February 7, 2003

The National Grain and Feed Association this week urged the Food and Drug Administration to retain its existing animal feeding regulations that have contributed to keeping the United States free of bovine spongiform encephalopathy (BSE), commonly referred to as "mad cow disease." The NGFA said FDA's current animal feeding regulations designed to prevent the spread of the BSE agent if it ever enters the United States continue to reflect the best available science and prudent risk assessment, which the association said should continue to guide the agency's BSE-prevention efforts.

On that basis, the NGFA said, it does not believe that the current ban on feeding certain mammalian proteins to ruminant animals should be expanded beyond the restrictions now in place.

FDA's regulations were adopted in 1997 and prohibit the feeding to cattle or other ruminants of certain mammalian proteins - which it calls "prohibited mammalian protein." Pure pork and equine protein are exempt from the feeding restrictions

In a 13-page statement submitted in response to FDA's November 2002 advance notice of proposed rulemaking concerning potential changes to its current regulations, the NGFA specifically urged FDA not to require feed manufacturers or renderers to use dedicated facilities if they handle prohibited mammalian protein.

Instead, the NGFA said, FDA should reconfirm - as it did when promulgating its original BSE regulations in 1997 - that existing flushing, sequencing and physical cleaning procedures that FDA deems appropriate clean-out methods for medicated feed manufacturing operations continue to "constitute an appropriate level of protection against cross-contamination" under the agency's BSE-prevention rule.

The NGFA noted that the association's BSE-Prevention Policy recommends, as a best management practice, that feed mills that manufacture feed for multiple species, including ruminants, voluntarily discontinue using mammalian protein banned from use in ruminant feed unless they have separate and distinct mixing, handling and storage systems to prevent accidental commingling or cross-contamination. The majority of commercial feed manufacturers have done so "either because they believed it represented the easiest and most effective way for them to comply with the BSE-prevention rule or because of recommendations from their trade associations or requests from insurance carriers and feeder-customers," the NGFA said.