Contact: Jeff Lyon, Director of Governmental Relations
608-828-5713
MADISON – More time is needed to consider a proposed federal rule’s unintended consequences to Wisconsin’s cattle industry, says the state’s largest farm organization.
Under the proposed rule, dead cattle 30 months of age or older must either be disposed of outside of the animal food chain, or the brain and spinal cord must be removed before rendering. Designed to prevent the spread of bovine spongiform encephalopathy (BSE), the rule will ultimately increase costs to rendering companies who will pass them on to farmers.
The Wisconsin Farm Bureau Federation has requested a 60 day delay in the effective date of a U.S. Food and Drug Administration rule entitled “Substances Prohibited from Use in Animal Food or Feed.” The WFBF’s letter notes that more time is needed to evaluate both the unintended consequences, and the true risk factor of BSE.
“It’s estimated that farmers will be charged between $100 and $150 per animal to have a rendering company pick up their animals,” reads the letter from Jeff Lyon, Farm Bureau’s director of governmental relations. “In addition, rendering companies will have the increased burden of trying to determine the exact of age of animals which is difficult to do.”
“With nearly 1.3 million milk cows in Wisconsin, we are concerned about the adverse effect the rule will have on the Wisconsin dairy industry and our rendering industry,” the letter continues. “With a 6 percent annual death loss (national average), there will be nearly 80,000 animals annually in Wisconsin that will need to be disposed of from our nearly 14,000 dairy farms.”
WFBF believes that rendering is the best way to dispose of dead animals, and that Wisconsin is fortunate to have a relatively strong rendering industry with a selection of vendors for farmers to choose from.
“The increased cost to farmers will cause many of them to not utilize rendering companies and dispose of their animals on the farm which has the potential to adversely effect the environment for the long term,” reads the letter. “In addition, if dairy farmers are not using rendering companies, the cost for the pickup of other livestock will also increase because of more distance between stops.”
Farm Bureau also contends the risk factors for BSE are over stated and need to be more fully evaluated before the rule takes effective.
Since BSE was discovered in the United States, nearly 900,000 tests have been conducted since June 1, 2004 (more than 100,000 in Wisconsin) to determine whether BSE is an issue in the United States. To date, only two animals have tested positive for BSE under the program and both cases were in animals born before the United States banned the practice of feeding recycled ruminant protein to other ruminants.
“It appears that FDA is trying to get to absolute zero, when in fact we are nearly there,” read the letter.
WFBF supports strengthening the ruminant feed ban in order to eliminate possible loopholes that might allow specified risk materials (SRM) to reach ruminants through misfeeding or cross-contamination. Better labeling, which is not part of the rule, would help farmers with compliance. Due to negligible chance of discovering BSE, WFBF believes that SRM could be included in pet food without a significant health risk.
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