2002N-0273 Animal Proteins Prohibited in Ruminant Feed
FDA Comment Number : EC36
Submitter : Mr. Michael Hippert Date & Time: 11/18/2005 02:11:49
Organization : Mr. Michael Hippert
Category : Animal Feed Industry
Issue Areas/Comments
My company(buyer) purchases byproducts from a company(seller) that uses only tallow of less than .15% insoluble impurities. The seller uses hyrdolysis on the tallow which also exempts the byproduct I buy according to the new regulation. However, the byproduct contains more than .15% insoluble impurities because it comes off of the distillation process and also the hydrolysis process which makes the byproduct more concentrated in insoluble impurities. My final product is a 99% fat product that is sold into the feed industry. When the labelling comes out, my products meets all criteria for the tallow, but yet I am over the .15% insoluble impurities. This will be a problem as a competitor can use this to their advantage to mislead consumers.