Publications

Industry News Update

Current Association News – December 11, 2008

NRA Working Group on Carbon Issues

There were several discussions of issues surrounding carbon and global climate change at the recent NRA convention and there was a need identified for a smaller group to do further work in the area. Issues for discussion and input include (but may not be limited to):

  • Carbon Footprint— FPRF has funded a research project at Clemson to study the carbon footprint of the rendering industry which first must develop a representative model of industry operations to properly define all of the inputs and outputs that should factor into the determination of a carbon footprint. This will entail collecting data from the industry, much of which is proprietary, so we need to figure out how to do this.
  • Carbon Credits— Congress will deliberate on instituting a national policy to reduce greenhouse gas (GHG) emissions while promoting clean technologies and economic growth. One possibility is a cap and trade scheme based upon emission allowances. Whether rendering would get any credit for “business as usual” or only for controlling GHG emission sources not already captured will be an important factor. This working group will advise NRA as we figure out how to weigh in on policy proposals.
  • Renewable Fuels—As NRA and the Environment Committee works to counter negative attitudes about biofuels made from animal fats, data from the above efforts can be used to show the environmental and energy balance advantages of animal fats over some other alternative fuels. Such data may be important in working for equal and fair treatment of rendered products in tax and incentive programs.
  • Other related issues as needed.

Enhanced Feed Ban—New Regulation Update

The FDA has published changes to the BSE Feed Rule that go into effect April, 27, 2009. There is no grace period and the supply chain must be cleared of prohibited materials before that date. The main part of the rule is this: Brain and Spinal cord from cattle 30 months of age and older cannot go into animal feed. Once removed, prohibited material must be dyed. Renderers must keep records to indicate they are doing these things and their suppliers are also following the rule. Also, tallow being fed to ruminants must be less than 0.15% impurities.

NRA established a Working Group, chaired by Mark Myers of Darling International to study the final rule and make suggestions to FDA on practical ways to approach the Guidance. We believe this was very helpful in minimizing the damage from the final rule that NRA had opposed on the grounds that it is unnecessary. NRA’s working group provided input to FDA as they work out terms of their compliance guide for the new rule. For the most part, the Guidance published by FDA followed NRA recommendations. Our goal was to make sure renderers can be prepared to implement the new rule and marketing is not disrupted any more than necessary. The rule is to take effect April 27, 2009. FDA has published the guidance document for feed rule amendments here:

http://www.fda.gov/OHRMS/DOCKETS/98fr/FDA-2008-D-0597-gdl.pdf and will take comments up until January 26, 2009. The final FDA rule can be found here: http://www.fda.gov/OHRMS/DOCKETS/98fr/08-1180.pdf

Feed Rule Webinars Successful

NRA co-hosted two seminars delivered over the internet to explain to raw material suppliers their responsibilities in ensuring compliance with the new feed rule. The first, on November 13, was aimed at the meat industry (cattle slaughterers and processors) and was broadcast from the American Meat Institute (AMI). The second was broadcast from the National Cattlemen’s Beef Association (NCBA) on December 8, and was aimed at cattle producers and markets concerning dead stock going to renderers. Both of these were viewed from nearly 80 different sites, and some of the sites had large audiences gathered together to receive the information.

NRA Sends Out “Compliance Kit” for Feed Rule Changes

In addition to working on the Guidance, NRA’s Working Group developed two forms to assist renderers in gathering the required information from raw material suppliers. These are titled “Age Warranty” to be used when collecting cattle mortalities from producers, and the “Cattle Processor RM Supplier Declaration” to be used when picking up offal and trim from meat processors. Individual companies can add their company name, logos, and any additional questions they may need. These were sent to all members.

Food Industry Environmental Council Comments on Global Warming Act

The Food Industry Environmental Coalition (FIEC, of which NRA is a member) commented on the Advance Notice of Proposed Rulemaking (ANPRM) “Regulating Greenhouse Gas Emissions under the Clean Air Act.” In summary, we believe that the most effective and cost-efficient method of curbing GHG emissions in the United States is through comprehensive climate change legislation. Barring such legislation, we have identified a regulatory approach that would bring up to eighty percent of GHG emission sources under control, but without the unintended consequences of dramatically expanded air quality planning procedures, preconstruction permitting requirements, or operating permit requirements. If legislation is unavailable, we urge EPA to: (1) decline to list GHGs as criteria pollutants; (2) regulate the top ten categorical sources of GHG emissions under a Section 111 cap-and-trade program with offsets; (3) interpret the phrase “regulated NSR pollutant” under the preconstruction permit program to include only those GHGs emitted at a Section 111 categorical source; and (4) interpret the definition of “major source” under the federal operating permit program to include only those GHGs emitted at a Section 111 categorical source.

REGULATION

EPA Spill Prevention, Control and Countermeasure (SPCC) Program Revised

On December 5, 2008, the Federal Register published EPA’s final rule to amend the SPCC program aimed at streamlining requirements and providing greater flexibility to regulated facilities. The final rule completes the revisions proposed by EPA in October 2007. The final revisions are published in the Federal Register and can be found here:
http://www.epa.gov/fedrgstr/EPA-WASTE/2008/December/Day-05/f28159.pdf

A summary of the revisions is here:
http://www.epa.gov/OEM/docs/oil/spcc/SPCCFactsheet_FinalAmendments_Nov08.pdf

This final rule is effective February 3, 2009. More info on SPCC is here:
http://www.epa.gov/oilspill/

A few of the points of interest to the rendering industry:

  • EPA came up with a compliance alternative for certain animal fat/vegetable oil (AFVO) storage containers subject to FDA’s GMP rules. Owners of AFVO containers would be allowed to use industry standards for visual inspection, rather than meeting the otherwise-applicable SPCC integrity testing requirements, provided the containers were: (1) elevated; (2) stainless steel; (3) non-insulated; and (4) shop built.
  • The final rule modifies the SPCC program’s general secondary containment provision to clarify that the method, design and capacity of secondary containment need only address typical failure modes and most likely quantities of oil discharged, and that both active and passive secondary containment measures are permitted.
  • In addition to the SPCC program revisions outlined above, EPA also proposed to extend the date for compliance with the new rules to November 20, 2009. This proposal was published in the Federal Register November 26, 2008, with a 30-day comment period.

OTHER ISSUES

Spill Prevention, Control and Countermeasure (SPCC) Regulation Seminar

There is an SPCC Seminar via the internet scheduled for January 13, 2009 from EPA. The web site accommodates three types of registrations (online, fax or mail), provides seminar handouts available for printing; offers additional program specific materials for users, and provides certificates for attendees. EPA Regions 5 and 7 are co-hosting a 4-hour seminar which will broadcast via satellite to 33 locations throughout the two Regions. In addition, this year the seminar may also be viewed over the Dish Network or via a high-speed Internet connection. The seminar will cover topics such as SPCC Plan basics, Integrity Testing, Applicability, Secondary Containment, the SPCC Rule Amendments (signed November 20, 2008) and a 1-hour Question and Answer session. The Web site address is www.k-state.tv/epa/ For seminar questions only (no registrations), contact Dr. Carr at 312.886.7187 or carr.barbara@epa.gov or Susan Jagerson for registration assistance and questions at 785.532.3105 or sdj@ksu.edu.

Irish Meat Contaminated with Dioxin

As many as 25 countries could be pulling Irish pork products from their shelves, after the Irish government said 10 farms in Ireland and a further 9 farms in the British province of Northern Ireland had used a feed contaminated with dioxin. The Irish government said on Saturday that laboratory tests of animal feed and pork fat samples confirmed the presence of dioxins, with toxins at 80-200 times the safe limits. Preliminary evidence indicated the problem was likely to have started in September of this year. The Irish Exporters Association said the total exports of pig meat and related added value products such as pizzas, pies and sandwiches containing pork was about 750 million euros ($950 million). Irish officials confirmed Tuesday that cattle at three farms have tested positive for dioxin, but they insisted that the country’s beef poses no real risk to health. A statement from the European Food Safety Authority (EFSA) on the risks for public health due to the presence of dioxins in pork from Ireland is here:
http://www.efsa.europa.eu/EFSA/efsa_locale-1178620753812_1211902210863.htm

CAST Publishes Carcass Disposal Papers
Swine Carcass Disposal Options for Routine and Catastrophic Mortality
CAST Issue Paper
http://www.cast-science.org/displayProductDetails.asp?idProduct=155

This Issue Paper provides a critical assessment of information available on methods of swine carcass disposal under routine and catastrophic conditions. The authors have focused on efficiency and effectiveness of available methods as well as potential animal health and environmental protection considerations. The paper addresses the four predominant methods of mortality disposal in commercial swine production—burial, incineration, rendering, and composting—and various alternative and nontraditional methods and technologies.

Poultry Carcass Disposal Options for Routine and Catastrophic Mortality
CAST Issue Paper
http://www.cast-science.org/displayProductDetails.asp?idProduct=158

Methods for the disposal of poultry carcasses currently include burial, incineration, composting, and rendering. Although each method is preferable under specific circumstances, each also presents disadvantages, including potential effects on groundwater and increasing cost considerations. With those concerns in mind, there are other, emerging technologies for carcass disposal that may offer viable alternatives. Methods, strategies, and practical applications presented in this paper summarize acceptable means for disposal of poultry mortality.

Ruminant Carcass Disposal Options for Routine and Catastrophic Mortality
This CAST Issue Paper is in the final stages of development and will be introduced in January.

Carcass Disposal Meeting July 21 – 23, 2009—“Save the Date” Notice

3rd International Symposium on Management of Animal Carcasses, Tissue, & Related Byproducts Connecting Research, Regulations, and Response at the University of California –Davis, California 3 days of plenary, breakout and poster sessions to discuss, learn and share information with researchers, policy makers and regulators on carcass disposal technology, planning and policy. Included in these days will be hands-on workshops and demonstrations of available carcass disposal technology.

  • Carcass disposal in response to routine mortalities, accidental deaths, natural disasters, and disease outbreaks;
  • Research and public policy on carcass disposal;
  • Federal and state agency response and training experience;
  • Carcass treatment (management) options;
  • New and emerging technologies for euthanasia, carcass treatment/ disposal, and disinfection;
  • Final product use and disposition;

(Note: Animal studies are not limited to farm animals. Projects focusing on disposal of wildlife, marine mammals, or other species are welcomed.) Watch for registration material coming soon to http://extension.umaine.edu/ByproductsSymposium09/default.htm

DHS Issues Final Environmental Impact Statement on Plum Island Replacement

The U.S. Department of Homeland Security’s (DHS) Science and Technology Directorate released the final Environmental Impact Statement (EIS) for the National Bio and Agro-Defense Facility (NBAF), recommending Manhattan, KS as the preferred site for the state-of the-art, high-security laboratory facility to study foreign animal and zoonotic (transferable from animal to human) diseases that can impact livestock. A formal Record of Decision, which will officially designate a site on which to build the NBAF, will be published on Jan. 12, 2009. Facility design will begin in 2009 with plans for construction to begin in 2010. It is expected that the NBAF would be operational by 2015. The final report is here: http://www.dhs.gov/xres/labs/gc_1187734676776.shtm#1

FDA Touts Efforts to Enhance Food Safety

Responding to criticism that it has done a poor job safeguarding the nation’s food supply, the FDA released a report earlier in December detailing its efforts to protect consumers. The new report updates progress made since the FDA unveiled its Food Protection Plan in 2007. Titled Food Protection Plan: One-Year Progress Summary, the document cites improvements in three areas: prevention of outbreaks of food-borne disease; intervention; and response to outbreaks. Some of the accomplishments claimed include:

Prevention:

  • The agency said it’s in the process of opening five offices around the world, to be staffed with its own inspectors, in China, India, Europe, Latin America and the Middle East.
  • The FDA participated in meetings in China to discuss food-safety issues in both countries and to share suggestions on ways to address global food safety.
  • It is hiring an “international notification coordinator” to serve as a liaison between the FDA and its foreign counterparts.
  • It has approved the irradiation of iceberg lettuce and spinach to control toxins such as E. coli.
  • It has developed tests to detect contaminants such as melamine and
    cyanuric acid.

Full text: http://www.fda.gov/oc/initiatives/advance/food/progressreport1108.html

What Animal Activist Success Means to the Beef Producers – Steven L. Kopperud Video

Steven L. Kopperud is senior vice president of Policy Directions, Inc., a Washington, DC government affairs company specializing in production agriculture, agribusiness, animal health, food, farm policy, trade and ag research/health-related issues.

As an authority on activist assaults on animal agriculture, Kopperud has spoken to audiences in the U.S., Canada, Australia and Latin America on threats to food production. He coordinates the Farm Animal Welfare Coalition and is the immediate past president of the Animal Agriculture Alliance, a national charitable education foundation dedicated to telling the American public the reality of modern livestock production.

Watch as Kopperud introduces the audience to a new and different perspective on animal welfare and explains “What Animal Activist Success Means to the Beef Producers.”

If you’re even remotely connected to animal agriculture, Click here http://tinyurl.com/6gnrwr for a streaming video of his speech at this summer’s International Symposium on Beef Cattle Welfare. It’s 34 minutes well-spent.

As long as you’re using your company’s valuable time looking at videos…take three more minutes and watch this one: http://www.greatquotesmovie.com/ on great quotations.

International Feed Expo and the International Poultry Expo Offer World of Opportunities

This great show now includes a new section featuring rendering equipment, suppliers, and rendered products. The International Feed Expo and the International Poultry Expo is scheduled for Jan. 28-30, 2009, in Atlanta, GA. Exploring the Expo’s 16 acres of show floor is a great way to learn about new technologies, services and issues facing the feed and livestock industries, as well as meet with domestic and international industry peers. Registration for the 2009 Expo may be completed online. Register at www.ipe09.org to save $10. The pre-registration fees will be $30 for online registration and $40 for registration via mail or fax. After Jan. 5, 2009, you must buy your Expo pass at the door for $50.

Lawrence Selected to Serve on NASS Committee

Dr. John Lawrence of Iowa State University received word this week that he was appointed by Agriculture Secretary Ed Schafer to become a member of the National Agricultural Statistics Service’s Advisory Committee on Agriculture Statistics.

FDA Issues Melamine Guidance Level

CVM officials confirmed the level of concern the agency published for melamine in food products also applies to feed and feed ingredients. Tests confirming melamine at or above 2.5 parts per million in either finished feed products or feed ingredients will result in further investigation and possibly a request to recall the products in question. The FDA notice said, “In food products other than infant formula, the safety/risk assessment concludes that levels of melamine and melamine-related compounds below 2.5 ppm do not raise public health concerns. This conclusion assumes a worst case exposure scenario in which 50 percent of the diet is contaminated at this level, and applies a 10-fold safety factor to the Tolerable Daily Intake to account for uncertainties.” The full melamine risk assessment, including the rationale and scientific references, may be found here:
http://www.cfsan.fda.gov/~dms/melamra3.html