North West New York
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Rendering Regulation Changes
By: Jerry Bertoldo


In response to concerns about tightening the safety net against BSE (mad cow disease) the FDA has added a new section to the existing regulations on the books. In recent years, rendered cattle by-products containing “specific risk materials” (SRM) from brain and spine processing were banned from use in ruminant feeds. Nerve tissue can contain the abnormal prions (very small proteins) that are associated with BSE and its related disease in humans Creutzfeldt-Jakob Disease. Bovine meat and bone meal and blood meal were notable examples of materials prohibited from inclusion in cattle feeds. Tallow was exempted from the rule.

New regulations are slated to go into effect on October 26, 2009. SRM now called “cattle material prohibited in animal feed” or CMPAF may not be used for any animal feeds including pets if the rendered animal is over 30 months old. In addition, the entire carcass of cattle not inspected and passed for human consumption cannot be used for animal feed unless the cattle are less than 30 months of age or the brains and spinal cords have been effectively removed. Tallow derived from CMPAF must now contain less than 0.15% insoluble impurities. Previously, any cattle mortality could be rendered and processed for use in any species other than bovine.

The primary impact of the 2008 rule will be on the rendering industry due to a number of specific requirements. The expense of CMPAF removal is significant. Although the feed industry is required to formulate feeds free of banned materials to the best of their knowledge, it is the renderers that must bear the responsibility of having written procedures explaining how they determine the age of cattle. They must keep records documenting their compliance with the requirement as well. Farms are required to provide a statement as to the age of the animal to be processed. The liability associated with age identification, however lies solely with renderers. This situation has pushed some out of cattle mortality handling and the remaining processors to raise prices dramatically for on-farm removals.

So, what happens to all that CMPAF that has no commercial use as feed? Disposal in landfills, by incineration, composting, alkaline hydrolysis and burial are the options. All of these options add labor and expense to mortality disposal by the renderer and potential environmental problems.

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