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December 2, 2022
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Processed Animal Protein feed – what could possibly go wrong?

While the NFU claims that the UK has world-class food standards, the Minister for Rural Affairs tells the House of Lords that we are already importing meat-fed Processed Animal Protein and so the UK should follow the EU and reintroduce it, despite the BSE disaster. But why not call the EU’s bluff and use this opportunity to differentiate UK pork and poultry products from other EU producers. That would be a much greater benefit to UK farmers than slightly cheaper feed.

A race to the bottom on food safety?

The European Commission has recently announced that the EU will be allowing farmers to feed farm animals food made from other animals. So far this only involves granivores – known as omnivores before the EU encouraged ‘farmers’ to keep hundreds of thousands of chickens and pigs in giant sheds for their entire lives, fed exclusively grains. The problem with this industrial method of production is that the meat produced tastes somewhat bland compared to that of a free-range animal able to forage for roots, insects and worms. But according to the Guardian, the EU’s motivation is purely financial  . Animal protein is cheaper than plant-based protein, and crucially is being used in other countries that are undercutting EU producers.

PAP and the Northern Ireland Protocol

When questioned in the House of Lords the Parliamentary Under Secretary of State (Minister for Rural Affairs and Biosecurity), The Rt Hon Lord Benyon, made some surprising admissions when answering Lord Moylan’s question on this subject. Apparently, the UK’s/EU’s supposedly “world class standards” for food safety, standards that prevent imports of chicken meat washed in chlorinated water and beef produced from cattle drip-fed tiny amounts of beef hormones, already allow the importation of meat produced from animals fed on processed animal protein – as well as, according to Lord Benyon, meat produced to “a lower standard to even where the EU will go following the changes they have announced.” In other words, EU food production standards (which are still applicable in the UK) do not apply to imports.

Apart from anything else, this is revelatory in terms of the EU’s efforts to stop British produced meat being sold in Northern Ireland by claiming that it could somehow contaminate the Single Market because it doesn’t meet EU standards. It will in fact be produced to higher and safer standards than the EU is proposing for its own farmers.

Lord Benyon seemed unperturbed about the EU’s proposed new and lower animal feed standards. Current EU feed regulations were instigated during the BSE crisis under the   notorious ‘precautionary principle’ when the EU could not isolate the infected animal protein feed. Now, with genetic testing, they believe they will be able to identify any infected feed – although probably only after an outbreak unless they are testing every batch before it is released onto the market.

And regarding trade with Northern Ireland, Lord Benyon replied to Lord Moylan that ‘there is not a question of this concerning any trade and cooperation agreement and meat will still be able to be traded to and from Northern Ireland as it will with the EU.’ Huh?

When Lord Dodds stated that the Northern Ireland Protocol meant that consumers in Northern Ireland would not be able to prevent this change in regulations becoming law in Northern Ireland, Lord Benyon sidestepped the dilemma created by the Protocol, but did reassure (if that is the right word) Lord Dodds that products are already being imported into Northern Ireland, as they are into the rest of the UK, from both EU and non-EU countries, which are already produced to a certain [low] standard.

So just to summarize for those who haven’t been paying attention over the past few weeks: the UK’s National Farmers Union is demanding that the Department for International Trade not sign trade deals with countries whose agricultural standards are ‘lower’ than the UK’s, even if only different due to different customs or climates, but the Minister for Rural Affairs and Biosecurity has just said in House of Lords that the UK is already importing agricultural products produced to a lower standard and produced using animal feed that is banned for use by UK farmers.

The economic necessity of PAP is not obvious in the trade figures

This begs another question – how much of this low standard meat is being imported and where is it coming from? According to TradeMap, over the last 5 years the UK has imported on average 423,000 tonnes of chicken, and only 4% of it came from non-EU countries. These countries are: Chile (UK 5-year average imports 6298 tonnes), Brazil (5,768 tonnes), Argentina (2381 tonnes), Thailand (2180 tonnes), Ukraine (183 tonnes), Uruguay (12 tonnes), South Africa (9 tonnes), Norway (6 tonnes), and China (1 tonne). In the grand scheme of things these imports are insignificant amounts. The UK produced 1.9 million tonnes of chicken in 2019 according to DEFRA, Lord Benyon’s department, and the 96% of imports from the EU would have been bred without the use of animal protein feed. So why would the UK change its regulations for fear of competition from imported chicken, only some of which may have been fed PAP, if the amount imported equates to less than 1% of our domestic production? There is no commercial justification for this change. One per cent is not enough to put domestic producers under any kind of competitive pressure.

Similarly, with pork, over the last 5 years the UK has imported on average only 827 tonnes of pork from non-EU countries, out of average total imports of just under 400,000 tonnes. According to Trade Map most of the 827 tonnes came from the US with occasional smatterings of pork from Australia, Chile and South Africa. UK domestic production, according to DEFRA, was 922,000 tonnes in 2019. So Non-EU imports were less than 0.1% of UK pork production. And yet our Minister for Rural Affairs believes that the production costs of these imports are so much lower than the UK’s that we have no choice but to follow the EU’s lead and lower our standards by also feeding our pigs animal-protein based food.

The largest determinant of agricultural price competition is the relative currency values between the importing country and the exporting country. The next determinant would be relative wages in labour intensive production, or the cost of farmland for land intensive production. The differential in the cost of animal food in Chile or South Africa and the UK is immaterial, there are currently about 20 South African Rand and over 1,000 Chilean pesos to the pound and lowering UK feed costs will not make up for this difference.

There is much more to this proposal to change UK rules on feeding farm animals food made from other farm animals, than simply the need to lower the cost of animal feed in the UK.

Some History

To anyone who lived through the BSE crisis in the UK in the 1990s, reintroducing feeding dead animals to live animals is probably a shocking idea. The disease, Bovine Spongiform Encephalopathy (BSE), which caused a progressive neurological disorder in cattle, is believed to have originated from feeding cattle a protein-based feed made from the rendered meat, bones, and nervous system of scrapie infected sheep and from rendered BSE infected cattle.

This animal protein feed was euphemistically known as Meat and Bone Meal or MBM, a suspiciously similar name to the new Processed Animal Protein or PAP feed. It is interesting that animal feed producers never want to call their product what it is. But there is a fascinating, if rather gross New York Times Article that clearly explains the process of rendering dead farm animals, together with roadkill, abattoir waste, and even euthanised pets to produce fats for commercial use and animal feed – including pet food. This process is not restricted to the UK and it is used internationally. The proteins produced from rendering were mixed with other plant-based feed and fed to farm animals.

At the peak of the BSE crisis, 1993, there were over 1000 cases of BSE diagnosed a week in the UK. In total there were 184,500 cases, across more than 35,000 cattle herds.  It was later discovered that there is a causal association between BSE and a human disease called Variant Creutzfeldt-Jakob-Disease (vCJD) and eating beef contaminated with BSE is believed to have caused 177 deaths from vCJD in the UK. There are also vCJD victims with the disease whose brains are slowly degenerating, and the government has set up the vCJD Trust to help them.

The UK was not the only country effected by BSE, but it had by far the most reported cases. It is believed that as the UK has a proportionally larger sheep herd than the US or other EU countries, dead sheep suffering from scrapie made up a greater proportion of the rendered protein used in animal feed in the UK. Certainly, many of the BSE cases found in the EU were traced back to animal feed from the UK. Although the Government was quick to ban UK consumers from eating meat on the bone or offal, and they banned cattle and sheep feed containing ruminant Meat and Bone Meal in July 1988, it did not become illegal to feed ruminants any form of mammalian protein until November 1994 and the export of MBM feed was not banned until March 1996. In April 1996, the Government extended the ban to include feeding any farmed livestock mammalian meat and bone meal.

Ironically, the introduction of MBM into the diet of UK cattle came not from the beef industry, even though they bore most of the resulting devastation, but from the dairy industry. Dairy farmers found that feeding protein to their cows increased their milk yields and that animal protein was more effective than plant protein. However, many of the dairy cows’ progeny became part of the UK’s beef herd after weaning, bringing the disease with them. It was discovered that a calf born to a cow with BSE would also have BSE.

As a consequence of BSE, over 4.4 million UK cattle were culled in case they spread the disease to other cattle herds, and the UK population was unable to buy meat on the bone, offal or mince made from the meat mechanically sucked off the skin and bones of a beef carcass. Even now, any UK cattle killed over 30 months old must have their spine removed by the abattoir and sent for analysis of any trace of Transmissible Spongiform Encephalopathy (TSE). The disease not only devastated UK beef farmers, but it also forced many independent UK butcher shops and hamburger restaurants out of business.

The crisis also destroyed the UK’s beef export industry even with other EU states despite EU Single Market rules. The European Commission banned the worldwide sale of UK beef in 1996, a ban that they only partially lifted in 1999. France, the UK’s largest beef export market before the crisis, refused to lift the ban and was taken to the European Court of Justice by the Commission. France lost and was fined £100,000 a day before agreeing to lift the ban on importing boneless UK beef in September 2002.  The EU only lifted the ban on UK beef cattle completely, including live cattle exports to other EU member states, in May 2006 – ten years after it was first imposed, while Japan only lifted its ban on UK beef imports in 2019 and the US lifted their ban on UK beef only last year.

The potential for a similar devastating hit to the British livestock industry from PAP feed, forced on us if we align with EU rules (via the Northern Ireland Protocol) should be enough to make anyone question the wisdom of unthinking acquiescence to EU demands for dynamic regulatory alignment – the acceptance of rules made in Brussels with no say.

So, will PAP be different from MBM?

The Commission’s proposal to allow the feeding of processed insects to chickens is not controversial. Chickens are omnivores and naturally eat insects and worms if they can catch them. Chickens will also eat scraps of meat and fat and were once kept to eat kitchen leftovers as well as to produce eggs. However, it is the quantities involved in PAP that may be a problem. The difference between a safe substance and a poison is usually only the dosage. Will the Minister for Biosecurity set a maximum proportion of chicken feed that can be made of processed insect-based protein? Would he even be allowed to diverge from EU levels?

It is claimed that insect-based protein will be cheaper than plant-based protein so there would be a financial incentive for chicken producers to feed their birds exclusively insect-based feed. But rendered waste animal protein will be cheaper still. Will the render be able to include dead chicken carcasses as well as other animals? While chickens might not get BSE, there is a chance that any avian viruses would be multiplied if contaminated carcasses are fed to an otherwise healthy flock. Could there be zoonotic transfer of avian viruses to humans as a result of eating PAP-fed chickens? What limitations would be applied on the type and health of animal waste included in any PAP? And what rendering temperature would be needed to kill any possible viruses in the animal waste?

Whether PAP can be scaled up safely to feed the hundreds of thousands of birds often kept in giant sheds, without causing another BSE-style crisis – we will have to wait and see. On the positive side, chickens are not mammals and so there is a lower chance of any viruses jumping from pig-based PAP to the chickens that eat it.

Pigs are also omnivorous, but meat tends to make up less than 5% of their diet if they are free to forage. Again, would there be limits on the amount of animal protein that could be fed to any pig herds or on what could be in it? It is currently illegal to feed swill to pigs in the UK. Pig ‘swill’, which could contain anything: from restaurant leftovers/supermarket waste/abattoir waste/dead animal carcasses etc., often caused outbreaks of swine fever. This disease caused millions of Chinese pigs to be culled in 2019.

Are there any positives to reintroducing PAP?

While there could be a slight carbon footprint reduction from feeding chickens crushed insects from Africa rather than crushed soybeans from Brazil – but it is unlikely to make a massive difference in transported weight as insect protein will hopefully be only a small proportion of any animal feed. Meanwhile importing insects and probably undetected insect eggs or larvae could create a new problem for Britain’s agrarian farmers if not for its chicken farmers.

But domestically processed animal protein (PAP) made from rendered waste animals will have a production carbon footprint but no additional transport footprint. Hopefully after the disaster caused by rendered protein from BSE cows and scrapie sheep, the Minister for Rural Affairs and Biosecurity will legislate to prohibit any diseased animals being included in the PAP render. Although this would probably push up the price of rendered protein and discourage its use.

But viewed in total, PAP feeds may not be the best solution to reducing the reliance on imported plant-based animal feed, nor the best way to improve meat taste, quality or food safety.

Just a political manoeuvre?

There may be another element to this proposal, which is entirely political. It seems strange that the EU, an entity that stops at little to protect its farmers from commercial competition, would even be contemplating such a change in its regulations when there is a commercial advantage, and an easy justification, for not changing them.

Admittedly, some EU farmers are probably complaining that the BSE crisis was caused by the British, and as the UK has left the EU, why must EU farmers comply with this regulation. But what if this is just the EU demonstrating its power over the UK’s politicians and civil servants, many of whom are still desperate to re-join the EU. What if this is simply a powerplay, showing the world who is still boss? Forcing Northern Ireland to adopt these new feed rules would do far more damage to UK sovereignty and the integrity of the UK than simply setting the PAP among the chickens.

The UK’s National Farmers Union (NFU) has been busy trying to block any new UK trade deals with non-EU countries by claiming that the UK has the ‘best animal welfare and food standards in the world’ and implying that all non-EU countries fall short of these criteria. But how could the NFU continue claiming this if the UK is led by the nose and lowers its standards on animal protein feeds at the behest of the EU.

Call the EU’s bluff

This is a phenomenal opportunity for the UK to differentiate its pork and poultry products from other EU producers, and a chance to block a large part of its imported competition in these markets. Now the UK could actually have the best animal welfare standards in Europe, provided of course that they do not reintroduce rendered animal protein in farm animal feed.

This would be a massive benefit to UK pork producers and would be worth a lot more financially than a small reduction in their feed costs. The ability to block imports of EU pork that presently make up around 40% of the pork consumed in the UK each year would greatly increase their revenue. And unlike cattle, pig production can be upscaled very quickly as sows have litters of 8 to 12 piglets twice a year.

The UK should not follow the EU down this path but call the EU’s bluff. We have nothing to lose. If they diverge, we block their imports that no longer meet our standards, and our pork producers benefit, and any struggling beef and sheep farmers should be encouraged to diversify into pig farming. The NFU will have to declare if they are actually interested in high animal welfare or simply want the UK to remain dependant on EU farmers forever, as will several politicians and public servants. And of course, UK consumers will be able to enjoy delicious UK produced pork without thinking about what rendered garbage it was fed. Who knows, the UK might even be able to export its pure pork to the EU…

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