Open letter to China and the U.S. Cattle Industry regarding Chicken Feces in Cow Feed
- From: Soylent Brown <soylentbrown@xxxxxxxxx>
- Date: Tue, 23 Oct 2007 11:08:15 -0700
October 21, 2007
TO:
The Embassy of the People's Republic of China in the United States of
America
3200 Connecticut Avenue N.W.
Washington, D.C. 20008, U.S.A.
Phone: 202-328-2587, 202-328-2515
Fax: 202-588-0046
Email: chinaembassy...@xxxxxxxxxxxx
Mr. Terry Stokes, CEO
National Cattlemen's Beef Association
9110 East Nichols Ave, Suite 300
Centennial, Colorado 80112
Phone: 303-850-3310
Fax: 303-694-7372
Email: tsto...@xxxxxxxx
FROM:
Dr. Robert Ben Mitchell, D.O.
16375 N.E. 18th Avenue, Suite 310
North Miami Beach, FL 33162
Phone: 786-262-5750
Fax: (none)
Email: DrRBMitch...@xxxxxxxxx
REGARDING:
An open letter to the United States Cattle Industry and The People's
Republic of China for the purpose of addressing the practice of
recycling animal feces into the human food chain.
To whom it may concern,
As a United States citizen, I respectfully present the following
information and questions as an expression of my first amendment
rights. The information herein has been taken from the public
domain,
with internet citations given whenever possible.
I am a licensed Osteopathic Physician, currently practicing in North
Miami Beach, Florida. As part of my profession, I am constantly
studying issues regarding health and healthcare. It was
inadvertently
during these studies that approximately six months ago I was
introduced to the topic of recycling animal feces into the human food
chain. This is a topic which, in the United States, is predominantly
practiced with regards to cattle, swine and chicken feces. However,
for the purpose of this letter, my discussion will be limited to the
recycling of chicken feces as a source of protein in cattle feed.
Please note that throughout this letter, the following terms will be
synonymous and used interchangeably. Poultry means chickens. Feces,
excrement, dung, and manure will all refer to the excretions from
chicken intestinal tracts. Urine and urea will refer to the
excretions from chicken urinary tracts. Waste may refer to
excretions
from either chicken intestinal and/or urinary tracts. Litter (i.e. -
poultry litter) refers to droppings on chicken breeding,
manufacturing, and processing floors, including but not limited to
feces, urine, feathers, discarded feed and other forms of waste.
It is a currently acceptable practice within the United States Cattle
Industry to feed chicken feces to cows as a source of inexpensive
protein. The United States Food and Drug Administration (FDA) does
not currently publish a position on this practice. However, its 1998
statement on this topic has been preserved at:
http://www.ehso.com/ehshome/FoodSafety/chickenmanurefda.htm
The following three quotations were directly taken, unedited, from
this site:
"Recycled animal waste is a processed feed product for livestock
derived from animal manure or a mixture of manure and litter. Animal
wastes contain significant percentages of protein, fiber, and
essential minerals and have been deliberately incorporated into
animal
diets for their nutrient properties for almost 40 years.
Incorporation
of this product into animal diets is a viable alternative to land
application or land fill."
"Although not officially recognized by FDA, the Agency regards the
AAFCO definitions as generally constituting the common or usual names
for animal feed ingredients."
"AAFCO is an organization of State, Dominion, Federal, or other
government agencies on the North American continent that works to
oversee the regulation of animal feed and seeks to achieve
uniformity.
FDA´s Center for Veterinary Medicine is a very active participant in
this organization. AAFCO has developed feed ingredient definitions
and
model regulations that States may use to regulate the manufacture,
labeling, distribution, and sale of animal feeds."
Mr. Shannon Jorde (phone: 240-276-9229) of the FDA's Center for
Veterinary Medicine Division of Compliance is an advisor to the
Association of American Feed Control Officials (AAFCO). AAFCO can be
located on the internet at:
www.AAFCO.org
The use of feces and urine as feed was most recently documented in
AAFCO's 2007 Official Publication. In the section titled "Feed
Ingredient Definitions", the following items are listed (where
available, I have included IFN reference numbers):
1. Hydrolyzed Whole Poultry (ingredient #9.58, page #261). This is
the
whole chicken carcass, including entrails and their contents.
2. Hydrolyzed Poultry By-Products Aggregate (ingredient #9.59, page
#261). This includes by-products of slaughtered chickens, including
the intestines and their contents.
3. Paunch Product, Dehydrated (ingredient #60.24, page #323). This is
the contents of the upper intestinal tracts from cattle (IFN
1-09-327).
4. Urea (ingredient #66.1, page #328). This is a subclass of Non-
Protein Nitrogen (NPN = ingredient #66) that is predominately derived
from animal urine (IFN 5- 05-070).
5. Dried Poultry Waste - DPW (ingredient #74.1, page #335). This is
chicken feces with or without urine (IFN 4-07-255).
6. Dried Poultry Waste - NPN Extracted (ingredient #74.2, page #335).
This is chicken feces with the intermingled urine mostly removed (for
NPN see Urea, above) (IFN 4-07-255).
7. Dried Poultry Litter - DPL (ingredient #74.3, page #335). This is
chicken feces intermingled with floor waste such as feathers, dropped
feed, etc. (IFN 5-05-587).
8. Dried Ruminant Waste - DRW (ingredient #74.4, page #335). This is
cow feces with or without urine (IFN 1-07-526).
9. Dried Swine Waste - DSW (ingredient #74.5, page #335). This is pig
feces with or without urine (IFN 5-02-790).
10. Undried Processed Animal Waste Products (ingredient #74.6, page
#336). Any non-human feces with or without urine (IFN 2-07-258).
11. Processed Animal Waste Derivative (ingredient #74.7, page #336)
Any non-human feces with or without urine that has been treated by
chemical, physical or microbiological means (IFN 1-07-307).
Though items 3, 8, and 9 do not directly concern chicken waste, they
are included here to display the breadth of this practice throughout
the livestock industry.
While the practice of recycling animal waste can be documented back
to
the mid 1900's in the United States, and its use has escalated
dramatically since the turn of this century, raw data on this
practice
is hard to come by. FDA form #3537 (updated 05/07), the "DHHS/FDA
Food Facility Registration Form," is a prime example of this. The
form itself is available on the internet at:
http://www.cfsan.fda.gov/~furls/nfm3537.pdf
In section 11B on page 6 of this form, registrants may select from 26
different types of product categories of foods for animal
consumption. Number 20 of these 26 categories is titled "Recycled
Animal Waste Products." I contacted the FDA regarding this form and
requested a list of the individuals and/or corporations who had
checked off this box as part of their registration with the FDA.
Assuming that this would be public information obtainable by a
Freedom
of Information Act request, if need be, I was astonished to be told
that the FDA would not release this information to the public as it
had been classified as a homeland security issue.
Fortunately, some data about chicken feces in cow feed still exists
in
the public domain. Several 1997 news articles about this issue have
been preserved at the following site:
http://www.ehso.com/ehshome/FoodSafety/chickenmanurenews.php
Amongst these articles, on October 1st of 1997, Reuters published a
story titled, "U.S. Group Says Ban Chicken Manure as Cattle Feed."
In
it, the article states that "18 per cent of Arkansas chicken farmers
together feed about 2.6 million pounds of chicken manure to cattle
each year."
By comparison, this year, Amy Sapkota (phone: 301-405-1772) and her
colleagues at the John Hopkins Center for a Livable Future and the
University of Maryland published a paper titled "What Do We Feed to
Food-Production Animals? A Review of Animal Feed Ingredients and
Their
Potential Impacts on Human Health." It is available online at:
http://www.pubmedcentral.nih.gov/articlerender.fcgi?artid=1867957
In the section of this paper titled "Animal Feed Ingredients and
Feeding Practices," they state that "in 2003, it was estimated that
approximately 1 million tons of poultry litter were produced annually
in Florida, and an estimated 350,000 tons of this litter were
available for use in feed." That means that from 1997 to 2003, using
an interstate comparison, there was a 269 fold or 26,900% increase in
the use of chicken feces as cattle feed from 2.6 to 700 million
pounds
(350,000 tons equals 700 million pounds).
This practice is by no means limited to just Arkansas and Florida, as
even the State of Texas documents it on their "Office of the Texas
State Chemist Feed License Application," which is available online at
http://otscweb.tamu.edu/New%20Feed%20License%20Application%2011-06.pdf
On page 1 of this form, in section 2 which is titled "Type of
Operation," one of the three options available is "Distributes
products containing toxins, chemical adulterants, or poultry litter."
It is of interest to note that the current President of AAFCO, Mr.
Ricky R. Schroeder, is also the Supervisor of Feed and Fertilizer
Registration at the Office of the Texas State Chemist (phone:
979-845-1121, ext 114).
Dr. Michael Greger, M.D., (phone: 202-676-2361) works for the Humane
Society of the United States. His 2006 book "Bird Flu: a Virus of
Our
Own Hatching" is available to read on the internet. Of particular
interest is chapter 2, part 3, section D, titled "Offal Truth," which
is available online at:
http://birdflubook.com/a.php?id=53
It is here that Dr. Greger makes the following statements (Dr.
Greger's cited reference numbers 1106 through 115 have been omitted):
"Ecologists assert that animal fecal wastes pose public health risks
"similar to those of human wastes and should be treated accordingly,"
yet in animal agriculture today, fecal wastes are fed to other
animals. Although excrement from other species is fed to livestock in
the United States, chicken droppings are considered more nutritious
for cows than pig feces or cattle dung. Because poultry litter can
be
as much as eight times cheaper than foodstuffs like alfalfa, the U.S.
cattle industry feeds poultry litter to cattle. A thousand chickens
can make enough waste to feed a growing calf year round."
"A single cow can eat as much as three tons of poultry waste a year,
yet the manure does not seem to affect the taste of the subsequent
milk or meat. Taste panels have found little difference in the
tenderness, juiciness, and flavor of cattle from steers fed up to 50%
poultry litter. Cattle from animals fed bird droppings may in fact
even be more juicy and tender. Cows are typically not given feed
containing more than 80% poultry litter, though, since it's not as
palatable and may not fully meet protein and energy needs."
Given the extraordinary amount of online internet data which
demonstrates the pervasive use of chicken feces as a protein source
in
American cattle feed, one must ask about the possibility of health
risks associated with such practices. While no deaths have yet been
directly linked to this practice, it is of particular note that there
is no indication that anyone either inside or outside the industry is
considering the consequences of using such feed ingredients. The
analogy between the current state of affairs and the decades of
denial
which preceded the Tobacco Industry's admission to the link between
smoking and cancer is not unnoticed.
During the 1997 concerns over BSE, commonly known as Mad Cow disease,
the FDA wrote that they were "unaware of any research on this issue
that would indicate that the agency should take regulatory action on
poultry litter at this time." This quote comes directly from the
United States Federal Register, volume 62, number 108, page 30940 (at
the top of the left most column; date: Thursday, June 5, 1997). It
is
available online at:
http://www.fda.gov/cvm/Images/6597bse.pdf
The consumption of feces can lead to a number of diseases. This route
for spreading disease is commonly called fecal-oral transmission, and
it can be responsible for many illnesses in humans, including but not
limited to the following:
AIDS
Cholera
Giardiasis
Hepatitis A
Hepatitis E
Polio
Shigellosis (bacillary dysentery)
Typhoid fever
Vibrio parahaemolyticus infections
Bird flu will likely be added to this list once it has made a notable
footprint upon human health. In addition, many of these diseases are
viral and untreatable by antibiotics. So why would we assume that it
is safe to feed chicken feces to cows?
AAFCO and many State regulatory agencies in the United States have
adopted several strategies to turn "dirty" feces into "clean" feces.
The most common of these practices is a technique called stacking or
dry-stacking, in which the chicken feces is stacked in a pile, much
in
the same way many U.S. citizens stack and recycle waste in their
garden compost heaps behind their homes. The idea here is that over
time, due to its weight and organic breakdown, the pile of manure
will
heat up sufficiently to sterilize itself of any harmful disease
causing agents.
The Washington State Administrative Code's commercial feed rules for
processed animal waste defines "animal waste" and "processed" online
at:
http://apps.leg.wa.gov/WAC/default.aspx?cite=16-256-010
...and...
http://apps.leg.wa.gov/WAC/default.aspx?cite=16-256-020
Here the State says that "commercial feed containing raw or
unprocessed animal waste is considered adulterated." It is illegal
to
give adulterated feed to cattle. However, in order to be clean and,
therefore, legal to feed to animals, the Washington code goes on to
say that the waste can be "dry-stacked" or "thermally dehydrated to a
moisture content not in excess of 12.00 percent." By this method,
excrement that would otherwise be an illegal adulterant can
supposedly
be converted into a safe, wholesome, and nutritious food ingredient
for cattle to eat. The FDA is so confident in State laws like this
one that in 2004 the federal agency rejected a proposal to ban the
practice of feeding chicken feces to cows, as was reported by
Bloomberg.com at:
http://www.bloomberg.com/apps/news?pid=10000103&sid=ae4.Ko7FZld4&refe...
The Topps Meat Company, one of the United States' largest producers
of
ground beef recently went out of business due to a recall of E.Coli
contaminated beef. As E.Coli is a bacteria which colonizes the
intestinal tracts of humans, cows, and chickens, one wonders as to
the
effectiveness of stacking chicken manure before feeding it to cows.
A
New York Times article about Topps quotes one of the company's
employees as stating that "the problem is the beef, not the company."
The full New York Times article is available online at:
http://www.nytimes.com/2007/10/06/us/06topps.html?ex=1349323200&en=7d...
&ei=5088&partner=rssnyt&emc=rss
With globalization spreading, and the fact that United States
corporations dominate many intra- and international trades worldwide,
I would like to address the following questions to both the United
States Cattle Industry and one of its biggest customers: the People's
Republic of China. Please be aware that I already posed such
questions to some of the largest meat processing companies in
America,
including Cargill, Tyson, Smithfield Foods, and JBS-Swift and
Company. To date, they have all refused to answer any of my
questions. Therefore, if possible, would you please respond to the
following:
1. What data has the United States Cattle Industry collected
regarding the use of chicken feces in cow feed for American cattle?
2. On what basis can the United States Cattle Industry assure the
American public and all other worldwide consumers of U.S. Cattle
products (beef and dairy) that there is no real or potential health
hazard from the large scale practice of feeding chicken feces to
cows?
3. Does the People's Republic of China have an official policy
regarding the use of chicken feces as cow feed for its cattle?
4. Given the recent concerns over consumer safety and health issues,
and the importance of these issues to world trade between nations,
what is the People's Republic of China's opinion on the United States
Cattle Industry practice of feeding chicken feces to cattle?
When considering these questions, please keep one point of
clarification in mind. While this letter may appear to focus on beef
production, chicken feces is fed to cattle used for both beef and
dairy products. Therefore, the consequences of such feed practices
may affect both meat and dairy goods, including but not limited to
beef, milk, cheese, and yogurt.
I appreciate you attention and time taken to address this matter. I
am forwarding a copy of this letter to the individuals below whom I
believe may also be interested in your response.
Sincerely,
Dr. Robert Ben Mitchell, D.O.
CC TO:
Philip Seng, President and CEO
U.S. Meat Export Federation
1050 17th Street, Suite 2200
Denver, CO 80265
Phone: 303-623-6328
Fax: 303-623-0297
Email: ps...@xxxxxxxxx
Twig Marston, Director
Beef Improvement Federation
126 Weber Hall
Manhattan, KS 66506
Phone: 785-532-5428
Fax: 785-532-7059
Email: t...@xxxxxxx
Amy Sapkota
Maryland Institute for Applied Health
College of Health and Human Performance
University of Maryland
College Park, 2306 HHP Building
College Park, Maryland 20742
Phone: 301-405-1772
Fax: 301-405-8397
Email: a...@xxxxxxxxxxxxxx
Shannon Jordre
Division of Compliance
FDA/CVM, HFV-235
7500 Standish Place
Rockville, MD 20855
Phone: 240-276-9229
Fax: 240-276-9241
Email: shannon.jor...@xxxxxxxxxxx
Ricky R. Schroeder
Supervisor of Feed and Fertilizer Registration
Office of the Texas State Chemist
Texas A&M University
445 Agronomy Road
College Station, TX 77843
Phone: 979-845-1121
Fax: 979-845-1389
Email: r-schroe...@xxxxxxxx
Michael Greger, M.D.
Director of Public Health and Animal Agriculture
The Humane Society of the United States
2100 L Street N.W.
Washington, DC 20037
Phone: 202-676-2361
Fax: 202-676-2372
Email: m...@xxxxxxxxxxx or mgre...@xxxxxxxx
.
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