Baise: Contaminants in livestock and poultry manure

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EPA has spent a lot of your tax money to have an outside contractor from Boston review contaminants found in livestock and poultry manure. The EPA report reviews pathogens and contaminants in manure as an emerging concern impacting water quality.

The 125-page report is a roadmap for EPA to insert itself further in regulating concentrated animal feeding operations (CAFOs). The report is entitled Literature Review of Contaminants in Livestock and Poultry Manure and Implications for Water Quality. It was issued July 13, 2013.

By the time you finish reading this report, you are convinced that livestock excretion is a source of pathogens, antimicrobials, and hormones "…that have the potential to cause infections in humans." (It is scary stuff because the report claims runoff carries the excretions to waters of the U.S.)

The report claims there is evidence of linkage between antimicrobial-resistant human infections and foodborne pathogens from animals. Further, the report advises us that hormones excreted from all livestock "may contribute" to the risk of aquatic life and likely impacts fish reproductive fitness and behavior.

The American Meat Institute (AMI) posts some interesting facts regarding the use of antibiotics. For example, the EPA report estimates "60-80 percent of livestock and poultry routinely receive antimicrobials." Interestingly, there is no citation to this statistic. AMI claims the number comes from the Union of Concerned Scientists. AMI suggests EPA may be “cooking the books” by using data from a questionable source.

Another theme of the executive summary is that "overuse and/or misuse of antimicrobials…can facilitate the development and proliferation of antimicrobial resistance, an issue of concern for animal and human health protection."

On page 27 of the report, it is claimed that over 29,000,000 pounds of antimicrobials were sold for livestock use in 2010 or "an estimated 3 to 4 times more than the amount used by humans." I may have missed it but I did not see any lengthy discussion advising the reader that the Food and Drug Administration regulates antibiotics administered to animals that produce food. Likewise, there is no discussion about FDA's extensive guidelines about how antibiotics must be used to ensure safety for humans and animals. The entire thrust of the report is clearly noted in the summary, which is to show overuse and misuse of antimicrobials.

For environmental managers of CAFOs, this report provides you with a roadmap of the future. EPA is not going away and will be using the argument that antibiotics, when used in animals, will cause humans to become resistant to those antibiotics and such use creates water quality issues because of runoff from feedlots and fields.

What this report and EPA do not seem to understand is that when antibiotics are used in livestock, there are strict withdrawal periods which must be followed before animals and poultry are processed for foods. It may be news to EPA and the contractor drafting this report that FDA has tolerance levels that are deemed unsafe, and if tolerance levels are exceeded, the animals are not processed for food.

The contractor, The Cadmus Group, Inc., prepared this literature review report for EPA. The company is located in Waltham, Massachusetts, and proudly touts that it has recently won a five-year contract to work on EPA's global climate-change projects. These projects include work with EPA's Center for Corporate Climate Leadership. It also has been awarded a seven-year $116.5 million contract with EPA's Drinking Water Protection Division.

As you can see, Cadmus has just outlined its work plan involving agriculture and you.

Gary H. Baise is a principal at OFW Law (Olsson Frank Weeda Terman Matz P.C.). This article first appeared in Farm Futures magazine. The opinions presented here are expressly those of the author. For more information, go to

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South Dakota  |  December, 17, 2013 at 09:24 AM

Gary, nice review. Yes, the EPA is comming and we may be able to fend them off on antibiotic issues, but probably not on Air Quality andEnvironmental impact. In future, US producers will no doubt have to find better ways to control odor, GHG's, and pathogens found in manure.

Thom Katt    
Midwest  |  December, 17, 2013 at 04:28 PM

Wm@eXpertCo, the reverse is actually more likely. EPA pretty much struck out on regulating gaseous emissions from livestock operations and doesn't have any mandate to regulate odor. That is part of the reason that you are seeing Obama's EPA with the encouragement of the radical environmental and animal rights fringe go after this anti-biotic red herring. We have to tell both the scientific and the emotional story to convince the consuming public that we are doing the right thing to keep our social license to operate. If we don't keep that, we will be figuring out how to operate under the regulations handed to us.

Thom Katt    
Midwest  |  December, 17, 2013 at 04:35 PM

Gary, one thing left out of the report that you didn't comment on is EPA's failure (and that of the scientific community in general) to recognize the fate of antibiotics, hormones and other substances in the environment. Many of the compounds used in livestock exit the animal in a depleted or degraded form. For some compounds, further degradation occurs in manure storage. Exposure to sun and air causes more degradation. And, believe it or not, soil microbes are collectively voracious little pharmacuetical comsumers. In other words, the half life of the various compounds must be considered when determining what is a problem, what isn't a problem and when. There isn't much science along that line of thinking/inquiry.

SD  |  December, 17, 2013 at 10:40 PM

Time we all quite and let them feed themselves- the geopolitical consequences of hunger are pretty intense.

James Benson Family    
December, 22, 2013 at 07:17 AM

The EPA is as always not policing the metro discharge. What about the pathogens, antimicrobials, hormones, and human medications in our water.


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