FDA regulating feed

Respectfully I don't think you truly grasp how regulation, government, and corporitism are in bed with one another. I don't hate the rich at all. What I do hate is how lobbyists are able to use the power of government to raise the a barrier for competition through cost of entry.

Now to the fictional rule...

Let us say that the cost of compliance for a slaughterhouse or any other business would be $5000 to use nice round numbers. if that slaughterhouse only sells 10000 pounds of meat or a factory produces 10000 widgets annually that cost has to be absorbed somewhere. Where possible that cost is passed on to the consumer. So in this case that would be 50 cents per unit.

Now suppose mega-corp does 10x the annual business of that smaller shop. Their cost/unit is only 5 cents per unit. Still a cost but as a percentage much smaller.

Here is the incideous part. The story ends one of two ways using your 90% figure...

1. The consumer is willing to pay 50cents more for the product and through government regulation mega-corp just made 45 cents more off every unit sold minus the cost of the lobbyist.

2. The consumer is not willing to pay 50 cents more for the product but will pay 10 cents. Now the smaller place cannot operate profitably and eventually closes while mega-corp stays in business and makes more per unit.

#2 is the more likely reasons for the 90% figure you use.

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It's not me it's spell check.

We may argue that this will not affect relatively small brewers, but I've already heard directly from the small brewer, and they believe it will impact them. To the point that they are seriously thinking of no longer being a micro-brewery, just because of the expense of dealing with this additional cost of disposing of their 1-ton/week wet grain. They are not dealing in selling animal feed in any way (we pick it up for free), but their attorney is responding to this threat right now. We have been told there will be paperwork we will have to attest to, but we haven't gotten it to read yet. Maybe there will be a way for them to slide around the very expensive requirements, but at least they feel it is dire enough that they need to respond right away.
Kit

It is easy to get off on our own biases and gripes and run the topic around. We are liberal, conservative, city, country, all different ways, and we see things differently, that is cool.

At any rate, it would appear this set of regulations is set to come about, as it is in its second round of comments, it needs no voting on or action by any elected leaders, it is one of those regulations that comes around on its own.

It would appear the regulations will affect our food and feed supply. Seems the cost of feed will go up a bit, and the number of feed sources might go down a bit.

Distillers has become a pretty big source of protein these days. Making it cost more, even if a seemingly small amount more, will have a big effect on meat production costs. The lick blocks and the bags of higher protein are going to be most effected by this.

From the wording of the many pages of rules, it seems they want to further regulate all feed producers someday. That step will have an even bigger effect on feed supplies, most especially on the smaller feed mills many of us tend to depend on.

If it is needed fine.

Is it needed for pet food more - it seems that feed more likely comes from overseas.

Is it needed for milk and meat supplies?

Is the FDA trying to protect our food supply, or protect the feed supply given to animals?

Should the USDA be in charge of a feed issue? What role does the FDA have in this, why are they in charge?

When the next set of rules come along in 5 years and put your small local mill out of business, the process started here, with this. When food prices go up, it wasn't ethanol, or greedy farmers, or bad weather causing it.

It was another booklet of paperwork, another set of fees and taxes, another round of plant closings due to extra expenses.

Will our meat and milk be any safer from the increased costs and fewer options?

Paul

What sort of "compliance" would fit a small operation and satisfy a mega slaughterhouse? Perhaps require an apartment for the USDA Meat inspector? On everything else there is scale.

I grasp your math, but I doubt it happens in real life, especially after reading the scope of this feed safety issue.

I think that this regulation will have little impact on small and medium feed facilities. The government will get assurances from the big operations to make sure the filth and chemicals are kept to a minimum.

But for now, we are just shadow boxing. Clearly, our debate here won't change anything. Writing to your Washington representatives about excluding those small feed producers that are already excluded, won't change anything. Since the market share of the breweries spent grain output is a tiny fraction of the whole feed issue, the focus is and always has been on the big guys.

But write this down for nostalgia sake, so years from now you can claim this as a victory of the little guy over the government and big business, " Way back in 2014, I sent a letter to Washington, protesting the regulation of hog feed. After a few months, it was announced that I had won. Things stayed the same. I was so happy that the government did something for me, that I voted Obama to run a third term."

You sound like you've got the inside track on this exciting regulation. I read it over a few times, acknowledging it may change in its final stage, but what, specifically, is the very expensive requirement?
Attest to paperwork? Is that lawyer talk for sign a receipt?

A year ago, I talked to a trucker that was hauling dried spent brewers grain that was being sent to Chins. Makes me doubt there is any interest to divert any grains to the landfill. If it is worth sending that far, there is a use for it here.

I'm not sure why you have taken to attack me on a personal level especially given that I am arguing against one-size-fits all regulation from Washington DC, how unrepresentative our representatives actually are, and how all regulations are disproportionately burdensome for small/mid size companies. Apparently I have angered you in a personal way and for that I apologize.

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It's not me it's spell check.

I happen to know where there is a shut down slaughter house, next to a closed tannery, near a boarded up furniture factory. The water in the stream that runs by all three is much more dangerous now. It seems that all the people that used to work at those places had to find a way to make it. It would appear that maybe meth lab run-off is probably right up there with lacquer, in terms of a stream pollutant. This is how regulation works. Government goons impose restrictions and monitor compliance until business becomes unprofitable. EPA regulations for instance. Did you know that there are no US plants manufacturing GAW (galvanized after weld) wire grid. Too much air pollution because you have to use a big vat to run a whole panel through. You can get past the regulations and do a single strand, then weld it, which makes the wire last half as long as GAW. So if you want wire that lasts, you have to pay the extra trucking to get it from a plant across the border, where the sky is made of glowing clouds of zinc vapor. But that is OK, because that is Mexican air that is being polluted, not part of the same air supply as the EPA protected air.
The proposed law works much the same. Drive American producers out of business, with inspectors worried about presence of contaminants and then when our only supply is the contaminated stuff from China, the inspectors just change their job duties. Instead of checking for the presence of any contaminants, they check to make sure contaminant levels "are within safe limits". I prefer having the choice to decide the contaminant levels that I am comfortable with, and I do every chance I get, (probably why I don't have Crohn's disease).
I don't have much trust for the people who, on one hand, tell us the importance of prion disease monitoring, and on the other hand, were the same folks who told us what a brilliant idea it was to feed ground up animal parts to herbivores. If you think the government is interested in much beyond providing their own job security, you are either un-informed, or you are you are on their payroll.

And, furthermore, if the FDA and USDA and others wanted me to view them as anything besides contemptible rogue agencies, maybe they should have someone of learning read them the tenth amendment to the Constitution of the United States of America, so that perhaps they could go through the motions of abiding by it.

You sound like you've got the inside track on this exciting regulation. I read it over a few times, acknowledging it may change in its final stage, but what, specifically, is the very expensive requirement?
Attest to paperwork? Is that lawyer talk for sign a receipt?

No, I'm no expert. I'm part of a tiny little group that raise our own food and feed ourselves. The micro-brewery from whom we get brewer's grain is one of a small local chain here in Oregon. Looking them up online there are about 8 locations over about 100 miles down the valley.

If this regulation passes as it is (and no, it probably won't but that's where we have to start), it looks as though each location would be required to dry their own brewer's grain if they were to sell/give it to farmers to feed animals. Otherwise, they would have to pay to have it taken to a dump site and disposed of. There is no reasonable way for each location to dry 1 to 2 tons of wet grain a week, and no profit in doing so. Therefore, they would have to pay to have it picked up and pay the dump fees which wouldn't be inexpensive.

SO FAR, without any final word from the corporate headquarters who are working with the attorney, and without a final version of the bill, the brewmaster says their current option is to quit brewing.

I don't do their books. I don't know what it would cost them. They could continue selling various commercial beers without being a micro-brewery. That's what she says will probably happen.

When I get the paperwork that ONE attorney deems necessary, I will be glad to share it.
Kit

Wrong. That only works for the huge producers. For all of the tiny micro-breweries, the brew pubs they don't have enough spent brewers grain to dry, pack and ship. Yet, their gross annual sales are over $500K per business so they get caught up in this. This is one more regulation set that will crush small producers.

No, that is unsustainable nonsense. Better to use resources locally as much as possible. Government should not put up hurdles to local use.

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SugarMtnFarm.com -- Pastured Pigs, Poultry, Sheep, Dogs and Kids

If you won't read the proposal that says $500,000 in animal feed production, there isn't much use discussing it.
We'll just have to wait and see what the final version reads. Then, one of us can stick their tongue out at the other and proclaim, "See, told you so!".
Reminds me of the RFID/NAIS that was to put small farmers out of business. Michigan requires it and beef and dairy farmers, large and small are doing great. The sky didn't fall after all.

Yes, and we won on the NAIS issue. We stopped the mandatory RFID and basically all of the NAIS nonsense. You were Pro-NAIS back then. Michigan may be requiring NAIS but fortunately you aren't forcing it on the rest of us. There is no need for the government to drive every back road and tag every chicken as they claimed they would do. They had some pretty loud nonsensical regulators on that drive.

NAIS died. It tried to come back in a second form. That died. It is now just a weakly watered down version used in a couple of states like Michigan where it isn't doing too much harm. The original NAIS program would have been a killer. Glad we killed it.

*sticking my tongue out at you on that one!* (Since you raised it.)

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SugarMtnFarm.com -- Pastured Pigs, Poultry, Sheep, Dogs and Kids

I said RFID/NAIS wouldn't hurt small farmers. Michigan and 3 or 4 other states are proof of it. Where are the dire consequences you predicted? You only proved fear mongering worked. I see this feed issue to be a lot more fear mongering. RFID was important to me and I have it. Spent brewers grain regulation has little effect on me. While Michigan ranks in the top few states for number of micro breweries, I don't know any that sell over a half million in animal feed, so I'm not concerned.

Michigan never implemented NAIS/RFID to the level that the USDA was proposing. What the USDA was proposing would have been a big problem. We stopped that train wreck. Twice. Now there is a little tiny version of it in Michigan. The Michigan version is not the original NAIS by any stretch of even the most creative imaginations. Michigan is no proof of anything you claim.

If you're not concerned then why do you spend so much time pushing your agenda?

I am concerned. That is why I push so hard to stop further government over regulation. I care. I vote. I speak up when I see this sort of government nonsense being thrust upon us from bureaucrats and lawmakers who have no real understanding of the burden of what they're trying to do. Or perhaps they do understand it as some people claim and perhaps they are trying to crush small businesses and small farms.

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SugarMtnFarm.com -- Pastured Pigs, Poultry, Sheep, Dogs and Kids

Some people don't realize the concept of precedent. If you allow the government oversight of spent brewers grain, where does it stop? What's wrong with a farmers nose? Are their no farmers that taste what they are feeding? If it has an off taste, smells bad, and makes your animals sick, it's probably not good to feed that feed. Heavy metals? Watch the paper for people getting sick from beer from a micro brewery, and don't get mash from them. This stuff is pretty simple. Not saying that a government agency could fathom it, but pretty simple. Once they start inspecting brewer's grain, next thing they will come out and inspect my round bales. If I have a moldy one from a shady corner of the field, I will have to pay to have the whole batch tested, and dispose of the moldy ones in a landfill. Instead of just putting it on an eroded spot. Because that mold could endanger the food supply.

It isn't $500,000 in total sales.

It is $500,000 in animal feed distillers grains.

This only applied to large breweries and doesn't affect small breweries at all.

It is important to realize this.

According to the FDA's Q&A sessions it is based on total gross sales averaged over the past three years adjusted for inflation for the entire establishment. Everything they're selling. Not just animal feed, not just carrots, not just apples. That is the problem that has come up repeatedly at the listening sessions and in comments to the FDA. If a farmer has an existing farm with lets say $490K of gross sales from other things then just $10K of sales from covered items (e.g., lettuce) throws him above the exemption. They said this is for all types of businesses so it would be for groceries and restaurants, for brewers and brew pubs. This means that $500K/365 days of restaurant is less than $1,300 in daily sales which is VERY small for a restaurant or pub. That in turns means almost everyone is covered by the FDA's new FSMA.

It is GROSS sales for the entire business. Not profits. Not sales of any particular thing like animal feed. Even brew pubs that give away the mash for free are faced with the FSMA regulations.

It is very important to realize this.

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SugarMtnFarm.com -- Pastured Pigs, Poultry, Sheep, Dogs and Kids

Yes the FDA has the right to go into this. As the FD & C makes it so.
the Federal Food, Drug, and Cosmetic Act enforced by the U.S. Food and Drug Administration.
Which regulates any processing facility that has food for human consumption, and FEED going into a FOOD Animal, sure will qualify under the FD & C

The United States Federal Food, Drug, and Cosmetic Act, is a set of laws passed by Congress in 1938 giving authority to the U.S. Food and Drug Administration to oversee the safety of food, drugs, and cosmetics.

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Oh my, dishes yet to wash and dry

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http://smg.photobucket.com/albums/0903/arabianknight/

There's where there is some confusion and there has been discussion at the USDA about this. They don't like the FDA trying to encroach on their territory. At one point the FDA claimed it would cover meat in the FSMA. The USDA pushed back and said no. The USDA won that one.

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SugarMtnFarm.com -- Pastured Pigs, Poultry, Sheep, Dogs and Kids

Well, the potential regulation has been changed/tabled. Fortunately some of the bigger interests also got involved and it's trickled down to little me. Good.

http://www.democratandchronicle.com/...eries/8102441/

Kit