n) of the act (21 U.S.C. 343(a)(1)). Section
403(a)(1) provides that a food is deemed misbranded if its labeling is
false or misleading in any particular. Section 201(n) provides that:
* * * in determining whether the labeling of a product is
misleading, there shall be taken into account (among other things)
not only representations made or suggested by statement, word,
design, device, or any combination thereof, but also the extent to
which the labeling * * * fails to reveal facts material in light of
such representations or material with respect to consequences which
may result from the use of the article to which the labeling * * *
relates under conditions of use prescribed in the labeling * * * or
under such conditions of use as are customary or usual.
The proposed rule would require cattle material prohibited in
animal feed to be labeled ``Do not feed to animals.'' We believe this
statement is material with respect to the consequences that may result
from the use of this material within the meaning of section 201(n) of
the act. As discussed in other sections of this document, the use of
the material
[[Page 58584]]
that would be prohibited under this proposed rule presents a risk of
BSE. Furthermore, there are no available definitive tests to detect
this material in feed. Therefore, under this proposed rule, the failure
to include this labeling statement would render the cattle material or
feed containing the prohibited cattle material misbranded under section
403(a)(1) of the act. We are also proposing that such statement be made
in a conspicuous manner. Under section 403(f) of the act, (21 U.S.C.
343(f)), a food is misbranded if ``any word, statement, or other
information required by or under authority of this Act to appear on the
label or labeling is not prominently placed thereon with such
conspicuousness * * * and in such terms as to render it likely to be
read and understood by the ordinary individual under customary
condition of purchase and use.'' Therefore, under the proposed rule,
the failure to include the statement ``Do not feed to animals'' in a
conspicuous manner would render the cattle materials or any feed
containing the cattle materials misbranded under section 403(f) of the
act.
IV. Analysis of Economic Impacts
FDA has examined the impacts of the proposed rule under Executive
Order 12866, the Regulatory Flexibility Act (5 U.S.C. 601-612), and the
Unfunded Mandates Reform Act of 1995 (Public Law 104-4). Executive
Order 12866 directs agencies to assess all costs and benefits of
available regulatory alternatives and, when regulation is necessary, to
select regulatory approaches that maximize net benefits (including
potential economic, environmental, public health and safety, and other
advantages; distributive impacts, and equity).
Section 202(a) of the Unfunded Mandates Reform Act of 1995 requires
that agencies prepare a written statement, which includes an assessment
of anticipated costs and benefits, before proposing ``any rule that
includes any Federal mandate that may result in the expenditure by
State, local, and tribal governments, in the aggregate, or by the
private sector, of $100,000,000 or more (adjusted annually for
inflation) in any one year.'' The current threshold after adjustment
for inflation is $115 million, using the most current (2003) Implicit
Price Deflator for the Gross Domestic Product. FDA does not expect this
proposed rule to result in any 1-year expenditure that would meet or
exceed this amount.
FDA tentatively finds that the proposed rule does not constitute an
economically significant regulatory action as defined in Section
3(f)(1) of Executive Order 12866. We base this conclusion on both a
study of the impacts on industry of the proposed rule (on file at the
Division of Dockets Management (see ADDRESSES) conducted for FDA by the
Eastern Research Group (ERG)), a private consulting firm, and the
discussion in the remainder of this section (Ref. 25). The agency has
further tentatively determined that the proposed rule may have a
significant impact on a substantial number of small entities. This
proposed rule imposes no mandates on government entities, and would not
be expected to require the expenditure of over $115 million in any 1
year by the private sector. As such, no further analysis of anticipated
costs and benefits is required by the Unfunded Mandates Reform Act.
The following regulatory impact analysis begins with a summary of
the proposed rule and the expected benefits and costs. Next, in section
V.B of this document, we discuss the need for the regulation. In
section V.C, we discuss the benefits of the proposed rule, while in
section V.D, we discuss the costs. In section V.E, we discuss the costs
to the government. Finally, in section V.F, we discuss the regulatory
flexibility analysis.
A. Summary of Proposed Regulatory Impact Analysis
The proposed regulation would prohibit the use of certain cattle
materials in any animal feed. The cattle materials prohibited in animal
feed (CMPAF) would include the brain and spinal cord of all cattle 30
months of age or older, as well as the brain and spinal cord of cattle
not inspected and passed for human consumption regardless of age, the
entire carcass of cattle not inspected and passed if brain and spinal
cord is not removed (again, regardless of age), as well as other
materials. For the purposes of this proposed rule, the term ``cattle
not inspected and passed for human consumption'' includes nonambulatory
disabled cattle. Tallow derived from any of the prohibited materials
named previously would also be banned from use in animal feed unless it
contains no more than 0.15 percent insoluble impurities. MS beef from
any of the prohibited materials named above would be prohibited from
use in animal feed. Additional provisions of the proposed rule would
require renderers that handle cattle materials prohibited in animal
feed to use separate equipment or containers to handle this material
once it has been separated from other cattle materials. Such renderers
will also be required to follow certain procedures for labeling and
marking prohibited material and recordkeeping and records access.
The benefits of the proposed rule include the elimination of the
vast majority of the risk of spreading BSE to other cattle from
intentional or unintentional use of non-ruminant feed for ruminants or
cross-contamination of ruminant feed with non-ruminant feed or
ingredients intended for non-ruminant feed. FDA believes that the
proposed rule would effectively remove from use in non-ruminant feeds
those cattle tissues that account for approximately 90 percent of
potential BSE infectivity. Although the animal and public health
benefit associated with the additional BSE risk reduction is paramount,
the U.S. economy may also benefit from increased exports to the extent
that the proposed rule, if finalized, persuades foreign governments
that U.S. beef products are safe to import. Although we are unable to
quantify these benefits, they are potentially large, because the
expected loss of exports from the discovery of one infected cow in
Washington State in December 2003 amounted to approximately $3.4
billion in the first year (Ref. 26).
The total costs to industry of complying with the proposed rule
range from roughly $14 million to $24 million per year annualized over
10 years assuming a 7-percent discount rate (at a 3-percent discount
rate, the cost would range from $14 million to $23 million). These
estimated costs are the sum of the costs including: (1) The ban on the
use of certain tissues from cattle 30 months of age or older and cattle
not inspected and passed for human consumption in any animal feed and
(2) feed substitution costs. We discuss the proposed brain and spinal
cord prohibitions as direct costs to the affected firms (including
disposal costs, where applicable) and the firms' lost revenues from the
ban on these raw materials used in feed product inputs. Then, we
discuss the costs incurred by feed substitution costs. Table 1 of this
document shows a summary of these costs.
The proposed ban on the use of certain tissues from cattle 30
months of age or older and cattle not inspected and passed for human
consumption in any animal feed would require slaughterers and renderers
that process cattle 30 months of age or older and firms that process
dead, down, disabled, and diseased cattle to separate the CMPAF from
the remaining cattle offal that could still be used for animal feed. We
estimate that, for slaughterers, the separation of these materials from
cattle
[[Page 58585]]
30 months of age or older and cattle not inspected and passed for human
consumption regardless of age would require about $555,000 in one-time
capital costs (or $79,000 annualized at 7 percent and $65,000
annualized at 3 percent, over 10 years) (see table 1 of this document).
We estimate that the annual cost of the additional labor to separate
these CMPAF from other cattle offal is estimated to cost about $597,000
annually. Although compliance costs for these activities would be borne
initially by slaughterers, and are presented as such by ERG, a portion
of the costs are likely to be passed along to cattle producers and
consumers. For renderers, capital investments and labor for separation
and segregation of CMPAF would range from about $1.88 million to $4.65
million annually.
Our analysis does not project a specific disposal route for CMPAF
due to the uncertainty inherent in disposing of such low volumes of
material. Instead, it describes various disposal methods that may be
employed and estimated a $12 per 100 lbs. (cwt) of CMPAF disposal cost
(including transportation costs) for the low-cost end of the range of
disposal methods. The cost to dispose of the CMPAF is estimated to
range from $7.72 million to $9.97 million annually. Additional on-farm
disposal of dead and nonambulatory disabled cattle is expected to
increase compliance costs from about $1.02 million to $2.53 million
annually (including labor and equipment). The annual revenues foregone
from meat and bone meal (MBM) sales due to the prohibition of CMPAF in
animal feeds are estimated at $1.41 million to $2.78 million, and
foregone tallow sales are estimated at $1.37 million to $2.62 million.
This includes the value from CMPAF from cattle 30 months of age or
older and cattle not inspected and passed for human consumption
regardless of age, as well as from whole carcasses of cattle not
inspected and passed for human consumption that could not be rendered
due to this proposed rule.
We considered including a provision in this proposed rule that
would limit the use of all tallow in animal feed to that which contains
no more than 0.15 percent insoluble impurities, not just tallow derived
from the materials proposed to be prohibited in animal feed that
contains no more than 0.15 percent insoluble impurities. Analysis of
this alternative concluded that it would result in annualized costs of
about $1.78 million. These costs would consist of capital and operating
costs for polishing centrifuges that would be needed by a small segment
of independent renderers. We have not included a provision requiring
that all tallow meet the 0.15 percent limit in the proposal because the
CMPAF ban would effectively negate the risk of infectivity in non-
CMPAF-derived tallow. We invite public comments and data on the need
for, and impacts of, a provision that would require all tallow used in
animal feeds meet the 0.15 percent limit.
Table 1.--Total Costs ($ Millions)
------------------------------------------------------------------------
Annualized
Cost Item One-Time Cost Annual Costs Costs\1\
------------------------------------------------------------------------
Slaughter Facilities .............. .............. ................
------------------------------------------------------------------------
Capital Investments $0.56 N/A $0.08
------------------------------------------------------------------------
Labor .............. $0.60 $0.60
------------------------------------------------------------------------
Lost Value of MBM .............. $1.41--$2.76 $1.41--$2.78
(cattle 30 months of
age or older, cattle
not inspected and
passed)
------------------------------------------------------------------------
Lost Value of Tallow .............. $1.37--$2.62 $1.37--$2.62
(cattle 30 months of
age or older, cattle
not inspected and
passed)
------------------------------------------------------------------------
Disposal of cattle not .............. .............. ................
inspected and passed
------------------------------------------------------------------------
Labor .............. $0.12--$0.29 $0.12--$0.29
------------------------------------------------------------------------
Equipment .............. $0.9--$2.23 $0.9--$2.23
------------------------------------------------------------------------
Renderer Facilities .............. .............. ................
------------------------------------------------------------------------
Capital Investments $3.11-$7.67 $0.04--$0.11 $0.49--$1.20
------------------------------------------------------------------------
Labor .............. $1.40--$3.45 $1.40--$3.45
------------------------------------------------------------------------
Disposal of CMPAF from .............. $7.72--$9.97 $7.72--$9.97
cattle 30 months of
age or older, cattle
not inspected and
passed
------------------------------------------------------------------------
CMPAF Marking (High .............. $0.01 $0.01
Estimate)
------------------------------------------------------------------------
Recordkeeping/Labeling $0.10 $0.05 $0.06
------------------------------------------------------------------------
Feed Substitution .............. $0.30--$0.46 $0.30--$0.46
------------------------------------------------------------------------
Proposed Rule Total $3.76 $13.91--$22.5 $14.44--$23.75
Costs 6
------------------------------------------------------------------------
\1\ Annualized costs equal to annual costs plus one-time costs at 7
percent over 10 years. Using a 3 percent rate, annualized costs equal
$23,535,000.
FDA believes that this proposal, when evaluated in terms of its
incremental cost-effectiveness at reducing risks from BSE, is more
consistent with efficient science-based risk management than other
regulatory approaches that it identified in the 2004 ANPRM. This
proposal limits use of animal tissues for which infectivity is high
relative to
[[Page 58586]]
tissue weight. Weight is a key determinant of the incremental costs
from excluding tissues from rendering for animal feed. The approach
adopted in this proposal is likely to be relatively cost-effective
because it is directed primarily at those tissues for which infectivity
is likely to be high relative to control compliance costs.
In the 2004 ANPRM, FDA stated it was considering prohibiting a
larger list of cattle tissues (the full SRM list) from use in all
animal feeds. Under this option, SRMs would be defined as the skull,
brain, eyes, spinal cord, trigeminal ganglia, vertebral column
(excluding the vertebrae of the tail, the transverse processes of the
thoracic and lumbar vertebrae, and the wings of the sacrum) and dorsal
root ganglia of all cattle over 30 months of age or older, including
the tonsils and distal ileum of all cattle regardless of age.
Additionally, this option would prohibit the small intestine of all
cattle, all material from nonambulatory disabled cattle, all material
from cattle that are not inspected and passed for human consumption,
and MS beef. Lastly, tallow derived from other prohibited materials and
containing more than 0.15 percent insoluble impurities would also be
prohibited from use in all animal feeds under this SRM option. As
detailed later in the analysis of alternatives, we have not included
all of these measures in this proposed rule because we believe the
proposed rule adequately addresses the risk from the presence of the
highest risk cattle material in the animal feed chain. We also note
that the proposed rule offers a more cost-effective approach to
achieving nearly the same level of protection against the spread of BSE
with regard to the presence of high-risk material in the non-ruminant
feed supply.
The approach described in the 2004 ANPRM is itself a refinement of
an approach announced early in 2004. In January 2004, shortly after
USDA reported finding a BSE-infected cow in Washington State, HHS
announced its intention to amend the current animal feed regulations by
adding several materials to the list of substances prohibited from use
in ruminant feed (Ref. 27). These materials included mammalian blood
and blood products; inspected meat products that have been cooked,
offered for human food, and then further heat-processed for feed (such
as plate waste and used cellulosic casings); and poultry litter.
Further, FDA planned to require establishments that manufacture,
process, blend, or distribute both products containing mammalian-
derived proteins and ruminant feed to use separate equipment or
facilities in their manufacture, processing and handling.
Preliminary analysis of the regulatory approach described in the
January 2004 announcement (Ref. 27) suggests that it is relatively less
effective in risk reduction compared to the CMPAF and SRM bans because
it would not remove the highest risk tissue (brain and spinal cord)
from animal feed channels. Instead, the approach described in the
January 2004 announcement would continue to allow the highest risk
cattle material in non-ruminant feed, but includes measures intended to
prevent cross-contamination of ruminant feed. Although we have not been
able to quantify the risk reduction associated with the approach
announced in January 2004, it is comparable in costs to the full SRM
ban described in the 2004 ANPRM. As a result we are not proposing it
here.
In developing this proposed rule we also considered other
alternatives (not included here), including combinations of bans of
various cattle tissues, from cattle of various ages (>30 months and <30
months) and various states (slaughtered for human food, deads,
downers). All of these resulted in costs over $100 million per year
with potential infective tissue reductions between 80 percent and 99
percent, when compared to the base case scenario.
Table 2 of this document lists the proposed rule (the CMPAF ban),
the SRM ban, and one of the options mentioned previously, namely a ban
on brain and spinal cord from slaughter cattle 30 months of age or
older, and a ban on the entire carcass of all dead and downed cattle.
The table lists both the expected costs of these options, and our best
estimate of the percent reduction in cattle tissues known to harbor BSE
infectivity. The proposed rule would reduce cattle oral ID50s (the
amount of infective material that would result in a case of BSE in 50
percent of the cattle that consumed it) that are available for use in
animal feed by about 90 percent as much as a ban on the full list of
SRMs (option 3), while imposing only 7 to 10 percent of the costs of
the SRM option (0.07 = $14 million/$195 million; 0.10 = $24 million/
$240 million). The second option would reduce the cattle oral ID50s by
more than 90 percent (a less than 10 percent increase over option 1),
but would impose costs that are about five to nine times greater than
option 1, though still only about 50 percent to 70 percent of the costs
of option 3. Based on the level of protection provided against the
spread of BSE and its cost-effectiveness, we believe the proposed rule
to be the most appropriate. FDA seeks further comment and scientific
and risk information on this analysis of additional regulatory options
for strengthening animal feed safeguards.
Table 2.--Cost-Effectiveness of Alternative Policies
------------------------------------------------------------------------
Option (Description of Banned Infectivity Annual Cost ($
Tissues/Materials) Reduction\1\ millions)
------------------------------------------------------------------------
CMPAF list from (1) Cattle 30 90% $14--$24
months or older, (2) deads,
(3) downers and (4), MS beef
if CMPAF not removed from
carcass, dedicated equipment/
container requirement;
tallow restriction (proposed
rule)
------------------------------------------------------------------------
Brain and spinal cord from >90% $115--$135\2\
cattle 30 months or older,
carcasses of all deads and
downs, MS Beef
------------------------------------------------------------------------
Full SRM list from cattle 30 >99% $195--$240
months or older, tonsils and
distal ileum from cattle of
all ages, carcass of all
deads and downers, MS beef,
tallow restriction
------------------------------------------------------------------------
\1\ Percent of ID50s from an infected animal that would be banned from
use in animal feed.
\2\ Detailed cost estimate of this alternative is not included in the
regulatory flexibility analysis section of this document.
[[Page 58587]]
B. Need for Regulation
Executive Order 12866 directs agencies to assess the need for any
significant regulatory action and an explanation of how the regulation
will meet that need. In this instance, FDA tentatively concludes that
private incentive systems for both suppliers and purchasers in markets
for cattle, rendering, and ruminant feed