2003N-0312 - Animal Feed Safety System: Risk Based Safety Program
FDA Comment Number : EC12
Submitter : Mr. Gary McKinley Date & Time: 09/24/2004 02:09:07
Organization : Wood Co. Industrial Commission
Local Government
Category :
Issue Areas/Comments
GENERAL
GENERAL
Technology is available from INEEL/DOE (Bechtel) through a CRADA agreement with EnviroQuest Research Consultancy (Phone 832-526- 4364), Houston, Texas which converts high fatty polymers (animal renderings) to biodiesel. Coupled with innovative engine technology by Wartsila Corporation, this technology can be used to process biomass into clean burning fuel for production of electricity. The licensing for such biomass processing (biodiesel production) and co-generation is available now. This leading edge technology allows the disposal of beef, poultry and pork waste streams into a sustainable production process that would allow even the most extreme animal feed restrictions to be manageable with cost compensation from the reduced cost of land-fill disposal and the revenues from electricity production of co-generation at these facilities. In addition to reducing animal feed chain risk, this approach would save the beef, pork, and poultry industry billions of dollars in environmental disposal costs, reduced risk to the food chain and immediate increase in availability of clean produced energy from biodiesel. Furthermore, licensing of this technology - available NOW - would provide investment revenue for expansion of EnviroQuest's commitment to creating sustainable economic development for rural communities by the production of oil-grain feedstock biodiesel. While developing rural economies, their approach will have direct benefit for enabling fleets, communities and the oil industry to meet Clean Air Act standards, it will also reduce dependence on foreign oil. Most importantly, the farmer becomes a key part of the energy production for the US - sustainable agriculture and economic development for rural areas.

Recommendation: Animal Feed Regulations should include legislated tax incentives to encourage the beef, poultry and pork industries to move immediately to acquire licensing for biodiesel technology to convert renderings into burnable biodiesel to offset the estimated cost from disposal of a projected 183 million pounds of unsuitable renderings (conservative approach for animal feed safety) to even the most radical rendering control measures that may be necessary to protect the food chain. Biomass conversion and co-generation facilities can be in construction in 2005 and in full operation by 2006 to meet animal feed safety regulation requirements without increased cost to meat producers and, in fact, with environmental benefits and revenue streams to support the producers that are willing to purchase these licenses. All of the economic, energy and safety objectives of the Administration are met with this approach.

Please contact me or EnviroQuest Research for more discussion or information.

G. M. McKinley, Captain (USN, Ret.)
Executive Director
Wood Co. Industrial Commission
Quitman, Texas
903-763-4831
Email: woodcic@peoplescom.net