| Comment Record|
Ms. Tamiko Thomas ||
2003-02-05 10:21:50 |
The Humane Society of the United States |
| Comments for FDA General |
1. General Comments
February 4, 2003
Dockets Management Branch (HFA-305)
Food and Drug Administration
5630 Fishers Ln, Room 1061
Rockville, MD 20852
Docket No. 02N-0273, “Substances Prohibited from Use in Animal Food or Feed; Animal Proteins Prohibited in Ruminant Feed”
On behalf of The Humane Society of the United States (HSUS) I would like to take this opportunity to submit comments regarding the rule on “Substances Prohibited from Use in Animal Food or Feed; Animal Proteins Prohibited in Ruminant Feed”. We would like to commend the Food & Drug Administration (FDA) for its proactive and preventative measures to keep bovine spongiform encephalopathy (BSE) out of the United States. In light of the devastating impact the introduction and spread of BSE would have, we support changes in the BSE feed regulation that would exclude brain and spinal cord from rendered animal products and prohibit recycled poultry bedding from being fed to cattle.
As a short term measure it is important to exclude brain and spinal cord from rendered animal products. An animal infected with BSE will have high concentration of the BSE agent in these tissues and the World Health Organization has recommended that countries exclude these tissues from any animal or human food chain.1 As well, because the dose needed to infect cattle is very small it is thought cross-contamination of feeds has played a continuing role in transmission of the disease in European countries. This has led to a feed ban involving all major food animal species in some of these countries.2
In the longer term we believe that there should be a complete phasing out of the feeding of mammalian protein based feed to animals, as it is risky in terms of disease transmission. BSE belongs to a class of spongiform encephalopathies that are found in a number of other animals. One of the commonly held theories is that BSE originated when the agent that causes scrapie jumped the species barrier, through contaminated feed, to infect cattle.1 Furthermore, other diseases can result from high risk feed with animal proteins in it like foot and mouth.
The feeding of poultry manure is also risky –as well as unnatural and offensive- and should be prohibited. It is a practice that would meet with widespread public revulsion and little acceptance. Recycled poultry litter will undoubtedly contain spilt feed and the amount would be difficult to quantify. If this feed contains meat and bone meal (MBM) from ruminants it could lead to BSE infection if fed to ruminants. Furthermore, the WHO concluded that digestive contents and faecal material from livestock or poultry being fed with MBM (which maybe contaminated with BSE) should not be used as a feed ingredient. Experiments with mice that were infected with scrapie showed that a detectable amount of infectivity passes through the gut.2 Furthermore, there are other risks associated with feeding poultry manure because it contains pathogens, drugs and their metabolites, and minerals and heavy metals.3
MBM and poultry manure are primarily used because they are a cheap source of protein. While we do understand and sympathize in particular with small family farms that find themselves under increasing financial strain a price should not be put on the safety of our food supply. It is disturbing that in an attempt to maintain a competitive advantage over other producers, industry will feed manure and animal protein to animals despite the risks. If the FDA bans these practices it will put all farmers on equal footing.
In conclusion, there are too many uncontrollable variables to sanction the continuation of the practice of feeding animal materials to animals and poultry manure to ruminants. We hope that the FDA will continue its proactive and preventative work and make these changes. Thank you for your time and consideration.
Tamiko J. Thomas, M.Sc.
Animal Scientist-Program Manager
Farm Animals and Sustainable Agriculture
The Humane Society of the United States
2100 L Street, NW Washington, DC 20037, USA
Switchboard 1 202 452 1100
Direct 1 301 258 3114
Fax 1 301 258 3081
1. WHO, 2002. Understanding the BSE threat. http://www.who.int/en/
2. WHO/FAO/OIE, 2001. Joint Technical Consultation on BSE. http://www.who.int/en/
3. Rankins, D.L., Poore, M.H., Capucille, D.J. and Rogers, G.M. 2002. Recycled Poultry Bedding as Cattle Feed. Vet Food Anim 2002;18:253-266