Arlington, VA -- The FDA’s preliminary decision to ban Specified Risk Materials (SRM) from all animal feed is "unwarranted" and other prevention measures being considered by the government agency "may not be scientifically or economically justified," says the American Meat Institute Foundation president James Hodges, in a letter submitted to the FDA today. The letter addresses the FDA’s Advance Notice of Proposed Rulemaking (ANPR), which contains numerous proposals to change BSE firewall strategies, which AMI says, will be exorbitantly costly while failing to provide any significant increase in BSE prevention for cattle. AMI recommended that FDA go back to the drawing board and conduct a comprehensive cost/benefit analysis that can be used in conjunction with a risk/benefit analysis to determine the best public policy.
prevention strategies must be both
scientifically based and economically prudent,"
said Hodges. "And in the case of this recent
ANPR, the proposed rule change to ban specified
risk materials (SRM) in animal feed fail both
criteria," he said. Hodges noted that while the
wholesale removal of SRM from feed would incur
immediate and dramatic costs to those who
slaughter and process cattle in the United
States, there are no data to show any
significant benefits from the removal.
"Producers and processors will be forced to
shoulder enormous economic hardships while the
government has no real evidence that the steps
its proposing will have any net benefit to
anyone," says Hodges.
The letter urges
FDA to re -evaluate the recommendations made by
the International Review Team (IRT) before
changing any BSE prevention strategies. The
IRT called for SRM removal and a complete ban
on feeding meat and bone meal to ruminants, but
Hodges noted that the IRT recommendations were
based on what happened in Europe and not the
current circumstances that exist in the United
States. "Fears of the disease greatly exceed
the actual risk. Promulgating science-based
regulations in an emotional environment can be
challenging, but we urge FDA to rely on the
empirical data and technical facts," he
Recent FDA data show a 99 percent
compliance rate with the existing feed ban.
"The FDA’s reports show that our strategies
for preventing the spread of BSE through feed
are working and compliance is extraordinary,"
"So the FDA really needs to do
more homework before making any suggestions
that will have such huge, industry-wide
ramifications as this one does," said
Hodges urged the FDA to
evaluate other alternatives instead of
requiring the complete removal of SRM from
feed, noting that a thorough analysis could
reveal a combination of alternative, preventive
measures that will strengthen animal health
protection and minimize the cost burden imposed
on the industry.
Hodges noted that the
removal of SRM "will cause real and significant
economic dislocations throughout the livestock
industry," requiring costly redesigns of both
facilities and processes, increasing disposal
costs and reducing the overall value of
livestock. The disposal of SRM will also cause
"significant environmental concerns that are
unresolved," the letter notes. "Not only will
the livestock industry lose revenues from the
loss of more than one billion pounds of SRM
which were formerly recycled into feed, but
will also have to incur the cost of disposing
of the material, which poses real environmental
challenges," says Hodges.
To view the
letter in its entirety, go to http://www.meatinstitute.org/Content/FoodSafety_Inspection/AnimalHealth_Biotech/FDA%20comments%208.13.04.pdf.
FDA Decision on Banning SRM from Feed "Unwarranted"Friday, August 13, 2004
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