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Disposing of Dead Cattle 30
Months and Older
May 4, 2009 Update
The Food and Drug Administration
(FDA) issued final guidance for
renderers regarding the enhanced
feed ban rule on April 30,
2009. The compliance date for
the new rule is
October 26, 2009. A copy
of the document is posted at:
http://www.fda.gov/cvm/Guidance/guide195.pdf.
Since the announcement of the
enhanced feed ban last year,
there have been concerns about
alternative disposal of cattle
materials prohibited from animal
feed (CMPAF) and dead stock that
will no longer be rendered.
Some landfills stated that CMPAF
would be classified as hazardous
waste and thus be very expensive
to dispose. The Environmental
Protection Agency (EPA) has
clarified that CMPAF is solid
waste and therefore allowable in
landfills. The EPA
classification is posted on
their website:
http://www.epa.gov/epawaste/nonhaz/municipal/landfill/cattle.htm.
The guidance document is
intended to help small firms
comply with the enhanced feed
ban which took effect April 27.
The guidance may also help
processers and farms who use
renderers for disposal
services.
This rule directly impacts
renderers and indirectly beef
cow and dairy operations because
it dictates that before cattle
over 30 months of age can be
rendered, the prohibited
materials (brains and spinal
cords) must be removed. The EPA
statement clearly states that
animal mortalities and wastes
generated from the slaughter of
animals, including CMPAF, would
not be a hazardous waste, but a
solid waste which should help to
mitigate some of the earlier
expected costs.
Still, renderers must decide
whether to:
a)
Discontinue handling cattle over
the age of 30 months, unless the
producer first removes the brain
and spinal cord; or
b)
Devise a plan and procedures for
handling cattle over the age of
30 months which includes:
·
Documenting these cattle through
a producer signed certificate
stating the age of the animal.
·
Identification of cattle over 30
months of age and handling them
separate from dead cattle under
30 months of age.
·
The development of a facility
for the removal of brains and
spinal cords (and a plan for
their disposal).
Clearly, for those renderers
choosing (b), they will be faced
with additional handling and
transportation costs which will
be passed to the cattle
producer.
In summary, Farm Bureau policy
supports strengthening the
ruminant feed ban in order to
eliminate possible loopholes
that might allow Specified Risk
Materials (SRMs) to reach
ruminants through misfeeding or
cross-contamination. However,
as an organization, we have
concerns about the practicality
of enforcement of some parts of
the rule, specifically the
removal of SRMs from deadstock.
AFBF along with several other
livestock industry groups will
continue to work to create
regulatory solutions that will
allow renderers to more
effectively handle cattle over
30 months of age and therefore
continue on-farm pickup of these
older cattle.
Members are encouraged to check
with their renderer to ascertain
their policies and fees for
handling cattle over the age of
30 months prior to the event of
an animal dying.
Background
Despite the best efforts of livestock producers, some animals
die and the safe disposal of
these dead farm animals is often
a challenge. According to
Kansas law, there are four
approved methods for disposing
of dead farm animals;
burial, incineration, rendering
or composting.
K.S.A.
47-1219 - Unlawful disposal;
penalty.
a.
Any person or persons who shall
put any dead animals, carcasses
of such animals or domestic
fowl, or any part thereof, into
any well, spring, brook, branch,
river, creek, pond, road,
street, alley, lane, lot, field,
meadow or common shall be deemed
guilty of a misdemeanor, and
upon conviction thereof shall be
fined in a sum not exceeding
$100.
b.
Any owner or owners of any dead
animals, carcasses of such
animals or domestic fowl, or any
part thereof, who shall
knowingly permit the same to
remain in any well, spring,
brook, branch, river, creek,
pond, road, street, alley, lane,
lot, field, meadow or common to
the injury of the health or to
the annoyance of or damage to
the citizens of the state or any
of them, shall be deemed guilty
of a misdemeanor, and upon
conviction thereof shall be
fined in a sum not exceeding
$100. Every 24 hours the owners
shall permit the same to remain
thereafter shall be deemed an
additional offense.
c.
Persons disposing of dead
animals shall do so in one of
the following ways:
1.
Burial (animals should be buried
a minimum of three feet
underground);
2.
Incineration;
3.
Delivery or unloading of the
carcasses of dead animals or
packing house refuse at a
disposal plant, substation,
rendering plant or place of
transfer licensed by the
commissioner; or
4.
Composting.
Rendering Issues and Feed Ban
Rules
Historically, rendering has been
the disposal method of choice
for most Kansas livestock
producers because the other
on-farm disposal methods such as
burial, incineration and
composting, while possible,
require varying levels of land,
labor, capital and expertise.
Rendering required only a phone
call, with on-farm or roadside
pickup being the norm.
Over time this situation has
changed. With fewer renderers
in business, deceased animals
must often be hauled further
distances and with higher fuel
prices, most renderers have
begun to limit or charge for
on-farm pickup, or if they were
already charging, have raised
fees. In addition, concerns and
regulations (feed ban rule)
surrounding
transmissible spongiform
encephalopathies (TSE’s),
such as Scrapie in sheep and
goats, and bovine
spongiform encephalopathy (BSE)
in cattle, have led some
renderers to stop accepting
certain species or animals. For
example, in 1989 renderers
stopped accepting sheep greater
than one year of age due to
Scrapie concerns and regulations
prohibiting their use as a
protein in feed rations.
On April 25, 2008, the Food and
Drug Administration (FDA)
announced through the Federal
Register that they were
amending the agency’s
regulations to prohibit the use
of certain cattle origin
materials in the food or feed of
all animals. Under the
proposal, 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, only prohibit the
inclusion of these high-risk
mammalian proteins in ruminant
feed. This revised rule was
proposed in October 2005 and FDA
received more than 840 public
comments, including those of
AFBF.
Materials classified as high
risk in the new rule include:
the entire carcass of
BSE-positive cattle; brains and
spinal cords from cattle 30
months and older; the entire
carcass of cattle not inspected
and approved for human
consumption that are 30 months
and older, if the brains and
spinal cords have not been
removed; tallow containing more
than .15 percent insoluble
impurities; and mechanically
separated beef derived from
materials prohibited by this
rule.
The removal of additional
high-risk materials from all
animal feed will reduce the
already low risk of BSE
transmission. Taking steps to
remove Specified Risk Materials
(SRMs) from all animal feed
eliminates the need to prohibit
the use of poultry litter and is
consistent with AFBF policy and
comments previously submitted.
FDA had also considered
prohibiting the use of blood
by-products, but did not include
that measure in the rule since
the World Organization for
Animal Health (OIE) has
confirmed that these products do
not transmit BSE.
Policy
In general, Farm Bureau policy
supports strengthening the
ruminant feed ban in order to
eliminate possible loopholes
that might allow SRMs to reach
ruminants through misfeeding or
cross-contamination.
Specifically, AFBF Policy #308,
(2009) Livestock and Poultry
Health, third paragraph,
(starting on line 19) states:
19 Livestock feed labels should
provide clear, concise and
accurate information regarding
Ingredients and nutritional
information. We believe the FDA
and state feed control officials
should consider making
modifications in labeling
requirements by developing more
specific classifications of
animal protein sources such as
"non-ruminant derived animal
proteins," "ruminant derived
animal proteins" and
"non-mammalian derived animal
proteins" to provide producers
with the information they need
to make the certifications about
feeding practices that the
marketplace is demanding. We do
not believe that it is necessary
to label feed ingredients
according to species origin. We
support the use of the current
warning statement of feed labels
that states, "Do not feed to
cattle or other ruminants" if
the feed contains ingredients
prohibited to be fed to
ruminants by FDA rules.
Additionally, AFBF Policy #308
lists several statements,
specifically numbers 9, 10 and
11 (starting on line 60) that
“we support:”
60 (9) Continued monitoring and surveillance programs for BSE
and other Transmissible
Spongiform Encephalopathies
(TSE) in the United States;
63 (10) A ban on the
inclusion in ruminant feeds of
any animal proteins
scientifically shown to
transmit BSE;
65 (11) A ban on the
inclusion of ruminant animal
proteins in poultry feeds;
Lastly, AFBF policy supports
efforts to increase the
number of rendering
facilities and collection
points. Specifically, AFBF
Policy #315, (2009)
Rendering Facilities and
Collection Points, states
that we support:
1) The streamlining of the
permitting process for
rendering facilities and
encourage livestock
producers to use rendering
facilities; and
2) Legislation that provides
economic and regulatory
relief to rendering
facilities and encourage
further development and
construction of rendering
facilities and collection
points.
And this AFBF policy also
“encourage(s) research that
adds value and marketability
of rendering facility
products.”
Kansas Farm Bureau policy
supports additional
collection points within
each county. Specifically,
CNR-17, paragraph 4 states:
“For safe disposal of dead
wildlife, domestic livestock
and pets, operators of solid
waste disposal sites should
be encouraged to develop and
maintain animal disposal
facilities at the county
level.”
On-Farm Solutions
As mentioned earlier, there are
three approved, on-farm disposal
methods of dead farm animals
other than rendering; burial,
incineration and composting. Of
the three, composting is often
the method of choice because it
is relatively inexpensive, can
be accomplished when the ground
is frozen and burial difficult,
and requires a minimum of space.
The following are several links
that provide additional
information on the subject of
composting livestock.
See AFBF Comments
FDA Final
Rule
KSU Composting Notes
KSU Composting Guide
KDHE Composting Guide
2004 CRS Report
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