2002N-0273 Animal Proteins Prohibited in Ruminant Feed
FDA Comment Number : EC35
Submitter : Mrs. Carla Yelkovan Date & Time: 11/01/2005 05:11:49
Organization : Mrs. Carla Yelkovan
Category : Individual Consumer
Issue Areas/Comments
GENERAL
GENERAL
I support the expanded ban on SRM in all feed (ruminant and non-ruminant) and would urge reconderation of the ban on blood products and food waste which was recently tabled as unnecessary.

I also think the ban on SRM should be expanded to banning use of materials from ruminants of all ages and all whole carcasses regardless of inspection. I find the visual inspection processes to be archaic in methodology, providing only a minimal level of consumer protection. As someone who worked in viral research at CDC's Special Pathogens Branch, I find it almost laughable that anyone could find the current inspection methods satisfactory to confirm the presence or absence of a prion pathogen.

I would further urge FDA to protect our food supply and the beef industry with proactive measures to increase inspection and testing levels (current levels would fail to detect significant levels of infection) and to modernize tracking of the supply chain so that infected animals, contacts and cohorts, and their byproducts could be quickly located upon detection of BSE.

We should be doing more, despite higher costs which the beef and feed industry balk at. The potential and arguably inevitable long term costs to the industry and American consumers are much higher.