2002N-0273 Animal Proteins Prohibited in Ruminant Feed
FDA Comment Number : EC42
Submitter : Mr. Thomas Johnson Date & Time: 12/09/2005 02:12:16
Organization : Mr. Thomas Johnson
Category : Individual Consumer
Issue Areas/Comments
Thank you for the opportunity to comment on the proposed rule. While I understand the need to be proactive in combating the spread of disease, I believe the proposed rule is more of a reaction to special interest group pressure. Implementation of the proposed rule regarding SRM removal would serve only to create a perception of increased protection for some, while accomplishing nothing from a scientific standpoint. What the proposed rule would create is a very real threat to human and animal health that does not exist today. The incidences of improper disposal of dead and downer cattle and the disposal of the proposed prohibited materials in landfills would establish a means for disease transmission that would be unparalleled. Predatory animals such as coyotes, fox and wild dogs as well as nuisance animals such as rats and mice would have unprecedented access to these materials and would likely strew them throughout the surrounding area. With the increased availability of these materials to those animals, their population would likely increase further compounding the problem. Disease within this animal population would rise and therefore increase the incidence and potential for the spread of disease from these animals to other farmed and domestic animals in the area, providing additional exposure to humans. Contamination of ground and surface waters would also be an issue under the proposed rule. If livestock producers did elect to dispose of farm mortalities or downers via burial, it is unclear what the long-term environmental consequences would be. I believe it is safe to assume that with the volume of animals that would require alternative disposal there would be a significant long-term environmental hazard created by burial of these animals. What will our grandchildren and great-grandchildren experience when they attempt to build a home in a rural location, with a beautiful view of the surrounding area and uncover farm mortalities buried years earlier as they attempt to dig footings for their home or put down a well to supply their home with water? The current feed rule is scientifically proven by the Harvard Study to be 99.8% effective, even assuming less than complete compliance with the feed ban. To implement a rule of this magnitude that in reality would only provide an additional 0.2% reduction in risk would be scientifically unwarranted and ethically, ecologically and environmentally irresponsible. USDA has tested over 600,000 "high risk" animals from the dead and downer portion of the cattle population and found only one presumed positive in a Texas cow that was born prior to implementation of the 1997 feed rule. Our government should not contemplate measures that would do more harm than good in a country where BSE has been proven to be essentially non-existent. I would encourage FDA to reconsider it's approach to solving a problem that is more perceived than it is real. No further revision to the current feed rule is necessary nor warranted. Thank you for the opportunity to submit these comments.