New FDA regulation to enhance feed ban for BSE
A new federal rule intended as one more safeguard against the transmission of bovine spongiform encephalopathy (BSE) may cause disposal problems of older dead cattle for many beef and dairy producers.
In an effort to strengthen safeguards against the transmission of BSE, a new federal regulation will be implemented on April 27 prohibiting the brain and spinal cord from cattle over 30 months of age from going into animal feed. The rule is intended to prevent any higher risk materials from ending up in livestock feed. The brain and spinal cord of BSE affected animals are of higher risk for containing the disease agent.
In the past, the brain and spinal cord from cattle was used in poultry and swine feed. However, issues such as feeding poultry litter to cattle as a non-protein nitrogen source became a concern. If the disease agent was ever introduced into poultry feed, it could be reintroduced into cattle from poultry litter being an added cattle feed ingredient.
BSE is a very slow incubating disease that takes years for symptoms to appear. The prion that causes BSE has to be injected or ingested in order for the animal to get the disease, which will then cause abnormal protein fractions that destroy the brain material and brain stem in its host by making microscopic holes.
Most cattle that die of BSE are five to 10 years of age. Cattle under 30 months old are not at risk for the disease because BSE has a much longer incubation period. Under the new rules, the brain and spinal cord of cattle over 30 months of age and certain cattle not inspected at slaughter are referred to as cattle material prohibited in animal feed (CMPAF) and are not allowed to be included in the feed chain.
Once the brain and spinal cord are removed from cattle over 30 months of age, they must be properly disposed of through a landfill, incinerated, use in biofuel, or other approved methods.
“This rule really caught most people asleep,” said Dennis Hughes, Nebraska state veterinarian. “They didn’t realize this rule was coming and now they are caught unprepared. Proving to the public our cattle don’t have BSE will cause a real hardship for some beef and dairy producers.”
The main concern among states is the environmental risk for disease and contamination.
“We don’t want to see these cattle dumped in shelter belts, into ravines or left by the road to rot,” said Hughes. “Although this is a federal rule, it will be up to the county sheriff and county attorney to enforce the proper disposal of these carcasses.”
In South Dakota, Dr. Dustin Oedekoven, assistant state veterinarian, said there are no rendering plants on the western end of the state and only a few on the eastern end of the state.
“Basically, the state law says they have to burn, bury or render within 36 hours,” he said. “We don’t want them to just leave the animal out there where scavengers and other animals can get into it and spread disease. It is important from a disease standpoint for the carcasses to be disposed of responsibly.”
However, ranchers and dairymen in some areas may feel they have few options once the new rule goes into effect. The biggest impact this new rule will have in Nebraska will be on large dairy farms. Hughes said some of the larger dairies can lose two to six cows a week. The question then becomes if the rendering companies won’t take them, what can the dairy do to dispose of them.
The options are limited, said Hughes, but there are some. Current regulations in Nebraska allow for dead animals to be burned, buried at least four feet underground, rendered or composted. However, in order for a carcass to be composted, it must weigh 600 pounds or less. Incinerators are also an option, but Hughes said they are so expensive they aren’t economically feasible for most producers.
Some states, like Wyoming and South Dakota, have landfills within their state that can accept dead cattle. However, under state law, Nebraska landfills don’t currently accept dead cattle and those who transport the deads must be licensed. Hughes said even if they changed the law, there are only six landfills in the state that could take them. “They don’t really want them. If they receive any numbers at all, they would be overwhelmed,” he explained.
Dr. Jim Logan, assistant state veterinarian in Wyoming, said the majority of ranchers in Wyoming dispose of dead animals through the landfill or composting, since the state has no rendering companies or large slaughter plants.
“Although I hate to admit it, I’m sure there are some dead animals that get disposed of in the bone pile, too,” he added.
Although not every landfill in Wyoming accepts dead cattle, Logan said some of them will.
“Ranchers should check with the landfill management to make sure they accept them before they try and take them there,” he explained.
One alternative being considered by some dairies, Hughes said, is digging a large hole before it freezes in the fall and using a layer of sand to cover their dead dairy cattle so predators and scavengers can’t get to them. However, these dairies will have to be concerned with the environmental issues – particularly ground water contamination.
Hughes is also concerned with how sale barn owners will dispose of old cows that die at their facilities.
“There are lots of times when ranchers will bring in a load of old cows and end up with a downer. They can’t be sold, so what will happen to it,” he said.
Spokesmen for some rendering companies have said they will no longer pick up cattle over 30 months of age mainly because of the extra costs and liability associated with handling of such animals. Other rendering companies will continue to pick up the cattle, but will do so at higher costs in order to cover the extra time of removing the brain and spinal cord. A few companies will continue to pick up these cattle at the same rates they currently charge if they can make it work.
Kevin Bosshamer, manager of Nebraska By-Products, Inc. in Lexington, said, “For anyone we are currently picking up for, it shouldn’t affect them at all. We will determine how old the animal is, and if it is over 30 months, we will remove the brain and spinal cord.”
Bosshamer said it is too early to tell how the new law will affect the company, but they are hopeful to continue with the same service.
“We will have extra expenses,” said Bosshamer. “We are just hoping they aren’t that great. It will take a little extra on our end to make it happen.
“One of the most important factors that producers need to know in our current coverage area is that we must pick up the dead livestock while they are fresh,” he added. “As soon as they die, we need to know so we can pick them up. If not, we may not be able to pick up the animal because we will not be able to remove the SRM’s.”
In Scottsbluff, NE, Jim Heumesser, manager of Platte Valley Pet Food, said they are also hopeful they can maintain their current rates.
“Our plan is to age identify the animal and if it is over 30 months of age, we will remove the brain and spinal cord,” he explained. “We will still pick up cattle over 30 months of age. Right now, we are not planning to charge anymore for them, but that could change in the future.”
Heumesser said one change the company will enforce is a stricter freshness policy.
“As soon as an animal dies, they need to contact us. If a cow is dead more than 24 hours, we will not pick it up,” he said. “It is much harder to remove the brain and spinal cord at that point and we wouldn’t be able to guarantee we got it all removed.”
Heumesser said they currently have fines in place for cattle they pick up that aren’t fresh. If the meat is rotten, it can’t be used for anything and the company has to pay extra to have it disposed. He added, the removal of the brain and spinal cord is not a hard process. The two pieces are relatively small and could fit in your hands when they are cupped together.
In South Dakota, Oedekoven said they were notified by two rendering companies with routes in the eastern part of the state that they will still pick up animals over 30 months of age, but they will rely on producer’s records and affidavits to determine the animal’s age. He added the companies may charge additional fees for these cattle to recover some of the extra expenses for handling the animal and removing the spinal cord and brain.
One of those companies, Central Byproducts in Redwood Falls, MN, said they will be charging producers an additional fee for the older cattle.
“We will continue to pick up cattle over 30 months of age,” said Don Davis, CEO of the company, “but we will charge an extra $35 a head to cover the removal of the brain and spinal cord.”
Davis said they expect the owner of the animal to be able to verify its age. If they can’t verify its age, Davis said they will have to charge the extra fee for removal of the brain and spinal cord.