Docket Management
Docket: 02N-0273 - Substances Prohibited From Use in Animal Food or Feed; Animal Proteins Prohibited in Ruminant Feed
Comment Number: EC -8

Accepted - Volume 1

Comment Record
Commentor Dr. Hubert Karreman Date/Time 2002-12-28 22:18:00
Organization Penn Dutch Cow Care
Category Health Professional

Comments for FDA General
1. General Comments Thank you for the opportunity to place my comment on the issue of feeding ruminant protein products to ruminants, either via rendering or poultry litter. While in veterinary school (1991-1995) I was astonished to learn that herbivorous creatures such as ruminants were routinely being fed various mammalian tissues, in order to get a cheap source of protein into the animal. It is counter-intuitive to feed meat to obligate herbivores. I do not agree with the notion that a protein is a protein, no matter the source. I think it not unreasonable to believe that an herbivore's digestive enzymes operate optimally -based upon their genetic blueprint - upon plant based feeds. The *only* time in a cow's life that a carnivorous behavior occurs is at calving when the dam will eat the placenta (as an instinctive behavior to leave no trace of calving for predators to detect). Otherwise, their four compartment stomach system is specifically designed to digest and utilize fibrous, plant materials. That is basic biology. With the possible link of BSE and human CJD, I would think it incumbent upon the governmental public health service to protect the population in the best possible ways. I applaud the regulations that have so far been in place for the last few years that ban using nervous tissue to be fed back to ruminants. As a dairy practitioner, I find is distressing, however, to still see that other mammalian derivatives are still allowed as part of the bovine diet. If I'm not mistaken, ruminant derived blood meal and meat and bone meal are still allowed to be in the diets of bovines. I find this odd, especially since the mode of transmission of BSE has not been *clearly* elucidated. Are scientists certain, beyond a shadow of a doubt, that prions *are not* present at any time in the blood stream? How do prions make their way to the brain (and do their damage) if not via ingestion, digestion, coursing through the bloodstream, possibly entering striated muscle and bone as well? While some in the rendering industry will argue that there has been no BSE detected in the U.S. since the present ban was put into effect, that is not reason enough to keep things the way they are. If there was ever one confirmed case of BSE in the U.S., it will devastate the entire cattle industry. The rendering business is not a pretty business and I respect the workers who toil in such a work atmosphere. I've been at a rendering plant occasionally (to do a necropsy) and there is just too much possibilty of commingling banned tissue from allowed tissue. There simply can be no mistakes when it comes to BSE. There can be not enough safe guards, in my opinion. To repeat: feeding herbivores any kind of carnivorous substance is in direct violation of the biology of herbivourous creatures - and it is a time bomb ticking away. I cannot urge you strongly enough to allow only *plant* derived proteins to be allowed in ruminant diets. Wouldn't this also help our crop farmers economically due to increased demand for plant proteins? Perhaps technology can render the cattle parts into field fertilizer and feed for other carnivores to a greater extent than already being done. In direct contrast to the conventional framework of feeding of animal proteins to ruminants, the new USDA National Organic Program regulations have it right - no animal proteins are to be fed to ruminants. It is that simple. At least one population of animals (certified organic ruminants) will not be indicted as guilty if BSE does rear its ugly head here in the U.S. Please, please, please do not allow *any* animal proteins to be fed to ruminants. There is too much at stake.

EC -8