By TIM THORNBERRY
Kentucky Correspondent

FRANKFORT, Ky. — Disposing of dead livestock is not the easiest thing to do when it comes to day-to-day operations on the farm but it is one of those necessities that has been placed in the media spotlight of late due to an Food and Drug Administration (FDA) proposal that will change the rules of rendering.

The proposal published in the Federal Register, will impose regulations mandating the removal of “Specific Risk Materials,” notably the brain and spinal cord, from cattle 30 months and older before rendering. The new regulations will go into effect by the middle of this month if pleas from ag officials here and in other states go unanswered.

The regulation change is an effort by the FDA to strengthen the 1997 Ruminant to Ruminant Feed Ban and reduce the BSE (Mad Cow Disease) risk by requiring rendering facilities to remove those “at risk” materials.

According to information from the Kentucky Farm Bureau (KFB), “The thought is that even though the proteins resulting from rendering are being used in nonruminant feeds (including poultry, hog and pet food production) there is a possibility for cross contamination in ruminant feeds because many feed manufacturers produce both types of feeds. Under this rule, certain tissues considered at a high risk for carrying the BSE agent will be banned from all animal feed, including pet food. Current feed rules, which have been in place since 1997, prohibit the inclusion of these high-risk mammalian proteins in ruminant feed only.”

Joe Cain, KFB national affairs director said the issue is here and this proposal will change the way rendering is done.

“What cattle producers will have to do is meet the new guidelines and utilize alternative disposal methods if current services from rendering companies are discontinued,” he said.

The profit margin for these services is slim at best and with the new regulations that margin could get even smaller or disappear altogether. If that is the case, companies that provide the service may stop, prompting visions of possible improper disposal of these animals.

 KFB is working with the state veterinarian’s in the event some of those pickup services stop, to inform farmers of the guidelines in place to dispose of dead stock. Cain said that in the face of this dilemma many farmers are seeing it as a business opportunity.
“We are starting to see folks looking at this as an opportunity to develop a business. I’ve had inquiries from farmers wondering if they could open a composting facility and pick up from surrounding counties and charge a fee for it. The entrepreneurial spirit is starting to show up,“ he said.

In the meantime, Cain said the main thing is to make sure proper disposal methods are followed. In most states, there are four generally accepted ways of animal disposal including burying, burning, composting and rendering.

“The key thing we’re working on is to make sure folks dispose of dead stock in an appropriate manner; one that’s approved and one that’s legal,” he said. “Livestock that is improperly disposed of could be not only a human hazard but a health hazard for other livestock and wildlife.”

Bill Clary, spokesman for the Kentucky Department of Agriculture said that the agency is one of many asking the FDA to withhold implementation of the revised regulations until more information can be gathered in regards to the effect the regulations will have on the farm and in the rendering industry.

“Agricultural departments from around the nation have asked the FDA for a moratorium until such time the government can study the implications to the rendering industry and what it’s going to mean to the livestock industry but I don’t know how seriously the FDA is taking that request,” he said.

“The biggest fear is that there will not be a reasonably priced and safe alternative for producers to dispose of carcasses. The sheer number of animal bodies that need to be disposed of within the course of a year means that there has to be some sort of system in place to deal with this problem.”

Information from KFB reports: “Kentucky has approximately 20 million pounds of dead stock picked up and rendered annually. Nationally, the current EPA estimate of rendered dead stock that would require some other sort of disposal is between 475-700 million pounds.”

Clary noted that in the event local renders discontinue their services, landfills aren’t really equipped to handle the problem and for many farmers, it’s not practical to bury the animals on their land.

“I just think we’re rushing into something that really needs more thought,” he said. “We don’t have a Plan B.”

Even though the rule has not become a mandate as of yet, the proposal has already had an effect on the industry.

According to the National Cattlemen’s Beef Assoc. (NCBA), “many renderers across the country have simply terminated their service to the livestock industry as a direct result of this rule. Beginning as early as December 2008, many renderers discontinued picking up dead livestock because of the severe economic realities of this proposal.”

The agency also reported that at least 18 senators have sent a letter to the FDA asking for a 60-day delay and that the comment period be reopened.