EPA wants to you

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EPA Manure The 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.

Discrepancies and Questionable Sources
The American Meat Institute (AMI) posts some interesting facts regarding the use of EPA Manure 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.

A Required Roadmap
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.

Editor’s Note: Gary H. Baise is a principal at OFW Law (Olsson Frank Weeda Terman Matz P.C.). This article first appeared in Farm Futures magazine and at PorkNetwork.com. For more information, go to www.OFWlaw.com.


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