2002N-0273 Animal Proteins Prohibited in Ruminant Feed
FDA Comment Number : EC43
Submitter : Mr. Tim Herndon Date & Time: 12/09/2005 02:12:29
Organization : F.B. Purnell Sausage Company
Category : Food Industry
Issue Areas/Comments
GENERAL
GENERAL
There are several reasons this rule should not be implemented:
1. No need for additional feed restrictions based on current compliance.
2. The current ruminant to ruminant feed ban created in 1997 has been in force longer than most living animals and within 2 years will have survived all living cattle.
3. The current USDA Surveillance Program clearly shows we do not have a BSE risk to the US cattle population and support the data of the Harvard Risk Analysis Study.
4. The FDA must maintain its regulatory decisions based on science, not political or international trade influence.
5. The FDA must conduct an environmental assessment of the animal disposal issue created by this proposed regulation and the associated animal and human health concerns created by improper disposal and the increase cost associated by such action.
6. With such action proposed by a federal agency with no enforcement ability, how will the FDA fund the state agencies who must deal with animal disposal and increased humal health problems associated with animal disposal.
Thanks for you Time.