An informative article for sure.
I note that it was writen in 1991 and by the FDA.
The following passage is interesting to me:
In August 1997, FDA established a regulation that prohibits the use of most mammalian protein in the manufacture of animal feeds for ruminants.".
There was a time when the "spirit" of a regulation was respected. Now it is fashionable to comply with the letter of any law and otherwise 'interpret' it to one's own advantage. Let's see how this one might measure up...
1) "Established a regulation..." it would be darned nice to know the monetary and professional impact of flouting a "regulation". My guess is that it is a nuisance at worst but I surely would be pleased to hear that it usually involves JAIL TIME.
2) "..most mammalian protein..", so that means that other animal "protein" is still acceptable
even though ruminants are herbivores!!!
3) "... feeds for ruminants." So let's see...such feed may still be fully legally if made for non-ruminants. And how is one to ensure that such legal feed is never fed to a ruminant???
In the end, then, the protein-laden feed from cows can be manufactured to feed, say, farmed salmon and trout. Then the by-products of salmon/trout butchering (I think it's just called 'cleaning' but butchering is more in tune here) can go to a rendering plant which can put it in feed for ruminants. Now if prions can survive high-temperature 'cooking' then it seems a safe bet that they can survive salmon/trout digestion too. So are we any further ahead? Why not establish a LAW - no feeding of any animal part, in whatever form and however processed, to herbivores. Seems so very simple.
By the way, seems it can also go into pet food (non-ruminants). I wonder if pets can end up at rendering plants? My bet is yes!
Here's another statement: "
More than three-quarters of these establishments were found to be in compliance. And most of the establishments that initially had problems were found in compliance upon re-inspection." (speaking of the insepction of 10,000 'establishments' directly involved with feed.
First, what portion of the whole does 10,000 represent? If its 98%, then maybe that's a good number. If it more like 50%, how good is it???
Secondly, what 'shortcuts' were involved in these "inspections"? For instance, if one 'establishment' of company XYZ was inspected was it then procedure to assume the other 13 plants of that same company to have been 'inspected'? Don't laugh, these things happen more than we care, by a long shot.
Thirdly, "most" is a nice cop-out, don't you think?... "most" could mean 51% or it could mean 98%. If it happens to be 51% then we have a nice report but a terrible situation where over 1,200 'establishments' remain out of compliance.
Finally, ANY establishment subject to "inspection" always looks for ways to prepare for inspection. Were these "inspections" unannounced or were they pre-booked? Were any of the inspectors getting under-the-table payments to pre-warn of impending visits?
At least ther's enough honesty to admit that compliance REMAINS less than 100% (as witnessed by the statement: "
Based on an evaluation of the inspections conducted from 1998 through 2000, FDA will revise its compliance strategy to try to assure its goal of 100 percent adherence to the feeding regulations.").
Finally this statement: "
FDA and USDA will continue to aggressively enforce their regulations and... ". No where has the penalty been stated. Obvoiusly, from prior statements regarding non-compliers, the penalty does NOT include shutting down a plant! Is it a simple slap on the wrist with a promise to return soon to see the remedies in place?
[I once had a user who got great mileage out of the statement 'but it's gotta be done or else we face a fine from the government'. We busted our a**es every time to meet the requirement. Then one day one of the my staff asked the simple question 'how much is the fine?'. The answer was $50.00!]
cheers and Happy New Year
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http://www.fda.gov/fdac/features/2001/201_cow.html
