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Dr. Koen Van Dyck, Head of Section TSE
Directorate General Health & Consumer Protection (DG SANCO) European Commission

1.  BACKGROUND

A ban on the feeding of mammalian processed animal proteins (PAP) to cattle, sheep and goats was introduced as of July 1994. This partial ban was extended to a total EU wide suspension on the use of processed animal protein in feed for any animals farmed for the production of food on 1 January 2001 with some exceptions like the use of fish meal for non-ruminants. Any presence of prohibited constituents of animal origin in feed is considered as a breach of the feed ban i.e. a zero-tolerance approach. Rules related to the feed ban are laid down in Regulation (EC) No 999/2001 laying down rules for the prevention, control and eradication of certain transmissible spongiform encephalopathies, as amended (TSE Regulation).

2.  TSE ROAD MAP

On 15 July 2005 the European Commission adopted a reflection paper, the TSE Roadmap, providing an outline of possible future changes to EU measures on TSE in the short, medium and long-term. Over the past few years, there has been a significant decrease in the number of positive cases of BSE detected in the EU, due to the stringent risk reducing measures at EU-level. In light of this positive trend, and new developments in science and technology, the TSE Roadmap considers possible amendments to certain TSE measures currently in place while still making food safety and consumer protection the highest priority. Following the adoption of the TSE Road map the Commission issued a Commission staff working paper i.e. Work Programme on TSE [SEC(2006) 1527] on future legislative actions in the field of transmissible spongiform encephalopathies.One of the topics concerns a revision of the feed ban provisions.

The starting point when revising the current feed ban provisions should be risk-based but at the same time taking into account the control tools in place to evaluate and ensure the proper implementation of this feed ban. Therefore robust detection methods and good performance of the labs is a key factor for any future amendments of the current feed ban provisions. The nomination of the Community Reference Laboratory for the detection of animal proteins (CRA-W Gembloux (Belgium)) in 2006 will contribute to ensure the highest level of uniformity and quality of the analytical results.

The following topics can be considered within a review of the feed ban provisions:

2.1. Use of fish meal for young ruminants

As part of its annual work programme, the Community Reference Laboratory for animal proteins in feed [CRA-W, Gembloux (Belgium)] conducted an interlaboratory study to evaluate the performance of the laboratories. The performance of the National Reference Laboratories to apply the microscopic method for qualitative purpose was good and the best performance obtained since ring trials using the microscopic method were organized within the European Union.
The good performance of the laboratories to differentiate fish meal and mammalian animal proteins allowed launching the discussion at working group level on the use of fish meal for young ruminants within the legal provisions provided in the TSE Regulation.

 2.2. Tolerance level in feed 

Analyses in Germany demonstrated that presence of bones in beet pulp is frequent (up to 10 %) and cannot be avoided. The likely origin is bone fragments of wild animals in soil which stick to the beets and end up in sugar beet pulp fed to ruminants. In 2005 a tolerance on the presence of bone fragments in sugar beet pulp due to this environmental contamination was adopted when a robust risk assessment has demonstrated the absence of cross contamination or the fraudulent incorporation of processed animal proteins. An extension of this derogation to other feedingstuffs (corn, hay) due to this environmental contamination may be considered.

Based on a quantitative risk assessment of traces of PAP in feed and if the necessary control tools are available to quantify the amount of PAP in feed, a tolerance level for insignificant amounts of animal proteins in feed might be considered.

2.3. Lifting total feed ban provisions 

This refers to re-introduce the use of pig meal to poultry and poultry meal to pigs. There is however no question to re-introduce ruminant meal in feed. Further improvement in differentiating animal proteins specific to certain species may result in an amendment of the provisions. The ongoing research activities in the framework of the SAFEED-PAP are therefore from paramount importance.