NGFA Adopts BSE Prevention Policy

March 20, 2001

The National Grain and Feed Association adopted a major policy statement concerning efforts to prevent the emergence of bovine spongiform encephalopathy during its just-completed 105th annual convention. Approximately one-third of NGFA-member companies are involved in the manufacturing and distribution of animal feed. The policy statement was developed and recommended by the NGFA's Feed Industry Committee, and subsequently was adopted unanimously by the association's board of directors.

NGFA "fully supports" the Food and Drug Administration's existing regulations that prohibit the feeding of ruminant-derived protein to cattle and other ruminant animals, and reiterates the importance of full compliance. To facilitate compliance and ensure consumer confidence, the NGFA policy statement recommends as a "best management practice" that feed mills that manufacture ruminant feeds voluntarily discontinue the use of prohibited ruminant-derived protein unless they have separate and distinct mixing, handling and storage systems to prevent accidental commingling or cross-contamination. Active surveillance in the United States since 1990 has not detected a single case of BSE.

The NGFA's policy statement also reiterates its support for FDA and state inspections leading to "full and fair enforcement" of FDA's BSE-prevention regulations to ensure compliance throughout the supply chain, including renderers, feed manufacturers, farmers and ranchers, transporters and meat processors.

To further reassure consumers, the policy statement says the NGFA will work with other involved parties – renderers; farmers and ranchers; meat packers; meat processors; food processors, manufacturers and retailers; and government – to provide mechanisms through which feed manufacturers can affirm their compliance with FDA's BSE-prevention regulations on the basis of existing government-based inspections.

"In particular, the NGFA will work to facilitate marketplace acceptance of individual company-to-company assurances, including contractual guarantees, company affidavits and other mechanisms, which are responsive to customer needs," with reliance upon existing, government-based inspection efforts.

The NGFA's policy statement recommends that upon completion of the initial round of FDA and state inspections of all identified renderers and feed manufacturers – and reinspections of facilities where warranted – that FDA maintain an ongoing, but targeted, inspection and enforcement effort. Specifically, the NGFA policy statement recommends that FDA develop a statistically valid random inspection program that traces the movement and use of ruminant-derived protein forward from rendering plants through the supply chain to facilitate continued compliance with the agency's BSE-prevention rule. In addition, the NGFA says it supports efforts by the Association of American Feed Control Officials to make BSE inspections a continuing part of routine feed mill inspections conducted by states.

NGFA also reaffirms the association's commitment to science-based measures to prevent the BSE agent from entering the United States, including retention and strict enforcement of existing import restrictions in place since 1989 on animals or animal proteins from countries where BSE incidents have been diagnosed or that may be vulnerable to its occurrence.

Consistent with its belief in science-based standards, the NGFA policy statement also "fully supports the continued use of ruminant-derived protein as a safe, nutritious and wholesome feed ingredient for non-ruminant species, for which it is legally approved."

The NGFA policy statement commits the organization to continuing its intensive ongoing BSE-prevention education, training and information efforts, in cooperation with its 38 affiliated State and Regional Grain and Feed Associations, to complement the efforts of government and industry to ensure a continued safe, abundant and wholesome food supply.