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National Pig Association THE VOICE OF THE UK PIG INDUSTRY NPA is active on members' behalf in Brussels & White-hall, and with pro-cessors, supermarkets & caterers – fighting for the growth and pros-perity of the UK pig industry.

"I wouldn't have survived financially over the past four years if I hadn't been able to use co-products," said East Anglia pig producer Philip Richardson tonight.

Like other pig producers who feed products such as whey and molasses, he stresses that co-products are produced to the same standards as human food and are carefully controlled through the United Kingdom Agricultural Supply Trade Association's Feed Assurance Scheme.

The Environment Agency's rationale for seeking to call co-products "waste" is based in part on a recent court case involving stone cutting in which the judge laid down rules for differentiating by-products from waste.

The Environment Agency view appears to be that if an end product is something a manufacturer seeks directly to produce, then it is not waste - but everything else is.

Livestock producers are clear that whatever happens in the stone cutting industry, it has little or no relevance to the food industry. For instance, a packhouse that handles cabbages will have not one, but several uses in mind..

• The perfect looking specimens will go to supermarkets.
• The less perfect will be made into coleslaw.
• And the outer leaves will be taken away for use as stock feed.

Commonsense and economics dictate that cabbage production must have all three outlets to ensure full utilisation of the British cabbage crop. Any other method of production would be environmentally wasteful and ultimately contribute to landfill problems.

It is felt in the pig sector that the Environment Agency has inadvertently adopted an untenable stance. The hope is that following negotiation with farming and feed industry representatives it will be prepared to modify its stance, which is intellectually flawed.

The Environment Agency's co-product bombshell came to light only a few days ago, in draft guidance relating to Integrated Pollution Prevention and Control regulations under a section entitled "The treatment of animal and vegetable matter and food industries".

Unless the Agency modifies its plans, any feed material that is not the primary product of a manufacturing process will be classified as waste.

Not only could this mean a raft of new controls for pig producers, it would also stigmatise them as being "waste feeders".

Worse still, it will drive some away from co-products altogether, rendering sophisticated feeding systems useless and raising a question mark over expensive research currently being carried out at the pig industry's independent research farm at Stotfold.

Huge volumes of wholesome human-quality food would be consigned to landfill, as the following figures (tonnes) for the UK show...

Brewers' grains/yeast	900,000 (+ imports)
Citrus pulp	250,000
Distillery feeds	570,000 (+ imports)
Maize gluten feed	1,000,000 (+ UK production)
Molasses	335,000 (+ non-compound use)
Potato processing feeds	270,000
Sugar beet feeds	1,000,000

The proposed downgrading of the above feeds is irrational, say manufacturers. Most are well established, traditional, components of compound feeds and farm-mixed rations.

The majority are produced as co-products within the human food and drinks industries and are subject to stringent hygiene and food safety safeguards in order to comply with the human food and drink regulations. They are at least as safe as any other feed material which has either been imported or grown on European or UK farms.

The Environment Agency's decision appears to have been reached without consultation with producers of such products, such as brewers, distillers, maltsters, potato and apple processors, starch and sugar producers, as well as farmers and merchants.

Defra - and indeed the Environment Agency - are aware that if pig farmers were no longer able conveniently to use these products, it would create significant environmental problems.

In making their case to the Environment Agency, manufacturers and farmers will be stressing the wholesomeness of co-products.

Take potato peel as an example. It is removed before the production of french fries, partially removed in the manufacture of potato crisps, and left entirely in place for jacket wedges.

The choice of food or feed markets for the peel is simply a matter of marketing strategy - as may be judged from the recent introduction of potato skins by the restaurant trade: it is not a matter of food hygiene or quality. No part of the potato is "waste".

Source: National Pig Association - By Digby Scott - 10th November 2003