WASHINGTON — The Food and Drug Administration’s April 6 decision to solicit public comments on delaying the implementation of a new feed ban instead of on the ban itself is being criticized by the National Cattlemen’s Beef Association.

Since proposed in 2005, N.C.B.A. has opposed the enhanced feed ban. The association continues to urge F.D.A. to open the rule to public comment and delay implementation until they have had adequate time to consider the many problems caused by the ban.

"Cattle producers across the country have been suffering as a result of this proposed rule months before it is scheduled to take effect," said Dr. Elizabeth Parker, chief veterinarian for N.C.B.A. "Members of Congress and the Senate have joined N.C.B.A. in petitioning the F.D.A. to reopen the rule itself for public comment so that the people impacted by the rule can share their stories. Instead, the F.D.A. is only allowing seven days of comments on whether to delay the implementation of the rule by 60 days. This is a weak and ineffective response to the issues already arising from this ill-considered action."

Industry and government have worked together over the past two decades to put in place science-based measures, which have proven successful in preventing and reducing the spread of bovine spongiform encephalopathy in the U.S., N.C.B.A. said. B.S.E. incidence worldwide has dramatically decreased due to the many measures put into place, including a series of interlocking safeguards and science-based mitigation practices.

"We must continue to look to the science to avoid over-regulating the industry and creating policy that doesn’t meet our objective of a safer animal-health system," Dr. Parker said.

The U.S. has prohibited ruminant feed from including parts of other ruminants since 1997. N.C.B.A. said this proactive "ruminant-to-ruminant" feed ban, combined with other government and industry safeguards, has proven to be highly successful in limiting B.S.E. in the U.S. herd. As a result, the U.S. has an extremely low-level risk of B.S.E.

N.C.B.A. said the enhanced feed ban would prohibit certain cattle-derived risk materials from all animal feed. As a result, the enhanced feed ban would provide negligible benefits to animal health or food safety. It would also create tremendous costs for ranchers, exacerbate disposal issues and generate environmental concerns. Many renderers stopped picking up dead livestock because of the severe economic realities of this proposal as early as December 2008.

"This rule has essentially ended rendering services in many parts of the country, and left producers with no legal alternatives," Dr. Parker says.

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