# Date: March 1, 2004

# To: Dr. Burt Pritchett

From: Dr. Dawn Capucille, Dr. Geoff Benson, Dr. Matt Poore

# 

# 

# As individuals that work closely with the cattle industry in North Carolina, we would like to voice our concerns regarding the proposed banning of recycled poultry bedding (aka: RPB, poultry litter) as a means of preventing transmission of Bovine Spongiform Encephalopathy.

# 

Dawn Capucille DVM, MS -- Beef Production

Geoff Benson, PhD -- Agricultural Economist

Matt Poore, PhD -- Extension Specialist, Ruminant Nutrition

It has been proposed that RPB be banned from feeding to ruminant animals
because it contains spilled feed that could contain ruminant proteins.
While this is clearly a potential source of ruminant proteins in
ruminant diets, a complete ban on RPB should be carefully considered
because of several factors.

1)  Recommendations of International Subcommittee -- The findings of the
    international subcommittee appointed by the USDA to review their
    investigation of the BSE case have recently been released. Pending
    final review of this document and further revisions of the UDSA
    rules, it would be appropriate to proceed more slowly with changes
    in feed rules.

2)  RPB has been shown to be a safe and economical feed source for
    ruminants and is widely used in the Southeastern US. A ban on
    feeding RPB would impose a financial burden on many cattle producers
    because replacement feedstuffs are more expensive. A ban would also
    impose costs on poultry producers because alternative uses or
    disposal methods must be found.

3)  A complete ban on feeding RPB is unnecessary because not all poultry
    feed contains ruminant proteins.

-   RPB from certified organic poultry producers does not pose any risk
    because feed can't contain animal protein and the producers have
    proof of this on-hand.

```{=html}
<!-- -->
```
-   Large poultry integrators can certify feed ingredients and some do
    not use ruminant proteins in their feed. Several in our area
    advertise that they do not feed their birds animal proteins. These
    growers have letters (or can obtain them) from their integrators
    indicating that their RPB is not a concern. Other integrators may
    decide to not use ruminant proteins due to the inability to
    otherwise dispose of the waste.

4)  It is not clear whether RPB could be used to fertilize pastures that
    would be grazed by ruminants because some RPB may be consumed by
    cows when it is applied to pasture. A ban on pasture application
    would be a natural extension of a feeding ban, and would create
    extreme nutrient management problems for poultry producers. Cattle
    on pasture will consume RPB for some time after pasture application
    such that an extended amount of time would need to be required
    between application and grazing, or RPB would need to be soil
    incorporated, which is a costly process. In many areas of poultry
    production there is insufficient tilled cropland available for
    application of RPB. In addition, personal communications with others
    in the poultry industry indicate that EPA is concerned about
    increased phosphorus load on cropland fertilized with RPB.

5)  Enforcement of an RPB ban would be difficult and costly. While
    controlling feed milling operations is a relatively simple issue,
    policing each farm that produces or utilizes RPB would be a
    monumental task. Also, controlling cross-contamination from anything
    in feed mills and transport vehicles would be very difficult.
    Removal of ruminant proteins from poultry feed would be much more
    enforceable and would eliminate the risks associated with feeding
    the RPB to cattle.

6)  Many poultry producers also raise cattle. Ensuring that cattle never
    have access (accidental or otherwise) to both poultry feed and RPB
    would be difficult for even the most conscientious producer.

In summary, there are important concerns about the need for,
practicality and economic impacts of a complete ban on feeding RPB to
ruminants. There are other potential solutions to this problem that may
be more practical and cost effective than banning RPB as a feed such as
removing ruminant proteins from some or all poultry feed. Some poultry
producers do not use ruminant proteins in their feed now, and others may
voluntarily adopt this practice to protect their growers from liability
associated with accidental consumption of either RPB or poultry feed, so
an overall ban would discriminate against these individuals. A thorough
investigation of impacts and alternatives is warranted before a ban is
enacted.

Contact information for authors:

Dr. Dawn Capucille, NC State College of Veterinary Medicine, Dept of
Population Health and Pathobiology, 4700 Hillsborough St., Raleigh, NC
27606 (919) 513-6244

Dr. Geoff Benson, NC State College of Agriculture and Life Science, Dept
of Agricultural and Resource Economics, Box 8109, Raleigh, NC 27695
(919) 515-5184

Dr. Matt Poore, NC State College of Agriculture and Life Science, Dept
of Animal Science, Box 7621, Raleigh, NC 27695 (919) 515-7798