BSE controls draft report, 6 November 2000, section 12
56. The aim of the feed ban is to keep potentially infectious material out of feed for farmed livestock and so remove exposure to BSE. It is therefore the key control in eliminating BSE from cattle. Initially it took the form of a ban on the feeding of ruminant protein to ruminants. However, some cattle born after its introduction in 1988 continued to be affected by BSE. It was thought this was, at least in part, due to cross-contamination of ruminant feed by material from other livestock feeds which were not subject to the same controls. Eventually, in 1996, the ban was extended to prohibit the feeding of meat and bone meal (MBM) from any mammals to all farmed livestock, in order to avoid any possibility of its getting into feed for ruminants.
57. Since 1 August 1996 it has been an offence to possess mammalian MBM on premises where livestock feed is used, produced, prepared or stored. A Feed Recall Scheme was conducted to ensure that residual stocks were removed from farms before the ban on possession came into effect. A feed sampling programme has been in place since February 1996 under which around 20,000 samples are taken each year from about 3,000 different premises. Samples of concentrate feed are routinely checked for the presence of ruminant or pig protein using immunological assays. The results of the sampling programme, which are published each month, indicate a high level of compliance with the feed controls. Since sampling began in February 1996, 63,662 samples have been tested, of which 99.72% tested negative for mammalian protein. Those which tested positive or inconclusive have been followed up. The results showed legitimate presence of mammalian protein (ie not MBM) in non-ruminant feed or MBM in non-ruminant feed. All potentially exposed (from cross-contamination) cattle were destroyed. Methods based on DNA technology are being researched with the aim of producing assays with better sensitivity and specificity.
58. The relationship between the decline in the BSE epidemic and the age profile of affected animals indicates that the feed ban has been largely effective. The surveillance currently costs over £2 million per annum and the extension of the ban to non-ruminant livestock has had economic effects on the pig and poultry sectors. It has been estimated by the industry (in 1998)43 that the absence of a market for meat and bonemeal creates an annual cost to the beef sector of £43 million, with £25 million to the sheep sector and £32 million to the pig sector. However, this is a market effect and cannot be attributed as a direct cost of regulation. It was also calculated that the annual cost to pig and poultry producers of using alternative, more costly feed supplements is some £14 million. This is attributable directly to the regulation.
59. We have not heard any convincing arguments for relaxation for the foreseeable future in the ban on feeding ruminant protein to ruminants. In addition, we agreed with SEAC's view44, that recycling of animal material within any species used for human or animal food is undesirable. Such recycling, as occurs in the feeding of swill to pigs, could theoretically amplify a new TSE in the species. It would then probably be some time before this were detected, by which time a substantial pool of infectivity could have been established, and a further BSE-like epidemic created. The report of the BSE Inquiry also noted that recycling animal protein carries a greater risk of spreading infection with a TSE when it is carried out within the same species. We recommend that consideration should be given to a complete ban on intra-species recycling and that no animal products should be fed to herbivores.
60. On the assumption that pigs do not carry TSEs, the pig industry has requested that pig MBM should be allowed to be fed to poultry. However, given the complexity of the chain of animal feed manufacture and previous problems of cross-contamination, we are not confident that, given the risks involved, adequate policing to maintain separation of feed streams for pigs and cattle could be assured or enforced. We accept SEAC's view45 that any infectivity in pig MBM fed to chickens would not be inactivated in the chicken intestine. If infected chicken tissues were then incorporated into pig feed it would amount to intra-species recycling.
61. The ban on mammalian MBM does not include use of blood, gelatin or tallow. This is based on advice from both the EU Scientific Veterinary Committee (now the SSC) and SEAC. In practice, although the feeding of mammalian blood products is permitted, little, if any, is thought to be used in livestock feed in the UK. Any bovine blood used would come from animals under 30 months old. Blood from animals slaughtered under the OTMS is rendered for disposal with other OTMS material. Blood from BSE suspect cases is not collected for use as such animals are not bled before incineration.
62. In light of recent research findings relating to the transmission of experimental BSE between sheep through blood transfusion, SEAC has reviewed the use of dried animal blood in animal feed. The Committee concluded that there was no evidence to suggest the presence of BSE activity in cattle blood. Given the conditions of use in feed described in paragraph 61 above, they concluded46 that any risks were extremely small and there was no need to change previous advice on blood in feed.
63. SEAC has also looked at the safety of gelatin and tallow. It noted47 that tallow and raw materials from gelatin production which could be used in animal feed in the UK were from cattle less than thirty months of age with all the specified risk material removed. The committee also noted that all tallow permitted in animal feed in the UK is subject to extreme processing. There are also restrictions on the sourcing of the raw material for gelatin. Because of these measures and the degree of processing, SEAC considered the risk to farm animals from tallow and gelatin in feed to be negligible. In fact, most gelatin used is of pig or fish origin.
64. Although SEAC has not recommended banning the use of blood, gelatin and tallow in animal feed, we have noted the uncertainties and concern surrounding the issue. Our recommendation at paragraph 59 above, about a ban on intra-species recycling, should include intra-species recycling of blood, gelatin and tallow.
65. Blood from animals which have passed the ante-mortem check at the abattoir (ie animals permitted to go for human consumption) is permitted to be spread on land. Such spreading is subject to certain waste management controls. SEAC is shortly to consider the safety issues involved in this method of disposal. We plan to revisit this issue once SEAC's advice is available, to assess any food safety implications.
66. One effect of the feed ban has been the loss of value of the products of rendering (i.e. mammalian MBM and tallow). Formerly the principal outlets for MBM were livestock feed and agricultural fertilisers, both of which are now closed although limited quantities of MBM may still be used in petfood and certain horticultural fertilisers. All tallow from the OTMS must be incinerated. "Clean" tallow of non- bovine origin, imported bovine tallow and bovine tallow produced in registered premises may still be used for non-food purposes (i.e. feed, cosmetics, pharmaceuticals, medical devices and technical uses). Other bovine tallow may be used for technical purposes only, though some may first be turned into derivatives by subjecting it to temperatures of 200°C at 40 bar pressure rendering them inert. However, tallow prepared from SRM must be landfilled unless it is burnt (usually as fuel). There is no public or animal health reason for the prohibition on the use of tallow derivatives prepared from SRM tallow. We consider that provision for their use should be reconsidered so that some value could be restored to the industry. We understand though that this would require agreement in Brussels before such a move could be made.
67. Having considered all these issues we see no likelihood or scope for relaxing the ban on feeding ruminant protein to ruminants. Experiments with heat and chemical treatments have shown how difficult it is to completely inactivate TSE agents. Even the "pressure cooking" rendering process can only reduce infectivity and not eliminate it. Other changes might therefore be considered in future only when:
(i) practical and sensitive diagnostic tests are available to distinguish ruminant from other mammalian material in animal feed;
(ii) it can be concluded that pigs and chickens fed with BSE and scrapie material do not carry infectivity in their tissues;
(iii) it can be demonstrated that stringent and enforceable segregation procedures are in place and can be maintained. Relevant experience in other EU Member States should be examined first; and
(iv) the UK achieves low BSE status.
These conditions should be monitored by the Food Standards Agency. Even if such changes can be made, it is unlikely that consumers would wish to buy meat from animals fed in this way. In the meantime, we recommend that non-feed use of inert tallow derivatives from SRM tallow should be considered but that intra-species recyling of blood, gelatin and tallow should not be permitted.
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43A study, not audited by the FSA, of the competitive position of the red meat industry in Great Britain in relation to the collection, processing and disposal of animal by-products both in Great Britain and other EU Member States (Meat and Livestock Commission, June 1998).
44 MAFF News Release 400/97, 17 December 1997
45 Letter of 20 December 1999 from Professor P G Smith, acting Chairman of SEAC, to Rt Hon Nick Brown MP, Minister of Agriculture, Fisheries and Food
46 SEAC press release, 19 October 2000
47 SEAC press release, [ ] October 1997