A federal regulation aimed at preventing mad cow disease from getting into the food supply could create health risks of its own: many thousands of cattle carcasses rotting on farms, spreading germs, attracting vermin and polluting the water.
At issue is a Food and Drug Administration rule, set to take effect in April, that will prohibit the use of the brains and spinal cords of older cattle as ingredients in livestock feed and pet food.
Some of the rendering plants that grind up carcasses for use in feed have already announced they will stop accepting dead cattle from farms because it would be too costly to remove the banned organs. Other renderers are likely to raise the prices they charge farmers.
As a result, many farmers — especially now, with the economy in crisis — may simply bury dead cattle on their property or let them rot in the open, industry officials and regulators say.
"I think there will be some illegal disposal — animals that get dragged into the woods or into the back fields," said Gerald F. Smith Jr., president of Winchester, Va.-based Valley Proteins Inc., which operates 12 rendering plants in seven states but will no longer remove dead cattle from farms come February. He said the fee per animal would have to go from $85 to $200 to cover the additional expense, and "I don't think the farmers would be willing to pay."
Farmers already routinely bury, abandon or compost millions of cattle carcasses each year without serious environmental problems, according to the FDA.
More likely at dairy farms
But the fear is that the new rule could lead farmers to put hundreds of thousands more dead animals into the ground, especially on dairy farms, which tend to have many more older cows than cattle ranches do, and are often closer to populated areas, too.
According to the FDA's own environmental assessment of the new rule, abandoning dead cattle or improperly burying or composting them can cause foul odors; pollute soil, groundwater and streams; and attract insects and scavengers. Moreover, the infectious agent that carries mad cow disease may survive burial or composting, the agency said.
"In some areas of the country ... adverse environmental impacts could be expected unless new disposal capacity is developed," the FDA said.
Thomas Glanville, an agricultural engineering professor at Iowa State University, said farmers who opt for burial will need to pick sites with favorable drainage and geology to avoid contaminating groundwater and soil.
For decades, farmers have sent their dead cows to rendering plants to be turned into pet food, soaps, cosmetics, toothpaste, lubricants and other products. The carcasses are ground to a uniform particle size, heated under pressure to separate fat, protein and bone, and then refined.
The FDA regulation is aimed at providing an added layer of protection against mad cow, a brain disease that has been linked to more than 150 human deaths worldwide, mostly in Britain. Scientists believe the human version of mad cow is transmitted when people eat tainted beef. The United States has had no known human cases linked to U.S. beef.
Nearly 2 million head of beef and dairy cattle annually, or more than 40 percent of all those that die before they can be sent to slaughter, are rendered in the U.S., according to government and industry estimates. The remaining carcasses are mostly buried.
Regulators estimate the new feed ban will reduce the number of cattle handled by rendering plants by 500,000 to 800,000 annually.
California bans composting
Some farmers will be hamstrung by state or local regulations that limit burial or composting, in which the carcass is left to decay in a pile of clippings and other organic material. Iowa, for instance, limits the number of cattle carcasses that can be buried to seven per acre. California prohibits composting of dead livestock.
Still, properly done, composting is a good alternative to rendering, experts say.
Dairy farmer Tim Forry said he began composting his 1,200-pound Holstein cows about two years ago after the cost of sending them to the rendering plant got out of hand. When a cow dies on his farm in Pennsylvania Dutch country, he dumps the carcass onto a 200-foot-long compost pile behind his barn, where dozens of dead cattle are slowly decaying in a steaming, aboveground tomb of manure, wood shavings, hay and leaves.
"I can't say I've noticed any odor at all coming off of this," he said.
Glenn Stoltzfus, 42, a dairy farmer with 500 cows in Pennsylvania, said he has been composting cows for years without a problem, although a bear or coyote will occasionally dig up a carcass, and "then there's not a very pleasant odor."
Other farmers, though, drag dead calves into the woods and leave them for scavengers, Stoltzfus said. "You'll see the turkey buzzards circling," he said. "It's not a very pleasant thing. A large cow, you don't want to do that with."
Tom Craig, 60, who runs a 1,000-cow dairy farm near State College, said he is not sure how he will dispose of his dead livestock if rendering is no longer an option. Housing developments border his 1,600-acre farm, and he said the neighbors may not take kindly to a compost pile.
"You don't want to have that next to somebody's house," he said.
The U.S. banned the feeding of bovine byproducts to cattle in 1997, but regulators say that didn't eliminate the risk of mad cow. Without the new rule, pigs and chickens could eat contaminated feed and then in turn be rendered and fed to cattle.
Because younger cattle are believed to pose almost no risk of mad cow, only the brains and spinal cords of cattle 2 1/2 years and older will be prohibited from animal feed. The FDA rule is expected to affect the dairy industry more than the beef industry because most beef cattle are slaughtered before they turn 2 1/2.
In Pennsylvania, the No. 5 milk-producing state, hundreds of farmers have attended recent workshops on composting. Agriculture officials also plan to mail an informational brochure to livestock farmers. The idea, said Shelly Dehoff, of Pennsylvania's agricultural ombudsman program, is to "get the word out that there are alternative methods, and legal methods, that do not include throwing an animal out in the woods somewhere, and just expecting it to decompose or have other animals pick away at it."