Pieter Derks.pdf

Currently the TSE regulation 999/2001 (as amended) prohibits the use of Processed Animal Proteins (PAP’s) in feeds for animals farmed for human food production (with limited exceptions, for example the use of fishmeal in feed for non-ruminants and the use of bloodmeal in aquafeed).This regulation is an important element of the EU BSE controls, which are designed to ensure that BSE is eradicated as soon as possible.

At the end of 2001 the feed ban became into force to prevent new cases of BSE. Therefore it is only necessary to prohibit the use of ruminant proteins in ruminant feed. However, to ensure complete compliance of this single element a much wider ban is enforced although it is safe to feed non-ruminant PAP to non-ruminants (or in principle, ruminant PAP’s to non-ruminants).

To lift the ban the following “Feed Control Tools” are needed:


  1. There must be a system of documents that makes traceability possible 

    To ensure traceability already documents are used in the whole chain from transport of slaughter byproducts, to transport of processed animal proteins and transport of feed. This channelling system is approved.

  2. Category 1 and 2 meat and bone meal must be marked so that it is possible to distinguish these products from the category 3 PAP’s 

    For the marking of category 1 and 2 materials JRC/IRMM proposed the use of GlycerolTri-Heptanoate (GTH) that must be added after the first heat treatment. This is obliged since July 2008. Also the storage facilities and trucks for both animal byproducts and processed products are marked with labels showing category and other information.

  3. There must be a control tool for checking the absence of processed animal proteins in ruminant feed
    Checks on absence of processed animal protein in ruminant feed are already possible (and done) by using microscopic control.
  4. Availability of species identification tests to analyse PAP’s to prevent intra species recycling (ban laid down in the Animal ByProduct Regulation EC 1774/2002 as amended) and to prevent the use of ruminant PAP’s 

    The first step in re-entry PAP’s in feed for farmed animals could be the use of terrestrial non-ruminant processed animal proteins only for the feeding of aquatic species (aquafeed). For this application, it is not necessary to have a porcine or poultry species identification test, but only a ruminant test is needed. The species detection in feed is very difficult because a very low detection limit is needed and because of the presence of allowed products. Therefore EFPRA has proposed the detection in PAP’s. As a result of the DNV risk analysis EFPRA recommends that a 2% threshold limit for the presence of ruminant PAP in non-ruminant PAP should be accepted as providing a safe level of protection of humans or animal health with regards to BSE. Detection methods are now available. The dipstick method from Neogen (Reveal) is a quick and easy method.

However from CRAW test results it is known that the results are not always correct. The MELISA-TEK method from Elisa Technologies Inc. is somewhat more time consuming but gives very good results (See presentation of R. Margry, CCL). Furthermore, there are PCR-tests available; a ruminant PCR test of TNO (although this test is not yet commercially available) and a cattle test from CRAW that can be used for confirmation.


The total decision procedure is summarized in the next scheme:




The conclusion of EFPRA is that methods are available that ensures a safe use of terrestrial

non-ruminant processed animal proteins in aquafeed.