erning some of the noninspected plants presently as against federally And thank you, Mr. Chairman. Senator JORDAN. Thank you very much, Mr. Pringle, we appreciate your testimony. Mr. PRINGLE. Thank you. Senator JORDAN. It has been very helpful to us. Our next witness is Mr. Kaufman, who is chairman of the Toxigenic and Bacteriological Committee, Grain and Feed Dealers National Association, of Minneapolis, Minn. We are very glad to have you with us. STATEMENT OF HENRY H. KAUFMAN, CHAIRMAN, TOXIGENIC Mr. KAUFMAN. Mr. Chairman and members of the committee, I am Henry H. Kaufman, grain laboratory manager, of Cargill, Inc., Minneapolis, Minn. My responsibilities include research in grain, livestock and poultry feeds, and oil seeds. I am a member of the American Association of Cereal Chemists, and the American Society of Agricultural Engineers. This statement is given on behalf of the Grain and Feed Dealers National Association, of which I am chairman of the Toxigenic and Bacteriological Committee. association is The Grain and Feed Dealers National Association is industry wide and nationwide. It represents 1,700 firms ranging in size from the smallest country elevators and feed mills to the largest grain marketing, feed milling, and processing firms. The membership also includes 56 State and regional associations which represent approximately 15,000 additional grain, feed, and farm supply firms. We would like to speak on two subjects being considered by your subcommittee. They are H.R. 16363, the Wholesome Poultry Products Act of 1968, and title I, section 25, of S. 3383. termine whe estimate the ing salmonel Section 2 products by ingredients. ly distribute salmonella" of salmonel the conclus epidemic in points in a monella in There is cludes that tamination been foun Federal co of Agricu monella co sion is on populatio The Grain and Feed Dealers National Association endorses reasonable and practical efforts to protect consumer interest in obtaining wholesome poultry products, to provide a healthy market environment in which poultry and allied industries, including our own, will prosper. Wholesome poultry products will help producers and processors expand their markets by minimizing disease and infection. The national association did not participate in the development of the Wholesome Meat Act nor did we testify on H.R. 16363. However, the national in contrib and we future." Mr. Cl placed in Senato Mr. K Senato may be i Mr. F This grains. little bas Detec ficult an orate sc More Techni easily d 1 Senat 2 Ibid. 3 Ibid. 4"A S Feeds," Decembe association is disturbed by provisions in S. 3383 which would require an additional inspection of grain and other commodities used as poultry feed (title I, sec. 25). The enactment of this section would seriously disrupt our industry, as well as penalize the producer and consumer of poultry products. Implications of section 25: In evaluating the purpose of section 25, Congress, governmental agencies and industry need to survey the incidence of salmonella; determine where the greatest source of contamination is likely to occur; estimate the costs and determine the benefits of inspecting and regulating salmonella infection. Section 25 seeks prevention of salmonella contamination in poultry products by requiring inspection of feed grains and other poultry feed ingredients. Section 25 if predicated upon the assumption that, "Widely distributed animal feeds have been found heavily contaminated with salmonella" 1 ***. Citing feed grains as "* * * 2 an important source of salmonella contamination", the sponsor apparently has accepted the conclusions of a 1967 Public Health Service report on a salmonella epidemic in New York which attributed contamination at multiple points in a frozen dessert preparation to, among other things, "salmonella in the poultry feed * * *” 3 There is a considerable body of creditable scientific evidence that concludes that feed grains are not an important source of salmonella contamination and that poultry feed ingredients made from grain_have been found infrequently contaminated with salmonella. A 1966 StateFederal cooperation survey under the direction of the U.S. Department of Agriculture found that there was a 0.66 percent incidence of salmonella contamination in grain. The study continued: "Feed transmission is only one of many modes of transmitting salmonellosis in animal population. Attempts to evaluate the significance of each of these in contributing to the overall salmonella problem is not known to us, and we feel that this type of study warrants consideration in the future." 4 Mr. Chairman, I would like to ask that the text of that article be placed in the record at the conclusion of my prepared remarks. Senator JORDAN. Do you have that? Mr. KAUFMAN. Yes, I do. Senator JORDAN. If you do, will you give it to the reporter so that it may be included in the record at the conclusion of your remarks? Mr. KAUFMAN. Yes; thank you [handing]. This research survey reported low incidence of salmonella in feed grains. At best, evidence to the contrary is mixed and therefore offers little basis for legislative action. Detection, identification, and eradication of salmonella is a very difficult and technical problem. Detection and identification require elaborate scientific testing which is complex and expensive. More than 1,200 different strains of salmonella have been identified. Technical experts agree that basic research and the technical art of easily detecting and identifying salmonella is still incomplete. 1 Senator Mondale, April 25, 1968, Congressional Record, p. S4485. 2 Ibid. 3 Ibid. 4"A Survey To Determine the Salmonella Contamination Rate in Livestock and Poultry Feeds," v. 151, Journal of American Veterinary Medical Association, pp. 1857-1860, December 15, 1967. Since technical information is incomplete, salmonella problems clearly do not lend themselves to legislative or regulatory remedies. The last U.S. census (1963) identified more than 20,000 grain elevators; hay, grain, and feed stores; and feed mills preparing animals feeds. To comply with section 25 each of these establishments that produced or shipped poultry feed ingredients would have to have access to new inspection services and laboratory facilities. This provision could possible require a qualified inspector in each establishment. Even assuming that the highly qualified technicians necessary for ingredient analysis were available and could be hired, the public expense of maintaining such an inspection system would seem highly disproportionate to any intended benefit. Laboratory testing techniques require at least 4 to 5 days to determine whether or not salmonella is present and to identify a particular strain, the time may be doubled or tripled. As a practical matter, shipment delays for such inordinate periods could not be tolerated. The rail demurrage expenses to the industry alone would be several million dollars annually. Further, shipment delays would aggravate the already existing freight car shortage. All feed grains and other ingredients would have to be tested for salmonella before being offered, sold, or shipped in interstate commerce. It would be impossible for the elevator operators to know whether corn and other feed grains will be used for poultry feeds or other purposes. The majority of country grain elevator and feed manufacturers upon whom this burden would fall are ill-equipped to assume the additional cost for equipment, handling facilities, and inspection services that would be so required. The cost of testing for salmonella at each level in the grain marketing system would be very high and would bear little relation to the incidence of salmonella in grain and even less relation to intended consumer benefits. of prevention operations: to tutions; and areas of mutu The indust the Food and These practic firms, under t or feed oper grain and p It is also w already exist Imposition of new feed grain or poultry ingredient inspection requirements would be inconsistent with amendments to the U.S. Grain Standards Act, which have been passed by the House of Representatives and are presently before your subcommittee with uniform support of the U.S. Department of Agriculture, the Interstate Commerce Commission, the Nation's railroads, and the commercial grain trade. The amendments remove requirements for mandatory inspection of grain shipped in interstate commerce and by so doing permit maximum utilization of facilities and equipment at a minimum of cost, delay, and inconvenience while not diminishing quality standards of grain in either domestic or foreign commerce. The amendments to the U.S. Grain Standards Act facilitate rather than retard orderly marketing of grain by eliminating requirements which burden interstate commerce but which are no longer needed by the commercial trade. Section 25 inspection requirements would be a reversal of the laudable progress that is represented by these amendments. PRESENT ACTIVITY Last year the national association established the toxigenic and bacteriological committee to study bacteriological and toxigenic problems in the grain and feed industry. This committee is to suggest methods and means of advancing the technical knowledge and practical means and the U.S salmonella f expenditures fiscal year Research Se 1 in 1968, $1. $768,000 in showing th partment o sible to rea ments at co The Gra that scien section 25 are to the of S. 3383 undertake flected in Chairman 25 in your I appr the Grai (The a [From A SURVEY (By Jose A stat salmonel finished states. A tota from ea as follo samples positive of prevention and control of any contamination in grain and feed operations; to recommend needed research to public and private institutions; and to act as liaison between industry and Government in areas of mutual interest. The industry carries out good manufacturing practices required by the Food and Drug Administration in preparing medicated feeds. These practices insure that a quality product is maintained. Also, all firms, under the Federal Food, Drug, and Cosmetic Act, whether grain or feed operations, must maintain premises that insure wholesome grain and products. It is also worth noting that section 25 requirements would duplicate already existing controls. Both the Food and Drug Administration and the U.S. Department of Agriculture have programs to eliminate salmonella from animal feeds. The U.S. Department of Agriculture expenditures for salmonella research and control have increased. In fiscal year 1967, the U.S. Department of Agriculture Agricultural Research Service-spent $676,700 on salmonella research and control; in 1968, $1,163,100. The State agricultural experiment stations spent $768,000 in 1967 for salmonella research. Without conclusive evidence showing that existing Food and Drug Administration and U.S. Department of Agriculture programs are adequate, it hardly seems possible to reach legislative findings that impose new inspection requirements at considerable cost upon the grain and feed industry. CONCLUSION The Grain & Feed Dealers National Association respectfully submits that scientific research to date does not demonstrate the need for section 25 ingredient inspection requirements. Important as feed grains are to the economy of this country, the proposal in section 25, title I of S. 3383 would dramatically revolutionize the marketing system. If undertaken, the increased costs in the marketing of grain will be reflected in higher consumer prices and/or lower producer returns. Mr. Chairman, we urge your committee to omit consideration of section 25 in your deliberations. I appreciate this opportunity to appear before your committee for the Grain & Feed Dealers National Association. (The article submitted by Mr. Kaufman follows:) [From the Journal of the American Veterinary Medical Association, Dec. 15, 1967] A SURVEY TO DETERMINE THE SALMONELLA CONTAMINATION RATE IN LIVESTOCK (By Joseph N. Allred, D.V.M.; John W. Walker, D.V.M.: Victor C. Beal, Jr., Ph. D.; and Francis W. Germaine, B.S.) SUMMARY A state-federal cooperative survey was conducted in 1966 to determine the salmonella contamination rate in 4 categories of feed ingredients and in 3 finished feed categories. This survey was limited to the basic feed mills in 26 states. A total of 12,770 samples were collected at 724 feed mills; the samples taken from each category, the percentage positive, and their standard deviations are as follows: grain, 2,698 samples with 0.66±0.19% positive; oilseed meal, 2,629 samples with 2.28±0.32% positive; fish meal, 805 samples with 4.72±0.92% positive; and animal by-products, 869 samples with 31.07±2.18% positive. In the finished feed categories: cattle feed, 2,597 samples with 0.85±0.22% positive; swine feed, 1,567 samples with 3.13±0.58% positive; and poultry feed, 1,605 samples with 5.23±0.73% positive. Work has been done to indicate that feed transmission of salmonellosis does occur in livestock and poultry populations. In 1960, an attempt was made to survey the occurrence of pathogenic organisms in feeds.1 This survey attempts to determine the incidence of salmonella in the 3 most common finished feeds and in their 4 major ingredients. Design and Conduct of the Survey In designing a survey, there are 3 items that are important to consider: (1) that the survey be designed so accuracy of the sampling estimate may be determined from the sample itself, providing an unbiased sample estimate; (2) that as much information as possible be obtained within the practical limits of the survey; and (3) that the sample drawn be representative of the population sampled. To obtain an unbiased sample estimate with the accuracy being determined from the sample itself, it is necessary to use some form of random sampling. This means that each mill and each state in the population has a known chance (which is different from zero) of being in the sample. Tables of random numbers were used for this purpose. 2 The 26 states participating in the survey were selected on the basis of availability of state and federal animal health personnel and on the availability of laboratory facilities. This limited the results of the survey to these states. Also, the survey was limited to the basic feed mills in each state. The number of samples assigned to each state for each category was prorated according to the annual tonnage of feed produced. The samples prorated to each state were assigned at random among the basic feed mills in the state, regardless of their individual annual production. Restrictions were put on the survey by taking part of the plants from each state and taking the samples from these plants. This is called "cluster sampling." Materials and Methods Samples were collected by a veterinarian or livestock inspector in a sanitary manner to avoid cross-contamination. Approximately 50 Gm. of feed or ingredient was sealed in plastic bags, identified with a plant code number, a sample number, a feed category, physical form code and then delivered to an animal disease diagnostic laboratory for culturing. All laboratories were instructed to use the Recommended Procedures for Isolation of Salmonella From Animal Feeds and Meat Byproducts, ARS-91-36, modified to include a lactose broth pre-enrichment incubation before inoculating the tetrathionate broth. All suspected salmonella cultures were serotyped at the nearest Animal Health Division regional serotyping laboratory and university laboratory." Reports were compiled by ANH poultry diseases staff and the biometrics staff in Hyattsville, Md. Results The incidence of salmonella contamination of 3 finished feeds and 4 feed ingredients was determined in 26 states. In order to determine the accuracy of these contamination estimates, the standard error was calculated for each estimate by their standar 1 Morehouse, G. E., and Wedman. E. E., Salmonella and Other Disease Producing Organisms in Animal By-Products, J.A.V.M.A., 139, Nov. 1, 1961, 989-995. 2 Orientation of state and federal animal health personnel was conducted by Dr. C. J. Pfow, assistant to the veterinarian in charge, St. Paul, Minn.; Dr. C. D. Murphy, poultry epidemiologist, College Station, Texas: Dr. D. R. Stauffer, regional poultry epidemiologist, Orono, Maine; and Dr. W. S. Thompson, poultry epidemiologist, Harrisonburg, Va. 3 A basic feed mill is an establishment in which grain and 1 or more additional ingredients are used to manufacture a finshed feed, e.g., an establishment with all 7 categories of the survey availabble for sampling. The basic feed mills manufacture 68% of the feed produced. 4 National Animal Disease Laboratory, Ames, Iowa; Phoenix, Ariz.; Atlanta, Ga.; and Orono, Maine. 5 University of Massachusetts, Amherst, Mass. |