| Comment Record|
Mr. Bruce Hiatt ||
2003-02-04 11:12:30 |
Virginia Farm Bureau Federation |
| Comments for FDA General |
1. General Comments
RE: Docket No. 02N-0273
To Whom It May Concern:
The Virginia Farm Bureau Federation’s following comments are in response to the Food and Drug Administration’s advance notice of proposed rulemaking, “Substances Prohibited From Use in Animal Food or Feed; Animal Proteins Prohibited in Ruminant Feed”, Docket No. 02N-0273. The comments are specific to FDA’s questions regarding the use of poultry litter in cattle feed.
The Virginia Farm Bureau Federation is Virginia’s largest agricultural membership organization representing over 36,888 farm families many of whom raise poultry, ruminants (primarily cattle) or both. Virginia’s poultry and meat animal sectors are significant and generated 49% of Virginia’s gross farm receipts in 2001. That year state poultry receipts exceeded $787 million, cattle receipts grossed nearly $350 million and sheep and wool contributed $3.3 million. Cattle receipts ranked second only to broiler receipts ($519 million).
1) How extensive is the use of poultry litter in cattle feed in the United States?
Poultry litter has been used as a feed supplement in certain cattle feeding programs in Virginia since at least 1976. Broiler litter is preferred above other poultry litter types as a cattle feed supplement due to broiler litter’s high level of palatability, relative supply and nutrient content. However, the practice of feeding poultry litter varies among state cattle producers according to cattle type produced, producer preference, proximity to poultry litter sources, litter availability and price, and, in some instances, cattle production and marketing contract constraints. To some extent, poultry litter may also be exported as a feed supplement to cattle farms in neighboring states.
Estimates indicate that approximately 10% of the poultry litter produced in Virginia or 58,000 tons/year is used as a cattle feed supplement. In 2002 Virginia’s cattle herd totaled 1.53 million head excluding milk cows. Poultry litter is not an approved feed supplement for lactating dairy animals.
2) What is the level of feed spillage in poultry litter?
Contract poultry grower compensation is based on feed conversion which encourages growers to minimize spilled feed. Estimates indicate spilled feed accounts for 0.5-1.0% of the total poultry feed fed during a grow-out cycle. The amount of actual spilled feed will vary by bird type and age, feeding equipment, flock production management, and possibly the feed itself. Poultry also consume some of the spilled feed from the litter.
3) What are the methods used to process poultry litter before inclusion in animal feed?
Poultry litter is generally processed by deep stacking, ensiling alone or ensiling with forages. Deep stacking consists of piling litter in a stack at least 6 feet or more deep and allowing the litter to go through a self-generated heating process for a period of two weeks or more or until the stack reaches 85-90% dry matter. Prior to deep stacking, broiler litter may typically originate at 72% dry matter and meat turkey litter likewise at 65% dry matter. Under extreme conditions, deep stacks may reach temperatures high enough to cause spontaneous combustion. Deep stacking is the most preferred method of processing poultry litter for use as a feed supplement.
Litter can be ensiled alone provided it contains 35-40% moisture with or without added water. Litter ensiled alone generally occurs in bunker-style silos or large plastic silo bags where the litter is allowed to heat and ferment.
Ensiling litter with forages is perhaps the second most popular method of processing poultry litter. Litter is typically ensiled with whole plant corn or small grains, like rye, at crop harvest. The mixture can be ensiled in both bunker and upright silo types or plastic silage bags. Forage and litter moisture levels vary; however, using normal dry matter contents, an ensiled mixture containing 80% whole plant corn and 20% broiler litter typically yields a desired 30% dry matter in the processed silage-litter mixture.
Processed poultry litter, deep stack or ensiled alone, is generally combined with grain, silage or other feed ingredients to formulate a cattle feed supplement that is fed in addition to hay or pasture. A processed silage-litter mix may, or not may not, be combined with grain to supplement hay and pasture. The amount of litter used to supplement cattle diets varies depending on the time of year, herd type and age, and price and availability of poultry litter and other feedstuffs.
4) What will be the adverse and positive impacts resulting from banning poultry litter in ruminant feed?
No known case of BSE exists in the United States. Banning the use of high risk ruminant tissue in poultry feeds is preferred and would prevent prohibited ruminant materials from being in poultry litter and would allow feeding litter to cattle and incidental litter consumption by cattle. Banning the use of high risk ruminant tissue in poultry feeds would avoid potential future concerns regarding the presence of BSE agents in both poultry meat production and poultry litter utilization. Such a ban would limit any adverse effects to the cattle and rendering industries.
Banning poultry litter in cattle feed would pose serious economic hardship for poultry growers and would severely hamper private and public sector efforts to manage the disposition of poultry litter in an environmentally sound manner. Again, no known case of BSE exists in the United States. However, the proposed ban would affect all poultry litter regardless of whether or not any spilled poultry feed contained ruminant protein. The proposed ban is based on the premise that all poultry processing companies and feed mills routinely use ruminant protein in formulating poultry feeds without FDA publicly documenting the extent of the practice. Such a ban would in effect pass the responsibility of managing high risk ruminant tissue’s end-use from the cattle and rendering industries to the poultry industry with no-net benefit to the poultry industry.
While it is estimated that 10% of Virginia’s poultry litter is fed to cattle, approximately 44% of the poultry litter is land applied as fertilizer to pasture and another 25% is applied to hay land. Banning poultry litter in cattle feed could quite possibly be extended to pasture and hay land in order to avoid incidental consumption of land applied litter by cattle. Applying litter to cropland instead of pasture and hay land would be difficult, since pasture and hay land are the predominant agricultural land uses in two of Virginia’s three major poultry growing regions. State law, and pending federal regulations, restricts the amount of poultry litter that can be land applied in effort control nitrogen and phosphorus environmental losses, further restricting agricultural lands that can receive poultry litter. Many cattlemen would suffer by the loss of poultry litter as an economical feed supplement, but even more cattlemen would suffer from the loss or further restricted use of poultry litter as a pasture and hay land fertilizer. There are few other alternative uses for poultry litter, most of which are relatively new and considerably difficult and expensive to establish.
Thank you for the opportunity to comment on the use of poultry litter in cattle feed. If additional information is needed, please contact Tony Banks, Asst. Director Commodity/Marketing Dept., at 804-290-1114 or firstname.lastname@example.org.
Bruce L. Hiatt, President
Virginia Farm Bureau Federation
Comments electronically submitted by Tony Banks