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Sandi K
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« on: April 06, 2009, 05:40:44 PM » |
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http://www.fda.gov/cvm/CVM_Updates/BSEDelayRule.htmApril 6, 2009 FDA Announces Delay of BSE Final Rule Implementation
The Food and Drug Administration today announced a delay in the implementation of the final rule entitled, "Substances Prohibited from Use in Animal Food or Feed" or more commonly referred to as the 2008 BSE final rule. The final rule, which would have gone into effect on April 27, 2009, is now delayed 60 days to June 26, 2009. The agency is taking this action in response to comments from affected parties expressing concerns about their ability to fully comply with the rule by the April 27, 2009 effective date. In addition, some affected parties are finding it difficult to identify appropriate alternate ways of disposing of material that may no longer be rendered for animal feed use once the rule takes effect.
The FDA is also providing 7 days for public comment solely on the question of whether to delay the effective date. Comments must be submitted within 7 days of publication in the Federal Register of the notice of proposed delay of effective date.
Interested persons may submit written comments on or before April 16, 2009 to the Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852. Electronic comments may be submitted to http://www.regulations.gov. Identify all submissions to the docket with the following docket number: FDA–2002–N–0031 (formerly Docket No. 2002N–0273).
Questions may be directed to Burt Pritchett, Center for Veterinary Medicine (HFV-22), FDA, 7519 Standish Place, Rockville, MD 20855, 240-453-6860, burt.pritchett@fda.hhs.gov. OK but pardon me, what does this mean? "In addition, some affected parties are finding it difficult to identify appropriate alternate ways of disposing of material that may no longer be rendered for animal feed use once the rule takes effect." Does it mean the cwap was so bad and now that they cant put it in animal feed, they have no other way to dispose of it? WTH? 
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3catkidneyfailure
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« Reply #1 on: April 06, 2009, 05:50:39 PM » |
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Except put it into pet food, since apparently the Final Rule makes no specific mention
of pet food. Might be something posters want to write a letter about before April 16, 2009.
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Spartycats
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« Reply #5 on: April 07, 2009, 12:51:21 PM » |
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This is a ironic, but it does make the point about all animal feed.
21 CFR Part 589
Substances Prohibited From Use in
Animal Food or Feed; Final Rule
"(Comment 68) Three comments stated
that salvaged pet foods, including
distressed pet food, should be
prohibited in cattle feed.
(Response) Pet food containing
prohibited mammalian protein is
prohibited from use in ruminant feed by
the 1997 ruminant feed rule. Pet food
products sold or intended for sale as
distressed or salvage items must be
labeled with the statement ‘‘Do not feed
to cattle or other ruminants’’ if they
contain or may contain prohibited
mammalian protein (see
§ 589.2000(d)(4)). This final rule further
reduces the risk that cattle could be
exposed to the BSE agent through pet
food because it requires the removal of
certain cattle-derived risk materials
from all animal feed.
(Comment 69) Two comments
requested that the current feed rule be
revised to exempt firms that handle
retail pet food from recordkeeping
requirements.
(Response) The 1997 ruminant feed
rule requires firms to maintain records
sufficient to track products containing
prohibited mammalian protein.
Exempting retail pet food distributors
from recordkeeping requirements would
diminish the ability of the agency to
trace feed or feed ingredients that are
adulterated under the 1997 ruminant
feed rule. The agency intends to issue
guidance that addresses what
constitutes records sufficient to track
prohibited protein associated with the
sale of retail pet food."
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Sandi K
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« Reply #6 on: April 07, 2009, 12:56:28 PM » |
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Huh, you mean thats the section regarding pet food?  S--t. So in other words, they are worried about the cows getting affected by bad pet food? WTF? And by the way, what is "distressed" pet food? I know I get distressed when I use it but....... |
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lesliek
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« Reply #7 on: April 07, 2009, 02:18:41 PM » |
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Probably out of date,damaged bags or cans & recalls.
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"the world's most inept extortionist"
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Spartycats
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« Reply #8 on: April 07, 2009, 02:25:55 PM » |
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« Last Edit: April 07, 2009, 02:32:05 PM by Spartycats »
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3catkidneyfailure
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« Reply #9 on: April 07, 2009, 05:29:22 PM » |
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So since pets are not ruminant animals, it seems to me Susan Thixton's
opinion article is perhaps in error and pet food is where this is all now going, since
even distressed and salvaged pet food may be repackaged but not fed to
ruminant animals in animal feed, which is a separate class from pet food.
BSE rendered products and SRM protein materials have and will continue to
go into commercial pet food under this Final BSE Rule when implemented?
Have I got that right in my thick head in all this wording mumbo jumbo?
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« Last Edit: April 07, 2009, 05:34:39 PM by 3catkidneyfailure »
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Spartycats
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« Reply #10 on: April 08, 2009, 04:51:06 AM » |
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3cat,
I think Susan Thixton is correct and this will include removal of cattle-derived risk materials from all feed, including pet food (at least that's the meaning I took from the section I posted). I'm sorry if my post confused matters.
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Sandi K
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« Reply #11 on: April 08, 2009, 06:25:46 AM » |
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LOL Sparty, I dont think its your post that confused anything, its the sneaky wording they put in all these proposed rules. Takes an attorney to decipher it all.  |
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lesliek
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« Reply #12 on: April 08, 2009, 06:49:41 AM » |
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I got a reply from Burt Pritchett & it says all pet food is included.
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"the world's most inept extortionist"
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catbird
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« Reply #13 on: April 08, 2009, 06:59:09 AM » |
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I just got a reply too, same thing. Pet food is included.
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Read "The Omnivore's Dilemma" and you'll know where we are going and why we are in this handbasket.
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Sandi K
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« Reply #14 on: April 08, 2009, 07:22:49 AM » |
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I got the same reply. I had also asked him about the FDAAA and why nothing has been acted on with that. He said his understanding was they had 2 years to implement it which would be Sept 2007 and he said his impression is that will be met....I wrote back as it was my understanding that the early warning system part of it had a 12 or 18 month deadline and he said when he found out more about the status he would let me know. He was at least trying to be helpful. He isnt the first person that said they had 2 years to enact it so I dont know if I am not reading the FDAAA law correctly or if its what Im thinking and that the deadline on certain parts of it have not been met.
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