To the Editor:

Rendered animal products have been utilized in the production of livestock and companion animal feeds for an extensive period of time. The use of bone meal as a source of minerals was taking place before the 1960s. During the past several decades, animal protein was looked upon as a suitable protein source for both livestock and companion animals. Animal fat is utilized to provide fat content in manufactured feeds. Maximizing milk production has led the dairy industry to utilize high protein and high fat pelleted rations in the feeding of dairy cattle. Meat producers feed rendered fats to increase growth rates of their livestock.

Environmental organizations, national governments and the United Nations Environment Program have made considerable efforts to minimize the presence of a group of chemicals referred to as persistent organic pollutants (POPs) in the global environment. Much of this work has taken place in connection with the Stockholm Convention on POPs. POPs are persistent in the environment. POPs are fat soluble and because of this reach elevated concentrations in body fat of animals at upper levels in aquatic and terrestrial food chains.

Polychlorinated biphenyls (PCBs) were invented by Monsanto Corporation in the 1930s. Industrial use expanded rapidly until production was banned in the 1970s. Releases of PCBs in waste water discharges from factories, disposal of PCBs in hazardous waste facilities and illegal dumping of PCBs have led to widespread contamination of the global environment. PCBs are POPs. The National Toxicology Program (NTP) has classified PCBs as “reasonably anticipated to cause cancer in humans”. PCBs are known animal carcinogens.

The use of plastics has increased greatly since the mid-1900s. Disposal of plastic wastes via combustion during the past 60 years has created and released a large quantity of PCBs and dioxins into the global environment.

During the period of time when plastics disposal was increasingly contaminating the environment with PCBs and dioxins, chlorinated hydrocarbons became extensively used as pesticides. These pesticides are POPs. Pesticide POPs include: hexachlorobenzene, DDT, hexachlorocyclohexane, chlordane and Mirex.

Polybrominated diphenyl ethers (PBDEs) are manufactured for use as flame retardants. PBDEs are utilized in the manufacture of many products: plastic electronics equipment, upholstery, carpet, drapes, clothing, etc.

Contamination of the environment takes place when PBDEs evaporate from the products they are part of and enter the outdoor atmosphere. PBDE pollution also arises in the form of house dust. Americans have higher levels of PBDEs in their bodies than any other people on Earth.

All animal fat contains a wide array of POPs. Most of the POPs have been classified by NTP as “reasonably anticipated to cause cancer in humans”.

The most well studied dioxin cogener, 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), has been classified by NTP as “know to cause cancer in humans”.

The outbreak of bovine spongiform encephalopathy (BSE), commonly know as Mad Cow Disease, which began in the United Kingdom in the 1980s, motivated change in the use of rendered proteins. BSE is believed to be caused by exposure to small protein molecules of aberrant structure. Thus, efforts to interdict transmission of the disease were focused on rendered proteins. Currently existing Food and Drug Administration (FDA) regulations prohibit the feeding of ruminant proteins to ruminants.

The feeding of rendered animal fats to livestock was not affected by the protein feeding restrictions. Feeding waste animal fat to livestock maintains relatively high levels of POPs in the human food supply. The most effective measure that US federal government regulatory agencies could implement to reduce human exposure to POPs would be the banning of the use of waste animal fat in the feeding of food animals.

The Institute of Medicine of the National Academies of Sciences published “Dioxins and Dioxin-Like Compounds in the Food Supply: Strategies to Decrease Exposure” in 2003. The key recommendation of this report was that girls and women of child-bearing age decrease their dioxin exposure by restricting consumption of animal fat. In 2011, no federal or state government health agency has yet taken up the work of educating the general public upon this crucial matter.

Cancer Action NY submitted a citizen petition to the US Food and Drug Administration (FDA) in December 2003 calling for rule-making that would serve to reduce dioxin exposure in the United States. Rules requested include: a ban on the feeding of animal fats to food animals, and a rule requiring food labeling that notifies consumers of the presence of dioxins in animal fat containing foods, including: fat containing dairy products, fish, meats and eggs. This petition can be accessed at: http://www.canceractionny.org/petitioningtheusfda.htm.

Animal fat should not be fed to livestock. Waste animal fat should not be fed to companion animals. Vegan pet foods provide an option for minimizing exposure of dogs and cats to POPs. Feeding pets raw and cooked foods that you eat is the best way to feed beloved companion animals.

Farmers should choose only plant sourced ingredients for their livestock feeds. Vegetable sources of fat include various oils. Palm oil is widely utilized in animal feeds.

Don Hassig, Colton