2004-07-28-Legal Doc To FDA-By Garth Merrick On Renderings


NOTE:ANPR issued by Dept Of Agriculture – Advance Notice of Proposed Rule-making
NOTE:SRM Specific Risk Materials (boils down to renderings)
NOTE:BSE Bovine Spongiform Encephalopathy (BSE)
FOR more info-   SEE http://www.fda.gov/cber/bse/risk.htm

From: Garth Merrick
P. O. Box 2257
Hereford, Texas 79045

July 28, 2004
Tejas Industries, Inc.
P. O. Box 2257
Hereford, Texas 79045

Food and Drug Administration
5630 Fishers Lane
Room 1061
Rockville, MD 20852

RE: Federal Measures To Mitigate BSE Risks: Considerations for Further Action
Docket #04-047-1

ANPR’s proposed rule to prohibit SRM’s from all animal food including pet food and prohibiting materials from non ambulatory cattle and dead stock from all animal feed creates the below listed consequences of disposal of pounds that previously could be manufactured into animal feed.

<SNIP>

Our company services mostly Texas and parts of New Mexico, Oklahoma and Kansas. Last year we processed 255,000 head of dead stock not counting calves with an average weight of 600 pounds per carcass. The total weight comes to 153,000.000 pounds that makes its way into feed ingredients. If you total these three categories, they total over 300,000,000 pounds that no one is discussing what to do with. If you cannot render it for feed to be fed to chickens, swine or pet food, then you have destroyed a system that currently works. We are the original recyclers. These numbers are only for Texas; when you consider the other lower 47 states, the consequences are inconceivable as to what the health hazards could be if these products are not processed the way they are currently being done. There is not a cost to local, state or federal agencies now, but if these proposed rules are adopted, then someone else will have to step in and I fear, they will not be as efficient or cost effective as what private industry is doing now. There are huge consequences to be reckoned with and these consequences have to do with an effective way to dispose of these billions of pounds which are currently processed in an environmentally friendly way.

<SNIP>

If the consumer is ever going to have confidence in any aspect of public safety in the U.S., they have to have some confidence that our government agencies’ actions are based on scientific evidence and no on emotional outpouring, speculation and scare tactics. U.S. business also has the right to expect action based on science. Where there is no reproducible evidence to support, no action needs to be taken. When you consider the amount of material that would be produced without a place to go and then the health dangers that would be created, there is absolutely no logical reason to make any changes to the feed rules as they now exist.

Sincerely,

Garth Merrick
President

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