2002N-0273 Animal Proteins Prohibited in Ruminant Feed
FDA Comment Number : EC40
Submitter : Dr. Wade Northington Date & Time: 12/09/2005 02:12:50
Organization : Murray State University Breathitt Veterinary Cntr.
Category : Academia
Issue Areas/Comments
To Whom It May Concern:

I write in opposition to Docket No. 2002N-0273 FDA proposed rule change to prohibit the use of certain cattle origin materials in the food or feed of animals.

The proposed rule change will effectively eliminate the rendering stream as a method of bovine carcass disposal in the state of Kentucky. Kentucky has the largest cow herd east of the Mississippi River and ranks 8th nationally in beef production. The loss of rendering as a method of carcass disposal without an alternative method will severely affect the cattle industry.

The rendering stream is a vital carcass disposal method for livestock producers, slaughter establishments, and animal disease diagnostic laboratories. Should the rendering industry be lost as a method of carcass disposal, animal disease diagnostic laboratories will be limited in accepting animals for testing to the amount they are capable of internal disposal (incineration/digestion) thereby significantly limiting the mission and purpose of the laboratories in animal disease surveillance.

The proposed rule change is not needed for the following reasons:

1. The current USDA BSE Surveillance Program clearly shows no BSE risk to the US cattle and human populations.

2. The FDA has not conducted a survey of the impact on the loss of the rendering stream as a method of carcass disposal on the affected industries and commodity groups.

3. The FDA has not provided an alternative method for carcass disposal.