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.

"BSE 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 said.

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," noted Hodges.

"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.

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.

Source: American Meat Institute (AMI) - 16th August 2004