Sludge Watch ==> More residuals problems - toxic distillers grain as animal feed

[Maureen Reilly]

Sludgewatch Admin:

Here is a little step sideways.  The food chain is not only in jepardy from 
sewage and papermill sludges.  Here is another industrial waste that is 
poised to poison our food.  While livestock have been eating distillers 
grain for a long time, the new distillers grain that is a byproduct of 
making ethanol is a more problematic material.

Feeding livestock on  distillers grain that was left over from making 
ethanol can concentrate toxins in our food.  Antibiotics, mycotoxins are 
only a few of the dangerous compounds found in distillers grain. And because 
there is so much distillers grain in the marketplace, livestock operators 
are making it as much as 82 percent of the feel of some animals..on a dry 
weight basis!

This whole discussion was new for me.  I think you will find it interesting. 
  We are now fertilizing our fields with our industrial wastes, and now we 
are feeding our livestock on the leavings of our fuel production.  It 
doesn't make good feed, but there is lots of it.

Have a read:
http://www.inspection.gc.ca/english/anima/feebet/consult/distillerse.shtml

And...then read how the US doesn't want Canada to make laws about feeding 
our livestock toxic industrial byproducts.

The Canadian regulations read:
No person shall manufacture, sell or import into Canada in contravention of 
the Regulations any feed that may adversely affect animal or human health

I don't know about you, but this looks like a regulation I would like to see 
enforced everywhere.
....................................................................

US National Grain and Feed Association (NGFA) Urges Canadian Agency to  Make 
Changes to Proposed Rules on Distillers Grains

http://www.ngfa.org/article.asp?article_id=9524at.

For Release
IMMEDIATE (April 8, 2008)

WASHINGTON – The National Grain and Feed Association (NGFA) has urged  the 
Canadian Food Inspection Agency (CFIA) to make several significant  changes 
to its draft regulatory policy governing the use in livestock  and poultry 
feed of distillers grains products derived as co-products  from fuel ethanol 
production.

In a statement this month to CFIA, the NGFA stressed the importance of  the 
agency developing sound science- and risk-based policies to  facilitate the 
safe production and use of feed ingredients, while  preserving efficient and 
fluid U.S-Canadian cross-border trade. Based  upon that yardstick, the NGFA 
said, several elements of CFIA’s draft  policy: 1) “exceed requirements 
necessary” to ensure the safe  production and use of distillers grains 
products; 2) are not in  harmony with current U.S. feed regulations 
applicable to such co- products; and 3) could inhibit cross-border trade.

Established in 1896, the NGFA consists of 900 grain, feed and feed  
ingredient, grain processing, exporting, biofuels and other grain- related 
companies that operate about 6,000 facilities and handle more  than 70 
percent of all U.S. grains and oilseeds. The NGFA is the  nation’s largest 
trade association representing commercial feed  interests, with more than 
350 member companies operating feed mills  and feed ingredient manufacturing 
operations, as well as 30 integrated  livestock and poultry feed companies.

CFIA’s review of the matter began in late 2007, when it issued a  notice to 
the Canadian feed industry stating that distillers grains co- products 
derived from fuel ethanol production are not considered to be  approved for 
use in animal feed under current Canadian feed  regulations, since the 
“manufacturing processes which generate fuel  ethanol products differ from 
those of alcohol for human consumption;  the differences stem from the use 
of non-food-grade starting  materials, different sources of enzymes, or 
processing aids.” In so  doing, CFIA also stated its intent to conduct a 
safety evaluation of  distillers grains and to use the resulting information 
to develop  distillers grains definitions representative of products 
currently  being manufactured, as well as a comprehensive policy document on 
  distillers grains derived from fuel ethanol production. That, in turn,  
led to subsequent discussions between CFIA and the Canadian feed  industry, 
and resulted in CFIA’s development of a draft regulatory  policy.

In its statement responding to the CFIA draft policy, the NGFA cited  the 
following specific concerns:

    * Use of Antimicrobial Drugs in Ethanol-Fermentation Process: The  NGFA 
urged the CFIA to limit, for the time being, the use of  antimicrobial drugs 
allowed during fuel-ethanol fermentation. CFIA  proposed to set maximum 
inclusion rates for four approved  antimicrobial drugs: penicillin (1 part 
per million), streptomycin  (2.7 p.p.m.), ampicillin (4 p.p.m.) and 
virginiamycin (6 p.p.m.). The  NGFA asked CFIA for the time being to limit 
the approved use of  antimicrobial drugs to virginiamycin – the 
antimicrobial found in the  only approved product currently recognized by 
the U.S. Food and Drug  Administration (FDA) for use by fuel ethanol 
producers in the United  States. “The potential use of antimicrobial drugs 
by Canadian fuel  ethanol producers not approved by FDA could cause 
cross-border trade  disruptions if the resulting distillers grains products 
are exported  to the United States,” the NGFA said. The NGFA also 
recommended that  CFIA and FDA work collaboratively to harmonize additional  
antimicrobial products approved for use in fuel-ethanol fermentation.

    * Fermentation Microorganisms, Enzymes and Processing Aids Used  in 
Producing Distillers Grains: The NGFA strongly urged CFIA to revise  its 
proposed policy to officially recognize those fermentation  microorganisms, 
enzymes and processing aids approved by FDA for use in  producing human 
beverage alcohol as being acceptable for use by  ethanol producers in the 
manufacture of distillers grain co-products.  CFIA proposed that such 
microorganisms, enzymes and processing aids be  subjected to independent 
review and approval by a Canadian  governmental body, such as Environment 
Canada, Health Canada or CFIA.

    * Sulfur: The NGFA urged CFIA to eliminate its proposal to  require that 
labels of distillers grain products contain a maximum  sulfur guarantee. The 
NGFA cited the following reasons: 1) The CFIA  proposal, by addressing just 
one potential ingredient of an animal’s  diet (distillers grains products), 
does not address the relevance for  feed manufacturers and livestock/poultry 
feeders of determining the  total dietary sulfur intake of an animal, which 
is the crucial factor  in determining whether sulfur levels are excessive 
for a given  species; 2) other feed ingredients, such as canola meal, 
typically  have similar or greater sulfur content than distillers grains  
products, but are not subject to mandatory maximum sulfur guarantee  
labeling requirements by CFIA; and 3) U.S. state feed regulations,  with the 
sole exception of South Dakota, currently do not require a  maximum sulfur 
guarantee on labels of distillers grains products.

      “As proposed, CFIA’s policy would place a negative connotation  only 
on distillers grains products by making them the only group of  feed 
ingredients with a required maximum sulfur label guarantee,” the  NGFA 
noted. “(Further), the CFIA policy would obligate U.S. firms that  export 
distiller’s grains products to Canada to take additional  actions to label 
products with required guarantees, thereby increasing  the cost of doing 
business and making cross-border trade more  difficult.”

    * Proposed Ingredient Definition for Distillers Grains: The NGFA  also 
urged CFIA to modify its proposed feed ingredient definition for  
“distillers grains dehydrated derived from fuel ethanol” to remove  
references that such products be labeled with guarantees for maximum  
moisture, maximum sulfur, maximum sodium and maximum phosphorus. The  NGFA 
maintained that such label guarantees are inappropriate for  distillers 
grain co-products because: 1) they are not required for a  variety of other 
feed ingredients that contain similar or greater  concentrations of sodium 
or phosphorus; and 2) the Association of  American Feed Control Officials’ 
(AAFCO) model feed regulations and  virtually all U.S. state feed laws 
require labels of distillers grains  products to contain guarantees only for 
minimum crude protein, minimum  crude fat and maximum crude fiber. Exceeding 
this requirement, as  proposed by CFIA, would require additional label 
guarantees for  moisture, sodium and phosphorus solely for exported 
distillers grains  products destined for Canada, thereby creating additional 
labeling  costs and potential cross-border trade disruptions.

The NGFA’s membership encompasses all sectors of the industry,  including 
country, terminal and export elevators; feed manufacturers;  cash grain and 
feed merchants; end users of grain and grain products,  including 
processors, flour millers, and livestock and poultry  integrators; commodity 
futures brokers and commission merchants; and  allied industries. Canadian 
and Mexican firms also are NGFA members,  and use its Trade Rules and 
Arbitration System by specific reference  in their contracts.

The NGFA also consists of 35 affiliated state and regional grain and  feed 
associations, as well as two international affiliated  associations. It has 
strategic alliances with the Pet Food Institute  and the Grain Elevator and 
Processing Society, and is co-located and  has a joint operating and 
services agreement with the North American  Export Grain Association.