2002N-0273 Animal Proteins Prohibited in Ruminant Feed
FDA Comment Number : EC44
Submitter : Mr. Dean Northcutt Date & Time: 12/09/2005 02:12:53
Organization : University of Tennessee Extension
Category : State Government
Issue Areas/Comments
The proposed change to this rule would strike a serious public health problem to Coffee County which worked hard to acquire a dead animal removal service about 12 years ago. This county, in an average year, has 600-900 dead bovine that need to be removed. Before this service was established low income farmers left dead animals on the land to rot or dragged them to public dumpster sites where they started rotting at public facilities. Ground water contamination was a problem because of products of decay going into the Duck River, the water source for Manchester, Tullahoma and other towns down river. UT Extension, local veterinarians, the county health department and interested citizens worked to obtain a sanitary removal service for the public health benefit.

The current ruminant feed ban has been effective since 1997 and this ban has been in effect longer than most living bovine in our county. Give this rule a couple more years and it will have survived all the cattle in our county. Our farmers are subject to the current USDA Surveillance Programs that have shown that we DO NOT have a BSE risk in the United States cattle population.

Before the FDA makes a decision like this, scientific research should be the basis of the rule, not political or international trade related issues. Show us the research that points out the need and we would not object. Do you realilze the cost to the farming community in just one county if rendering services should stop? If we averaged only 750 animals a year with a burial cost of $150 each animal, the cost would be $112,500. What if 5% of those 750 animals, or 37 of them were allowed to rot away and run into our goundwater and public water supply each year? What would that cost in human illness and death be? This is the problem we just solved a few short years ago and with this rule, all those public health issues we corrected will be for naught.

Should FDA decree that this is to be the rule, who will enforce the rule to see that rendering plants remove the brains and spinal cords, who will be responsible for the disposal of animals without brains and spinal cords removed, etc., etc. Enforcement of this rule as proposed could not be accomplished.

Speaking in behalf of the farming community in Coffee County, Tennessee, please don't do this. This proposed rule change has no merrit based on science or common sense.