2004N-0264 - Federal Measures to Mitigate BSE Risks: Considerations for Further Action
FDA Comment Number : EC16
Submitter : Mr. Link Reinhiller Date & Time: 08/20/2004 07:08:23
Organization : Dakota Resource Council
Other Organization
Category :
Issue Areas/Comments
GENERAL
GENERAL
August 13, 2004

Dr. Lester Crawford, Acting Commissioner
Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, rm. 1061
Rockville, MD 20852

Re: Docket No. 2004N-0264: Comments on Proposed Rule for Federal Measures to Mitigate BSE Risks: Considerations for Further Action, 69 Federal Register 134 (July 14, 2004)

Dear Dr. Crawford:

Dakota Resource Council is submitting these comments concerning the Proposed Rule by the Food and Drug Administration (FDA) for Federal Measures to Mitigate BSE Risks: Considerations for Further Action 69 Federal Register 134 (July 14, 2004) (Proposed Rule).

Dakota Resource Council (DRC) is a nonprofit, grassroots organization. Our members are working for a vibrant production agricultural economy thus preserving rural communities and family operated farms.

For the reasons set forth below, DRC strongly believes that the Proposed Rule to continue the ban of blood, blood meal, and chicken litter in ruminant feeds and all other animal feeds, as well as, the continued ban on downer cattle in the human food supply needs to be a permanent rule.

1) Tests have not confirmed that Bovine Spongiform Encephalopathy (BSE) is not transmitted via blood or blood meal. It is known that another form of Transmissible Spongiform Encephalopathy (TSE); Scrapies in sheep can be transmitted via blood. Blood meal is being used as a protein enhancer in milk replacements used to feed early-weaned calves, which further exacerbates the possibility of BSE transmission. The only way to destroy the BSE prion is the suspect material has to be heated to at least 1000? Celsius.

2) Cross-contamination of ruminant and non-ruminant feeds occurs. The feed standards for the USA need to include blood and blood meal as a prohibited ruminant by-product in poultry and hog feeds due to the possible cross-contamination of feeds either in the feed mills or on the farms.

3) Domestically, the USDA needs to strictly enforce the regulations for feed production. Feed mills should have to certify that no ruminant parts were used in the processing of the feeds. Requiring this strict enforcement will help to reassure our export markets that U.S. beef is safe.

4) Meat from downed (unable to stand) or diseased cattle must be withheld from the human food supply. The meat from downed and diseased cattle should never go into the human food supply. If this measure was in place when the December 2003 BSE cow of Canadian-origin that was slaughtered in Washington state, there would not have been a need to recall 10,000 pounds of meat and risk the health of the American public. An animal that breaks a leg at the packing plant could be used for human food upon a USDA certified veterinarian?s approval.

5) Meat from downed (unable to stand) or diseased cattle must not be rendered into feed and feed Supplements. Suspect animals, including blood meal, should not be rendered into feed or feed supplements for any ruminants, hogs, or chickens. As has been reported since the December 2003 case of Bovine Spongiform Encephalopathy (BSE) in Washington, chicken litter has been used in ruminant feeds. This has a potential for transmission of BSE to cattle.


Conclusion
The Dakota Resource Council believes that the banning of blood, blood meal, and chicken litter in ruminant feeds is necessary to protect the integrity and safety of the U.S. meat supply and protect animal health. Also, the banning of meat from downed or suspect animals is necessary to ensure public safety.

Sincerely,

Dakota Resource Council

Link Reinhiller

/s/ Robin Sherwood
Field Organizer Staff
Dakota Resource Council
PO BOX 1095
Dickinson, ND 58602
701-483-2851
robin@drcinfo.com

P.S. A hard copy of these comments has also been mailed to your office.