Federal Issue Brief

 APHIS Seeks Comments on Proposed Environmental Impact Statement on Animal Carcass Management (October 25, 2013)

Formal Title: FR Docket No. APHIS-2013-0044; Environmental Impact Statement on Animal Carcass Management (October 25, 2013)

Brief Description:

The Animal and Plant Health Inspection Service (APHIS) has announced that it intends to prepare an environmental impact statement (EIS) to examine the potential environmental effects of animal carcass management options used throughout the U.S.  The EIS will analyze and compare all major and readily available mass carcass management options that may be utilized during an animal health emergency.  APHIS is considering classifying mass carcass management as management of 50 tons or more of biomass per premises.  In the EIS, The USDA APHIS intends to compare unlined burial and open-air burning disposal methods with other available carcass management options. These may include composting (on- or off-site), rendering, landfills compliant with the Resource Conservation and Recovery Act (RCRA), and other fixed facility options, such as incinerators compliant with the Clean Air Act, that could accommodate a large volume of carcasses over a short period of time. 
 
The notice identifies potential alternatives and environmental effects that will be examined in the EIS and requests that the public comment on these proposed alternatives and environmental effects and identify other issues that could be examined in the EIS.
 
Current APHIS regulations regarding carcass management, including those found in 9 CFR 53.4, are based on World Organization for Animal Health (OIE) recommendations and sound science.  APHIS regulations specify that animals infected by or exposed to foot-and mouth disease, pleuropneumonia, rinderpest, and certain other communicable diseases of livestock or poultry are required to be disposed of by burial or burning, unless otherwise specified by the APHIS Administrator.

Excerpts from AVMA Response:

The AVMA advocates for safe and environmentally responsible disposal of animal carcasses, whether on an individual animal basis or during mass mortality events, and we support increased research and education towards the development of appropriate methods and guidelines for animal carcass disposal.

The AVMA applauds the USDA APHIS for considering other effective means for mass carcass management beyond that of unlined burial and open-air burning.  Expanding the programmatic disposal options available will better allow animal health and emergency management authorities to determine site-specific, optimal disposal methods in mass mortality events while mitigating to the extent possible any risks that the carcasses or their disposal method may pose to public health, the environment, or other animals.  Such flexibility is especially needed in areas or situations where neither burial nor burning are allowed, acceptable, or feasible.

In the Federal Register, the USDA APHIS combined natural disasters and manmade disasters in the same category of “animal health emergency” as events resulting from pests, pathogens, or respective control measures for them.  Not all mass mortality events in animals are animal health emergencies, and the AVMA suggests that the USDA APHIS address those due to infectious causes separately from noninfectious events because the potentials risks posed by the resulting carcasses will be different.  For instance, the thousands of cattle that died during the October 2013 snowstorm that impacted South Dakota did not die because of a pathogen or pest, but because of the extreme elements of the natural disaster itself.  Consistent with current scientific literature and the conclusions of the Pan American Health Organization (PAHO), the AVMA recognizes that animals that die from injuries, including massive animal deaths in cases of natural disasters, generally do not represent a health hazard for humans.  Furthermore, the presence of carcasses as a result of a disaster and lacking another risk factor is not a cause for disease spread.

Considering the vast number and range of variables that can be associated with a mass mortality event in animals, we encourage the USDA APHIS to focus the EIS on some of the basic, common needs and restrictions while providing guidance for authorities who could then assess site-specific factors unique to the situation in their area.

Composting should be among the disposal alternatives seriously considered by the USDA APHIS as an effective means for mass carcass management.  Studies have shown that when performed properly, composting inactivates various pathogens, including the foot and mouth disease virus and avian influenza virus.  Furthermore, the composting is typically more economical and environmentally friendly than other alternatives and can generally utilize on-site materials, including manure, to achieve the proper compost mixture.

Background Documents:

Related AVMA Policies: