2002N-0273 Animal Proteins Prohibited in Ruminant Feed
FDA Comment Number : EC123
Submitter : Dr. Patrick Cosgrove Date & Time: 12/09/2005 02:12:36
Organization : Dr. Patrick Cosgrove
Category : Health Professional
Issue Areas/Comments
GENERAL
GENERAL
I strongly oppose the use of non-ambulatory (downed) cattle in animal feed. Allowing sick, non-ambulatory cattle to be killed for animal feed will result in unnecessary pain and suffering for these animals. Downed animals should be humanely euthanized immediately, not kept alive and/or transported to be killed for rendering.

As you likely know, in some cases, downed animals die of neglect. If they are still alive to meet the slaughterhouse truck, they are typically moved by the easiest, but least humane ways, which can include being dragged with chains and being pushed with tractors or forklifts. These practices cause injuries ranging from bruises and abrasions to torn ligaments, broken bones, and dislocated joints.