The cost of calling your local renderer is likely to go up in the very near future.
The reason: FDA's "enhanced feed ban regulation,” which prohibits the use of brain or spinal cords from dead stock greater than 30 months of age for use in animal feed. The regulation's effective date is April 27, 2009. But since no feed from these animals can be in the pipeline on April 27th, renderers could start taking action as early as January.
All of this is being driven by the fear of bovine spongiform encephalopathy (BSE) recirculating into the feed supply. The Harvard Risk Assessment found that "specific risk material” such as cattle brains and spinal cords, if left in the feed chain, could cause new infections to occur.
The "enhanced feed ban regulation” has been on the docket for years. Some 840 comments, many pointing out the proposal pitfalls, were submitted to FDA while the rule was being considered.
Lack of progress on the proposal became an issue as the Bush Administration negotiated with the South Koreas over the recent trade agreement. As you know, South Korea street protests over U.S. beef—and possible BSE contamination--reached hysterical levels. The National Cattlemen's Beef Association was opposed to the feed ban regulation because of its high cost/low benefit ratio. But a source within NCBA says the South Korean free trade agreement took precedence, with the feed ban regulation a pivotal concession.
Renderers estimate that removing the brain and spinal cord from a cow will cost in excess of $200. Why so much? FDA prohibits mechanical separation of the prohibited material out of fear the process will either be incomplete or contaminate surrounding material. So the separation of brains and spinal cords must be done manually—driving up costs.
Renderers know few dairy producers will pay the full $200-plus cost, though some may soon start charging you up to $100 for the privilege of having the animal rendered. In addition, you will have to age verify all of your deadstock and maintain those records for up to a year.
(The U.S. Food and Drug Administration has inspection and verification authority. Penalties for failure to comply with the rules carry fines and imprisonment of up to five years.)
Plus, renderers might ask you to start marking each carcass with an orange paint stick. A large "U” on the animal's side is indication the animal is under 30 months of age. A large "X” indicates that animal is 30 months of age or older.
FDA acknowledges its new rule will drive up costs and fill up landfills. FDA estimates total compliance costs of $64 million to $80 million annually. Producer costs could range from $28 million to $39 million.
The agency also estimates a 26 to 42% drop in the number of cattle sent for rendering. And it estimates from 185,000 to nearly 290,000 tons of additional animal carcasses and parts will be landfilled each year.
Plus it acknowledges potential environmental threats: contamination of surface and ground water, odors and the release of pathogens to the environment from decaying carcasses. It's not a pretty picture.
In its comments to FDA on the final rule, the National Milk Producers Federation (NMPF) requested that FDA work with USDA to come up national deadstock guidelines. "FDA punted, and said disposal of carcasses is not under its jurisdiction,” says Jamie Jonker, NMPF's director of regulatory affairs.
If you can't have your deads rendered, composting carcasses is probably your best alternative. Click here for a compost guide from the Minnesota Department of Agriculture. Other alternatives for deadstock disposal are landfill (good luck), burial (a bit of a problem in areas with high water tables or frozen ground six months of the year) or incineration (carbon emissions?).
Good luck, and Happy New Year.
--Jim Dickrell is editor of Dairy Today. You can reach him via e-mail at email@example.com.
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