Opinion of the European Economic and Social Committee on the Disposal of animal carcasses and the use of animal by-products
Date: 2006-09-14
Institutions: European Economic and Social Committee
Subjects: animal nutrition, animal product, by-product, carcase, cereal substitute, food safety, public health, waste management

23.12.2006

EN

Official Journal of the European Union

C 318/109

Opinion of the European Economic and Social Committee on the Disposal of animal carcasses and
the use of animal by-products

(2006/C 318/18)

On 19 January 2006, the European Economic and Social Committee, acting under Rule 29(2) of its Rules of
Procedure, decided to draw up on the Disposal of animal carcasses and the use of animal by-products.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing
the Committee's work on the subject, adopted its opinion on 11 July 2006. The rapporteur was
Ms Santiago.

At its 429 plenary session, held on 13 and 14 September 2006 (meeting of 14 September 2006), the Euro-
pean Economic and Social Committee adopted the following opinion by 115 votes to 32 with
16 abstentions.

1. Conclusions

farms and safeguarding the health safety of the livestock and the
health of the farmers themselves.

the food that

1.1
Information has a crucial role to play in society, and
consumers have the right to accurate and timely information on
they eat. The EESC therefore
the quality of
considers that appropriate consumer information campaigns are
needed. The EESC reaffirms that protecting public health and
ensuring food safety in European production is one of its funda-
mental priorities.

The EESC suggests

1.2
the European Commission
that
pursue and step up as swiftly as possible the studies currently
under way which clearly show that the use of meat meal from
non-ruminants can be used in pig and poultry feed without
posing any danger to human health.

1.2.1
The way in which proteins are identified and the
methods used to trace the meat meal in which they are found
must give consumers a cast-iron guarantee that pigs are fed on
meat meal obtained exclusively from the by-products of poultry,
and that poultry is fed on meat meal obtained exclusively from
the by-products of pigs.

1.2.1.1
As soon as the current studies have been completed,
by-products from these (healthy) animals, which have been
slaughtered in separate abattoirs, should be used in the produc-
tion of meat meal, the protein in which is clearly identifiable
and fully traceable.

Establishing research programmes to develop methods of
1.3
destroying carcasses on-site is vital for preventing the possible
spread of diseases when carcasses are being transported.

2. Introduction

Six years after the BSE crisis, the Committee felt it would
2.1
be timely to re-examine the issue of carcass disposal and the use
of
food safety,
consumer health protection and the economic problems faced
by producers.

taking into account

animal by-products,

2.1.1
Safety standards for food production are much higher
in Europe than in third countries, but they do guarantee food
safety for consumers, environmental protection and animal
welfare. Maintaining these standards, with the higher production
costs that
they entail, will only be possible if production
continues in Europe.

2.2
Before the BSE crisis, destroying animal carcasses on pig
farms did not pose a problem for producers, because dead
animals could be used in the production of meat meal, which
in various
would then be used in animal feed. Consequently,
countries, producers of meat meal would collect carcasses free
of charge.

As a result of the BSE crisis and in the wake of the Euro-
2.3
pean Parliament
and Council Regulation 1774/2002 of
3 October, not only was the use of meat meal in animal feed
banned, but animal carcasses were also considered to be cate-
gory 2 risk material,
requiring them to be collected and
destroyed by incineration, and this only by undertakings
licensed for this purpose.

1.4
The EESC recommends promoting research into systems
— if possible, energy-producing systems — for processing all
farm by-products and waste, with a view to standardising
production methods, whilst protecting the environment in the
short and medium term, ensuring the economic balance of

2.4
As might be expected, this situation entailed further costs
for producers and thus increased distortion of competition vis-
à-vis third countries. This led producers to seek alternatives that
were less damaging to the sector's economy but still effective in
terms of biosafety and the environment.

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The current

trend in business is for an open global
2.5
market, where the only law is that of supply and demand. We
in Europe, however, have been the victims of a terrible distor-
tion of competition, because various technical and scientific
decisions have resulted in political stances that make our
production costs significantly higher than in third countries.

destroying animal carcasses are allowed to continue. The fact
cannot be ignored that collection costs in these areas would be
extremely high. Two further derogations are included:

— dead pet animals may be directly disposed of as waste by

burial;

2.6
One example of this is Council Decision 766/2000/EC of
4 December 2000, Article 2(1) of which prohibits the use of
animal proteins in animal feed in all Member States. This deci-
sion applied to all animal species. European Parliament and
Council Regulation 1774/2002 of 3 October 2002 (Article 22
(1)(a)) consolidates and broadens the scope of this ban.

— animal by-products may be disposed of as waste by burning
or burial on site in the event of an outbreak of a disease
mentioned in List A of the International Office of Epizootic
Diseases (OIE),
the competent authority considers that
transporting the carcasses entails a risk of propagating
disease or when the nearest processing plant does not have
the necessary capacity.

if

2.7
The crisis unleashed by the emergence of BSE in cattle
and its link with Transmissible Spongiform Encephalopathies
understandably affected intensive production sectors (pig and
poultry breeding) which receive no aid or production premium,
operate on very narrow margins and face major barriers to their
development due to legislation on the environment, animal
welfare and health issues.

3.1.3
Today there is a growing need to locate farms as far as
possible from human settlements and also from one another,
wherever this is feasible. Consequently, farmers increasingly seek
out remote locations so as not to trouble neighbours and to
protect the health of their stock.

The ban on the use of meat meal dealt the sector a
2.8
major blow, because it lost a major source of protein for feed
and the price of vegetable protein shot up due to increased
demand. Consequently, the price of feed rose sharply. Slaughter-
house by-products also went from being a source of additional
profit to constituting a financial burden; this factor, combined
with the higher price of meat meal,
inevitably led to higher
prices for the consumer.

3. General comments

3.1 Legal aspects and technical and scientific contradictions relating to

the disposal of pig carcasses

3.1.1
Regulation 1774/2002, which made it compulsory for
carcasses to be collected and destroyed by accredited undertak-
ings and which prohibited the use of animal proteins, not only
caused financial difficulties for producers in countries already
implementing this system;
it also led to much more serious
problems in those countries that did not have this system in
place, because they were then forced to implement it, incurring
even higher costs. This situation caused producers in those
countries to wonder whether the regulation was really intended
to compensate by-product processors for the ban on selling
meat meal.

3.1.4
As stated above, the process of collecting carcasses is
extremely expensive, hence the attempts to find solutions that
go further than the proposals contained in the regulation and
which reflect the reality of the situation today. When consid-
ering these options, certain factors must always be borne in
mind: human health and safety, animal health and welfare and
environmental protection.

3.2 Legal aspects and technical and scientific contradictions relating to

the use of meat meal

3.2.1
There is no scientific evidence that pigs and poultry are
at any risk of contamination from BSE. Pigs and poultry in the
United Kingdom have undeniably been exposed to the bovine
spongiform encephalopathy (BSE)
(prions).
Despite being fed the same animal protein that caused BSE in
cattle, there has not been a single case of contamination in
animals of either species. Studies of domestic chickens indicate
that they are resistant to infection by both parenteral and oral
challenge (1).

infectious agent

3.2.2
On issues relating to consumer health protection and
safety, the Commission is adopting risk-control measures based
on the most recent test results available and on a solid scientific
assessment such as that provided in the guidelines drawn up by
the Scientific Steering Committee (SSC). The SSC itself is assisted
by an Ad-Hoc Transmissible Spongiform/Bovine Spongiform
Encephalopathy group, made up of scientists from across the
EU.

3.1.2
The issue takes on even greater significance given that
this regulation includes a derogation for remote areas with low
for
animal population density, where traditional methods

(1) (D. Matthews and B. C. Cooke, Rev. Sci. Tecl. Int. Eprit. 2003, 22(1),
283 — 296). Another key study is: Poultry, pig and the risk of BSE
following the feed ban in France — a spatial analysis. Abrial D, Calavas
D, Jarrige N, Ducrot C; Vet. Res. 36 (2005) pp. 615-628.

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3.2.3
revealed in the following work:

The limitations of our understanding of TSE are

— A scientific study on ‘Oral exposure of humans to the BSE
agent: infective dose and species barrier’, adopted by the SSC at
its meeting of 13 and 14 April 2000.

— A scientific report on ‘the safety of meat-and-bone meal derived
from mammalian animals fed to non-ruminant food producing
farm animals’, SSC Meeting of 24-25 September 1998.

3.2.4
study:

The issue of TSE in pigs was also the subject of an SSC

— A scientific study adopted by the SSC at its meeting of 24

and 25 June 1999 on ‘fallen stock and dead animals’.

— A scientific study on‘the risk born (sic) by recycling animal by-
products as feed with regard to propagating TSE in non-ruminant
farmed animals’, SSC 17 September 1999.

— A scientific study on the use of animal proteins in feed for
all animals, adopted by the SSC at its meeting of 27 and
28 November 2000.

3.2.5
In a nutshell, the conclusion that we can draw from all
of these scientific studies is that no epidemiological proof exists
for the theory that pigs, poultry or fish are susceptible to
contracting BSE or that these species have been affected by BSE.
To date, no scientific tests have demonstrated the development
of TSE in pigs, poultry or fish.

3.3 Analysis of the problems and the possibility of processing by-

products on farms

3.3.1
farms must be adopted,
animal welfare and due regard for the environment.

A global approach to processing waste from livestock
incorporating food safety, health,

3.3.2
The EU produces more than 170 million tonnes of
farm waste every year (2). Managing a modern livestock farm is
an extremely complex task, and what to do with the waste is
one aspect of this. With regard to processing carcasses, more
efficient and cost-effective disposal methods must be found.

(2) Table 1 — List of zootechnical waste (EU15) — Source EUROSTAT/

MAPYA 2003.

The issue of disposing of animal carcasses is extremely
3.3.3
complex because, whilst account must be taken of the environ-
ment, we must also consider the possibility of diseases being
transmitted during transportation. There are also issues of
hygiene, safety and public health (3).

3.3.4 With this work we hope to expand the range of
options
for producers, whilst upholding the principle of
protecting public health and the environment. We therefore
suggest hydrolysis, together with any method that meets the
requirements set out above, which must also be considered (4).

Hydrolysis, as

In the case of pork, esterification of

the primary method of processing
3.3.5
is biologically identical to the hydrolysis of
animal carcasses,
other organic matter likely to degrade unaided under controlled
conditions. The biochemical path followed by hydrolysis is
determined by the substance's capacity for autolysis. Basically,
the proteins decompose, producing amino acids, with the carbo-
hydrates producing sugars and the lipids producing fatty acids
and alcohol.
the fatty
matter results in the hydrolysed matter ultimately taking on a
dense, viscous appearance with flow characteristics equivalent to
viscous liquid, which is an additional advantage when it comes
to processing it under controlled conditions and makes it easier
to handle the resulting fluid. To make hydrolysis more effective,
some factors must be controlled, such as particle size (which
requires carcasses to have been ground down in advance),
temperature, duration of processing and the oxygen content in
the atmosphere surrounding the process, in order to prevent the
release of unpleasant smells. The liquid produced by hydrolysis
can then be processed with the farm's slurry, with the added
advantages of:

— biosafety (carcasses are processed on the farm itself under
reducing the possibility of

controlled conditions,
diseases being transmitted to other farms);

thus

— making the traditional slurry disposal process more efficient;

— eliminating pathogenic elements;

— improving farm management, because carcasses and slurry

are processed on-site and in real time (5).

(3) Table 2 — Quantifying waste and by-products from farm animals

(Source EUROSTAT/MAPYA).

(4) — Risk assessment: use of composting and biogas treatment to
dispose of catering waste containing meat (Final report to the
department for Environment, Food and Rural Affairs). Gale P.
(2002). In http://www.defra.gov.uk/animalh/by-prods/publicat/
— Informe final relativo a los resultados obtenidos en los proyectos
de estudio de alternativas a sistemas de cadáveres [Final report on
results obtained in research projects on alternatives to carcass-
based systems]. Antonio Muñoz Luna, Guillermo Ramis Vidal,
Francisco José Pallarés Martínez, Antonio Rouco Yáñez, Francisco
Tristán Lozano,
Jorge Barrera, Miriam
Lorenzo Navarro, Juan José Quereda Torres. (2006).

Jesús Martínez Almela,

(5) Studies in this field:

— Informe final de resultados sobre la hidrolización de cadáveres
animales no ruminantes: experiencia en ganado porcino. [Final
report on the hydrolysis of non-ruminant animal carcasses: an
experiment on pigs]. Lobera JB, González M, Sáez J, Montes A,
Clemente P, Quiles A, Crespo F, Alonso F, Carrizosa JA, Andujar
M, Martínez D, Gutiérrez C.

— Parámetros Físico-químicos y bacteriológicos de la hidrolización de cadá-
veres de animales no ruminantes con bioactivadores [Physical and
bacteriological parameters of
the hydrolisis of non-ruminant animal
carcasses with bioactivators]. Gutiérres C, Fernández F, Andujar M,
Martín J, Clemente P, Lobera JB CARM-IMIDA. http://wsiam.
carm.es/imida/publicaciones%20pdf/Ganader%EDa/Gesti%F3n%
20de%20Residuos%20Ganaderos/Hidrolizaci%F3n%20de%20Cad
%E1veres/Resultados%20del%20Estudio%20Preliminar.pdf.

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Producing energy by means of biogas is important and,
3.3.6
to this end, interconnecting tanks can be used, preventing back-
flow or contact with the atmosphere. Also of great interest,
however,
is studying simpler processes that are suitable for
smaller farms and which also guarantee public health generally
and on farms, and protect the environment.

4. Specific comments

4.1
Information plays a crucial role in society today. Consu-
mers have the right to be fully and accurately informed, which
rarely happens, because the media always prefer to report disas-
ters and accidents whilst positive developments are given scant
coverage. We must, therefore, work hard to inform consumers
about all of the work being done in public health so that they
can make informed choices about what they think is best.

4.2 Economic consequences of eliminating animal carcasses and waste

4.2.1
The disposal of carcasses is causing a number of logis-
tical problems (in countries not previously implementing the
collection system) and in some cases, collection is incompatible
with good practice for health protection on farms.

4.3 Economic impact on the use of animal by-products

Banning the use of animal protein in feedingstuffs for pigs,
poultry and fish has led to significantly higher production costs
in Europe and has consequently caused further problems of
distortion of competition vis-à-vis other countries such as
Brazil, Argentina and the USA, for example, where the use of
animal protein is authorised. These higher costs have had conse-
quences at various levels, with slaughterhouse by-products no
longer being a benefit, because they now entail destruction
costs, and with increased demand for vegetable protein leading
to higher prices and consequently higher feed prices (8).

4.3.1
third countries for:

In real terms, EU production costs are higher than in

Destruction of by-products:

EUR 6 per 100 kg of pig
carcasses (9)

Non-use of animal meal:

EUR 0.75 per 100 kg (10)

Increase in soya price:

EUR 1.5 per 100 kg (11)

4.2.2
must be analysed in two specific cases:

The economic impact of

the Community directive

In countries where there was previously no collection
4.2.2.1
of carcasses, investment will be needed by farms (for building
cold-storage units and establishing safe carcass collection plans),
by transport companies, which will have to acquire lorries
specially equipped for the task and by by-product processing
plants, which will have to make changes in order to be able to
process entire animals (6).

4.2.2.2
In countries that have already established carcass
collection systems, there is no need for further investment, but
where meat meal cannot be used, the costs of its collection and
destruction must be covered (7).

(6) Calculations have been made suggesting an increase in production
costs of between EUR 0.36 and EUR 0.96 per animal produced,
depending on the location and size of the farm, although it is certain
that the smallest farms will always be the most heavily penalised.

(7) The product consequently entails an additional cost varying between

EUR 0.3 and EUR 0.5 per animal produced.

a

figures

represent

total Community-wide

When multiplied by the number of pigs produced annually,
these
loss of
EUR 173 million. To this increase in costs, we can add a set of
production factors such as feed, energy, labour, animal welfare
and environmental standards, which mean that one kg of pork
carcass costs EUR 0.648 in Brazil (12), compared to EUR 1.25 in
the EU (13).

This distortion of competition can never be openly
4.3.2
discussed in WTO negotiations, because it would immediately
be refuted, since no scientific evidence has been produced to
support it. If this situation continues, we will have to compen-
sate European producers or we will be threatening their
survival.

(8) Studies carried out by the University of Múrcia working group, led by

Prof. Dr. António Muñoz Luna, DMV, PhD, MBA.

(9) Source: National Institute for Agricultural Research (INRA).
(10) Calculated on the basis of the average price of raw materials before and

after the ban, on an average diet for a fattening pig.

(11) Idem 10.
(12) Production costs for a farm of 1200 pigs in a closed cycle with a
productivity of 20.3 suckling pigs per sow per year in the state of
Paraná.

(13) A farm with 500 pigs in closed cycle with a productivity of 23 suckling

pigs per sow per year in Portugal.

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4.5 The final obstacle to reincorporating non-ruminant meat meal

into feed for pigs and poultry

4.5.1
Currently, all that is needed is to develop techniques
capable of distinguishing pork protein from poultry protein, to
comply with another request from the European Parliament,
namely to ensure that no cannibalism takes place. It is incorrect,
in the context of meat meal, to talk about ‘cannibalism’. Canni-
balism refers to direct consumption and can only occur acciden-
tally on some farms. Talking about cannibalism in relation to
amino acids and fatty acids is, therefore, unacceptable.

4.5.2
In any event, regardless of the above comments, there
is now a real opportunity to set up a mechanism to monitor
systems exclusively supplying pork protein for poultry feed and
vice versa, because:

— meat meal from pigs and meat meal from poultry can never
the same slaughterhouse, because these

be produced at
species require different slaughtering facilities;

— since some plants produce only poultry feed and others
only pig feed, the two can never be accidentally mixed;

— the same applies to plants that have separate production

lines for different species.

The President

of the European Economic and Social Committee

Anne-Marie SIGMUND

4.4 Issues to take into account when considering the possibility of
lifting the ban on the use of meat meal from non-ruminants in
pig and poultry feed

4.4.1
The main issue is to ensure that there is no cross-
contamination in meat meal. A group of researchers from a
range of Belgian bodies was therefore asked to study and imple-
ment various techniques that would make it possible to deter-
mine the presence of animal protein from ruminants in feed.
This group satisfactorily completed its work in the first half of
2004, with DG SANCO issuing
report dated
24 September 2004, entitled ‘Determination of Processed
Animal Proteins Including Meat and bone Meal in Feed’, which
sets out methods for ensuring that
these proteins can be
detected in feed. This could now help us to establish production
systems for fully traceable non-ruminant meat meal (in other
words, protein whose origin would be easy to determine) which
is also monitored. This could enable us to establish an initial set
of systems for producing and reincorporating these ingredients,
with firm guarantees that these contain no meal from rumi-
nants (14).

final

a

Brussels, 14 September 2006.

(14) Other studies addressing this matter:

— Effective PCR detection of animal species in highly processed
animal by-products and compound feeds. Fumière O, Dubois M,
Baeten V, von Holst C, Berben G. Anal Bioanal Chem (2006)
385: 1045-1054.

— Identification of Species-specific DNA in feedstuffs. Krcmar P,

Rencova E.; J. Agric. Food Chem. 2003, 51, 7655-7658.

— Species-specific PCR for the identification of ovine, porcine and
chicken species in meat and bone meal
(MBM). Lahiff S,
Glennon M, O'Brien L, Lyng J, Smith T, Maher M, Shilton N.
Molecular and Cellular Probes (2001) 15, 27-35.