A Nov. 15 letter sent by Valley Proteins, Inc. to its customers has raised concerns that one of the most popular options for disposal of horse carcasses might soon become either prohibitively expensive or eliminated altogether.

For 50 years, the Winchester, Virginia rendering company has provided dead stock removal services to Maryland farmers – including those with horses. But the United States Food and Drug Administration has proposed a new rule regarding the use of dead stock in animal feed that could, in the company’s words, “seriously jeopardize the continuation of this service.”

It’s all part of the FDA’s attempts to further safeguard the country’s animal feed supply against the agent believed to cause bovine spongiform encephalopathy (BSE, or “Mad Cow” disease). This infectious agent is believed to reside in certain “high risk” tissues, primarily the brains and spinal cords of uninspected cattle or cattle 30 months of age or older; the entire carcasses of uninspected cattle; tallow derived from the materials in question; or mechanically separated beef derived from these same materials.

Under the current rule – which is based on the FDA’s 1997 feed regulation — only ruminant feeds (those fed to cattle and sheep) must be free of these tissues. According to an FDA press release dated Oct. 4, “The removal of high-risk materials from all animal feed – including pet food – will protect against the transmission of the agent of BSE that could occur either through cross-contamination of ruminant feed with non-ruminant feed or feed ingredients during feed manufacture and transport, or intentional or unintentional misfeeding of non-ruminant feed to ruminants on the farm.”

In its letter, Valley Proteins argues that the proposed rule “will require Valley Proteins to substantially increase service charges or exit the dead stock removal business. Disposal alternatives will likely become fewer and more expensive in this era of stricter environmental controls.

“There is no scientific need for this new rule,” the letter continues. “The current rule, established in 1997, is working – and the livestock industry’s compliance is 99 percent. After more than 500,000 tests, only one animal raised in the U.S. has ever tested positive for BSE. That animal was born prior to the implementation of the current feed rule.”

The company goes on to say in its suggested letter to FDA officials, “The alternative disposal means, such as burying the animals, are also expensive and a potential environmental disaster. We will see much tighter environmental regulations and fewer places to dispose of the material.”

The proposed rule is reportedly in the “comment phase” right now, so Valley Proteins is urging its customers to send their comments to the FDA, as well as their senators and representatives.

Jane Seigler of Reddemeade Equestrian Center, a training, leasing and boarding facility in Silver Spring, has some thoughts on the subject. “The concern is that if [the rule’s] implementation substantially increases the cost of dead stock removal services, or causes them to go out of this business altogether, as Valley alleges in its letter, there may be increased pressure on some farmers to sell aged or disabled horses at auction for slaughter, rather than having them humanely euthanized at home (and removed by services such as Valley),” she says.