2002N-0273 Animal Proteins Prohibited in Ruminant Feed
FDA Comment Number : EC163
Submitter : Ms. Gloria Eddie Date & Time: 12/09/2005 03:12:16
Organization : Member, Farm Sanctuary
Category : Individual Consumer
Issue Areas/Comments
As you know, in early 2004, following the discovery of mad cow disease in a Washington state downed dairy cow, the US Department of Agriculture (USDA) took emergency action to ban the slaughter of non-ambulatory cattle for human consumption. This ban remains in effect, although it has not yet been finalized.

In July 2004 the Food and Drug Administration (FDA) followed the lead of the USDA and prohibited the use of all materials from downed cattle in FDA-regulated human food, including dietary supplements and cosmetics. Also in July 2004, the FDA announced its tentative conclusion to ban all materials from downed cattle in animal feed.

But now, I understand, the FDA has reversed its earlier position on non-ambulatory animals. The agency recently announced that it plans to allow the carcasses of downed and dead animals to be rendered for animal feed as long as the brain and spinal cord have been removed. This would permit downed cattle to be killed for use in feed for birds (chickens & turkeys), pigs and companion animals. (Materials from downed cattle have been prohibited in feed for ruminants -- cattle, sheep and goats -- since 1997.)

Allowing sick, non-ambulatory cattle to be killed for animal feed will result in unnecessary pain and suffering. Downed animals should be humanely euthanized immediately, not kept alive and/or transported to be killed for rendering.