Dear Mr. Leiberman:
This letter is in response to your letter of June 26, 1999 expressing your desire for CVM to enact a law making the use of companion animals in canine and feline rations illegal. We appreciate your taking time to express your views to us.
In order to make any animal feed practice illegal, we would have to publish in the Federal Register a proposed rule and a final rule which would eventually amend Title 21 of the U.S. Code of Federal Regulations to accomplish the intended action. This process has many requirements such as background information, economic and environmental impacts, defining the need for the change and so forth. The Background section of the proposed rule requires a thorough search of the scientific and regulatory record to document past work on the issue. It must explain the dangers of the current situation and why the change is needed. The proposed rule must also describe the dangers to human or animal health if the change is not made. If no health threat can be associated with not taking the action, regulatory change is not permitted or necessary.
We agree with Mr. Noel, that this practice is rare due sto the negative publicity in the pet food industry. The risk of bovine spongiform encephalopathy (BSE) to cats is real in England, since approximately 90 cats (out of a population of many millions) were diagnosed with feline spongiform encephalopathy not previously diagnosed in cats. Dogs were never diagnosed with this disease indicating a resistance to BSE.
Before BSE appeared in the UK, rendering of animal remains was never associated worldwide with any disease or health risk for the animals eating the rendered proteins or humans consuming the animal products. BSE poses a threat only to humans and animals in the countries with BSE. The USDA has a very active serveillance program for BSE in the U.S. and has not detected it. No cats or humans have been identified with BSE-related diseases in the U.S. as well.
The FDA BSE feed regulation is a mammalian-to-ruminant feed ban. Cattle are the most susceptible species to BSE and can get the disease by eating contaminated feeds from rendered BSE-infected cattle brains and spinal cords. The FDS regulation is designed to prevent the amplification of undetected BSE to cattle in the U.S. This is an extremely expensive and conservative measure to prevent transmission of BSE to other ruminants in case it was to occur undetected.
In summary, a risk to U.S. animals and humans cannot be scientifically documented from the recycling of animal materials though rendering. A scientifically based regulation for prevention of pet recycling through rendering probably cannot be defended at this time. We appreciate your disagreeing with the rare practice of rendering pets for animal feed based on esthetics, which are important, but not sufficient basis for regulatory action.
John P. Honstead, DVM, MS|
Veterinary Medical Officer
Division of Animal Feeds
Center for Veterinary Medicine