Challenges for Todays Small Packers

1
Challenges for Todays Small Packers

• Robert E. Pitts, DVM
• Director
• WVDA-MPID

2
Factors

• Federal vs State Inspection
• Plant size
• Custom vs Commercial

3
Federal vs. State

• 27 State Inspection Programs
• Inter vs. Intrastate Shipment
• Title V

4
Plant Size

• Large vs Very Small
• Materials
• Available Resources
• Labor

5
Custom vs Commercial

• Facilities
• Inspection
• Client Options

6
Labeling Options

• Plant labels
• Custom labels

7
BSE

• SRMs
• More restrictions
• Cattle Material Prohibited from Animal Feed
  (CMPAF)
  

8
CMPAF

• The entire carcass of BSE-positive cattle
• The brains and spinal cords from cattle 30 months
  of age and older
  
• The entire carcass of cattle not inspected and
  passed for human consumption that are 30 months
  of age or older from which brains and spinal
  cords were not removed
• Tallow that is derived from other materials
  prohibited by this rule that contain more than
  0.15 percent insoluble impurities and
  
• Mechanically separated beef that is derived from
  the materials prohibited by this rule.
  

9
New Feed Rule

• Under this regulation, no animal feed or feed
  ingredient can be manufactured from, processed
  with, or contain CMPAF.

10
New Feed Rule

• Cattle materials intended for animal feeds must
  have prohibited material (CMPAF) removed and
  separated

11
Disposal Alternatives

• Burial
• Landfill
• Composting
• Incineration
• Alkaline Hydrolysis

12
Rendering Companies

• Company A
• Slaughter cattle only under 30 months
• Written procedures for age verification
• Documentation for every animal
• Signed certification for each collection
• Annual Raw Material Supplier Certification
  Annual Cattle Mortality Age Warranty
  

13
Rendering Companies

• Company A
• Slaughter cattle 30 months and over
• Written procedures for age verification
• Remove head spinal cord of all cattle with
  written documentation
  
• Written procedures for removal marking of
  CMPAF
  
• Procedures for containing and collecting all
  CMPAF tissues
  
• Signed certification for each collection
• Annual Raw Material Supplier Certification
  Annual Cattle Mortality Age Warranty
  

14
Rendering Companies

• Company B
• Separate CMPAF
• 2 year contract
• 2,000,000 Commercial General Liability Insurance
  Policy (Company B named insured on policy)