By Susan Harlow
Dairy producers would likely find it more expensive or even impossible to send dead animals to renderers, with a new U.S. Food and Drug Administration (FDA) rule that may go into effect later this year. The rule is intended to enhance the 1997 feed rule banning specific risk materials in ruminant feed to prevent bovine spongiform encephalopathy (BSE) in the human food supply. It forbids cattle older than 30 months of age being rendered for use in animal food, including pet food, unless the specific risk materials – brain and spinal cord – are removed first.
The rule was to go into effect April 27, but in March, FDA delayed implementation for 60 days and began taking public comment on whether to further delay the effective date.
According to FDA, the rule would cost U.S. producers a total of $28 to $29 million annually in lower cull cow prices that renderers will pay to offset higher disposal costs, and in cattle no longer sent to renderers.
Renderers are already working to comply with the rule in order to clean out their inventories before the rule goes into effect, says Tom Cook, president of the National Renderers Association. Some are getting out of picking up deadstock altogether. Others will only pick up cattle less than 30 months of age, and they’ll require farmers to produce some proof of age, such as records or using teeth to calculate age.
Some renderers will continue to take all animals, segregating them by age. If they have the facilities, those renderers will remove the brains and spinal cords from the older cattle, or they may offer alternate disposal. “Obviously, there will be added cost,” Cook says.
It’s good news to livestock and rendering organizations that FDA will delay implementation. “We welcome the chance to make our case for why we oppose the rule,” Cook says. “There’s no scientific justification for it.”
A patchwork of state regulations covers disposal of deadstock. In some states such as California, which bans burning, burying and, for the most part, composting deadstock, alternatives to rendering are limited.
Other states allow various disposal methods, but usually have restrictions. In Pennsylvania, for instance, producers must dispose of carcasses within 48 hours. In Minnesota, there are strict limits on how close to water supplies dead animals can be buried. “In some areas, it’s not an option,” says Curt Zimmerman, livestock development supervisor, Minnesota Department of Agriculture.
A statewide rendering study group in Minnesota has been looking at the issue since last year. Alternatives will eventually be feasible, such as mobile incinerators or regional composting facilities, Zimmerman says. The industry will find new uses for deadstock that can’t be used in animal feed, such as fertilizer.
Agricultural and environmental agencies in New York and throughout the Northeast are working on the problem, says Jean Bonhotal of the Cornell Waste Management Institute. “With a 4% mortality rate in the industry, that’s a lot of cows,” she says.
Bonhotal is advising producers of alternatives to rendering, including:
• Burial. Burial is legal in most states but not necessarily advisable, especially in areas like northern New York that have large numbers of dairy animals but little land available that they want to dedicate to animal burial. “If people bury too many cows in one location it concentrates nutrient and pathogens and can cause water quality issues,” she says. In some areas, burial is being offered by private operators, who then may illegally dump the carcasses. But the producer is still responsible – you must know where the mortalities are being buried and that it is a legal operation. “For your safety, have signed contracts in place with a statement of how and where mortality is being disposed of,” she says.
• Burning, or incineration. Difficult with large animal carcasses and creates pollution.
• Composting. Legal in all states except California, and in parts of Canada, although regulation varies. The Natural Resource Conservation Service’s standard is an umbrella guideline for all mortality disposal. State standards provide may provide more pertainent guidance. In Minnesota, Ohio, New York, Pennsylvania, Montana,VT, NJ, VA New Mexico, West VA, and other states, workshops on how to compost deadstock are offered. For detailed info visit http://cwmi.css.cornell.edu/composting.htm#mortalitycomposting
• Landfills. It is “hit or miss” whether landfills will accept mortalities, but they may do so in an emergency, Bonhotal says.
• Dumping carcasses in the back forty. Illegal, dangerous, attracts wildlife and polluting.
Producers who need more information should call their local rendering service, Extension service or agriculture department to learn about alternatives are in their states.
■ For more information on the rule, go to: http://www.fda.gov/cvm/bse_QA.htm
■ Cornell Waste Management Institute has information on composting, which is widely used, at http://cwmi.css.cornell.edu/naturalrendering.htm
■ A national symposium will be held July 21-23 in Davis, Calif., on carcass disposal including research, treatment options and new technologies for euthanasia and disposal. Contact: Mark Hutchinson, University of Maine Cooperative Extension, firstname.lastname@example.org or 207-832-0343. Or Jean Bonhotal, email@example.com or 607-255-8444.