Docket Management
Docket: 01N-0423 - Substances Prohibited from Use in Animal Food or Feed; Animal Proteins Prohibited in Ruminant Feed.
Comment Number: EC -17

Accepted - Volume 4

Comment Record
Commentor Dr. Bruce Arentson Date/Time 2001-11-21 14:33:50
Organization Kent Feeds, Inc
Category Company

Comments for FDA General
1. General Comments November 13, 2001 Dockets Management Branch (HFA-305) Food and Drug Administration 5630 Fishers Lane Rm 1061 Rockville, MD 20852 Docket No. 01N-0423 To Whom It May Concern: I am writing to express Kent Feeds, Inc’s views regarding the Food and Drug Administration’s current animal feeding regulations that are design to prevent the introduction of bovine spongiform encephalopathy (BSE) into the United States. Kent Feeds, Inc is a animal feed manufacturer headquartered in Muscatine, IA, and has 12 plants located in the Midwest. We market animal feed products through local “feed” dealerships located in 13 Midwestern states. Our products include feeds or foods for swine, beef, dairy, horses, poultry, sheep, goats, and pets. Our company supports the statements submitted by American Feed Industry Association and the National Grain and Feed Association at the FDA public hearing held in Kansas City, MO on October, 30, 2001. At Kent Feeds, we feel we have a strong responsibility to do out part in ensuring America’s food supply is safe. From the initial release of the regulations, we have meticulously complied. Furthermore, we feel we have a responsibility in helping our dealers comply with the regulations. We educate them on the BSE rules at meetings and have provided them a manual with the BSE regulations and suggestions on how they needed to comply. To help our dealers more easily comply with the BSE regulations and reduce the risk of contaminating ruminant products with ruminant meat and bone meal, Kent Feeds uses only porcine meat and bone meal in the manufacture of animal feeds. More recently, Kent Feeds provided Kent dealers a copy of the new FDA BSE Inspection Checklist form. This was sent as a reminder to dealers that compliance of the BSE regulations continues to be a priority and dealers should have documentation on how broken bags of pet foods are handled. Kent Feeds is committed to complying with the present BSE animal feed regulations and assisting our dealer organization in complying. We support the goal of 100% compliance and in order to obtain this, the FDA and states will have to continue their education and inspection efforts. From our vantage point, the intentions of the original BSE animal feed regulations are being accomplished without severe hardship on the animal agriculture industry. Any modifications to the present BSE animal feed regulations should be science-based. Additional regulations without just cause could severely hamper animal agricultural industry in the US. Thank you for allowing us to provide comments for your consideration.

EC -17