2002N-0273 Animal Proteins Prohibited in Ruminant Feed
FDA Comment Number : EC216
Submitter : Dr. Sam Holland Date & Time: 12/22/2005 03:12:28
Organization : South Dakota Animal Industry Board
Category : State Government
Issue Areas/Comments
RE: Docket No. 2002N-0273

Sirs: We would like to very briefly comment on the proposed rule referenced: While we feel very strongly that risks BSE must be addressed and commend federal and state regulatory agencies for their efforts, we do not support the changes proposed in this rule. Evidence from the Harvard study as well as the major BSE surveillance program in the US have demonstrated that the programs in place effectively prevent introduction of BSE and also prevent amplification should any importation occur. With this evidence now proven by the major surveillance, it appears the costs of the proposed rule, particularly in terms of potential for reducing effective and safe carcass handling outweigh any anticipated benefit from the minor portion of the risk that this rule would address. It seems it would be better to focus our efforts in this country on supporting research and efforts by the rendering industry to continue to develop alternative uses for the product and ensure continued good carcass handling by all industry. Thank you for the opportunity to comment.
Sam D Holland, DVM,
State Veterinarian, Exe. Secy.
South Dakota Animal Industry Board
411 South Fort St
Pierre, SD 57501