After denying a request for a 60-day delay, the U.S. Food and Drug Administration (FDA) in April announced its new rule on rendering practices for dead cattle would be effective April 27 and that all renderers must be in compliance with the rule by Oct. 26.

The final rule, entitled “Substances Prohibited from Use in Animal Food or Feed,” was designed to prevent the spread of bovine spongiform encephalopathy (BSE). It requires dead cattle 30 months old or more to either be disposed of outside the animal food chain or the brain and spinal cord must be removed before rendering.

Since the FDA’s announcement, members of the National Renderers Association (NRA) have been busy with preparations and determining what steps are necessary to be in compliance come fall.

“We were left a bit hanging by the late decision on the delay,” says David Meeker, Ph.D., MBA, who notes the denial came just days before the rule went into effect.

Meeker, senior vice president of scientific services for NRA, says the organization is currently talking with the FDA to figure out exactly what is required according to the wording of the rule.

Not only must rendering companies be ready to handle dead stock under the new requirements by Oct. 26, but all products on shelves and bins must also be in compliance on that date.

Foreseeing this rule, some NRA member companies are ready for the new provisions. However, the majority haven’t made changes yet, Meeker notes.

“Until now the entire cow could be ground up and used,” he says.

Now in order to comply there will be additional labor and added costs, plus the liability and potential costs of accepting the material.

Dissembling a bovine 30 months old or older is “easier said than done, depending on the weather,” Meeker says. In hot temperatures, the rate of carcass decomposition is accelerated, limiting the ability to remove the cattle materials prohibited from animal feed. Cold temperatures slow decomposition, but a frozen carcass is also difficult to separate.

Renderers recognize that picking up dead stock from farms in a timely manner will help combat the temperatures; however, in extreme heat and cold it still may not be feasible to work with the carcasses.

No matter what climate the rendering plants are operating in, they will most likely need to install special processing equipment and conduct additional training.

No plant has a separate cooker for these products, Meeker states. Therefore, the plants will have to contract with a landfill to dispose of the newly banned products. One of the main arguments to delay the rule was the reluctance of landfills to accept these materials.

According to a release by the National Milk Producers Federation, “The EPA and FDA announced that dead stock and specified risk material from rendered animals could be disposed of in landfills. However, the patchwork of local and state regulations still limit disposal opportunities for many dairy producers.”

Other alternatives renderers can use for disposal include the purchase of an alkaline digester or to apply for an industrial composting permit. Industrial permits are much harder to obtain than farm composting permits, Meeker explains.

If renderers are unable to find an alternative disposal location, they will not be able to pick up the banned materials to begin with, placing the disposal burden on producers.

Meeker reports that 70 percent of NRA members intend to do what is needed to comply with the new rule. The others will either shut down or deny rendering services for cattle.

For the rendering industry, dead stock only amounts to 5 percent of the materials it processes. Most of their materials are slaughter trimmings and byproducts, Meeker explains.

The plants that depend heavily on dead stock are most likely to make the necessary changes and stay in business, he says. They are typically located in areas where dairies and feedlots are prominent.

Most NRA members have started conversations with their clients, including small slaughter plants and livestock producers, on how these changes will affect them.

The smaller slaughter plants will need to place the brain and spinal tissue in separate containers and send in affidavits to verify the practices they used.

Dairymen and cattle ranchers may also need to fill out affidavits and be able to provide production records or other documentation of age upon pickup of cattle.

Many dairy producers can expect this new rule to result in an added cost to dead stock removal.

“We aren’t happy to raise our costs,” Meeker says, “but the alternatives aren’t cheap either.” Securing a backhoe for burial or composting dead stock can be equally costly and possibly not an option in some parts of the country.

Meeker advises dairy producers currently utilizing a rendering service to talk with that company to see what its intentions are in complying with the new rule. They should find out if their service will continue and under what conditions.

With just a few months remaining before the compliance date, the rendering industry is focused on making necessary changes. However, they would eventually like to do something about the country’s disposal system and may need help from dairy producers in that political movement.

In the long run, NRA would like to work with the FDA and the EPA to create a separate processing facility for non-feed products. PD

Progressive Dairyman
Editor
Karen Lee

Funds available in Kentucky for dead animal removal
The Kentucky Agricultural Development Board announced the availability of an assistance program to help counties implement a plan for the removal of deceased farm animals within the county.

Utilizing County Agricultural Development Funds, Kentucky counties may now apply for the Deceased Farm Animal Disposal Assistance Program. This program will serve as an interim measure to facilitate the coordination of environmentally sound and cost-effective disposal of deceased livestock for Kentucky’s producers. This program will cover expenditures incurred between July 1, 2009, and June 30, 2010, related to an acceptable disposal program.

“This program represents a necessary stop-gap measure to give counties time to develop longer-term plans in dealing with the disposal of dead animals,” said Roger Thomas, executive director of the Governor’s Office of Agricultural Policy. “We will continue to work with state, local and federal officials to find a reasonable long-term solution to address this issue.”

This program has been developed in partnership with the Kentucky Division of Conservation (KDOC), as well as local and state stakeholders. KDOC is also offering a cost-share program to assist counties with related expenditures by utilizing a portion of their Environmental Stewardship Fund, which receives an annual appropriation from the Agricultural Development Fund.

—Excerpts from the Kentucky Agriculture Report