Farm groups and state agencies are calling on the Agriculture Department, the Food and Drug Administration and the Environmental Protection Agency to give rendering a greater role in their proposed strategy for reducing food loss and waste.
The draft strategy, released in December, includes a goal of cutting food loss and waste in half by 2030 using food banks, promotional materials, recycling and additional storage infrastructure. Food waste, it says, causes around 58% of landfill methane emissions released into the atmosphere
The strategy fails to mention rendering, the process of cooking meat and animal byproducts to create pet food, biofuels and organic fertilizer, according to comments from the North American Renderers Association, the California Department of Food and Agriculture, the Food and Agriculture Climate Alliance, and the (formerly North American) Meat Institute.
“Given the fact that North American renderers upcycle more than 54 billion pounds of raw material each year, we were disappointed to see that rendering is not mentioned,” North American Renderers Association President and CEO Kent Swisher told the agencies in a comment.
Swisher said renderers recycle 99% of unwanted meat from farms, meat processors, supermarkets, meat lockers and restaurants and, in doing so, keep it from entering landfills. They also recycle 1.6 billion pounds of used cooking oil from restaurants into renewable fuels, he added.
In addition to giving the industry more consideration throughout the strategy, Swisher called on EPA to include rendering in its Wasted Food Scale. The scale, which lays out and ranks pathways for preventing or managing wasted food, “did not incorporate or acknowledge rendering’s significant contributions to [food loss and waste] reductions,” he said.
A separate EPA report on food waste issued last year said rendering wasn’t evaluated for its environmental impact “due to a lack of available environmental data.”
Annette Jones, the director of the Animal Health and Food Safety Services Division of the California Department of Food and Agriculture, said in a comment that rendering “has been an integral part of animal food recycling and biofuel production in California.”
“The draft strategy and the new Scale, if not revised to highlight the vital role of rendering, would unjustifiably omit a critical sector that helps EPA and the State of California achieve the target goals of waste reduction and recycling,” she wrote.
Approximately 50% of an animal carcass is inedible, which makes rendering an important method for reducing meat industry’s food production footprint, according to a comment from the Food and Agriculture Climate Alliance, whose members include the American Farm Bureau Federation, National Farmers Union, Environmental Defense Fund, and a broad range of ag groups.
One example can be seen with feather meal, said Ashley Peterson, senior vice president of scientific and regulatory affairs for the National Chicken Council. Poultry feathers, an inedible product, are ground and dried by renderers to serve as a “slow-release high-nitrogen organic fertilizer or a feed additive for livestock.”
The rendering industry has been making products like soap and candles for centuries, Peterson said. Rendering facilities are currently “seeing an influx” in demand “unlike any other time in the past” and should receive investments to help them keep up with animal protein increases.
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“Ensuring that rendering facilities can be easily expanded or built would be a great way to reduce waste and improve the repurposing of byproducts that would otherwise go to waste,” Peterson said.
Swisher, with the North American Renderers Association, also encouraged the agencies to consider a “technology-neutral approach” when looking at funding for organic recycling technologies. Federal subsidies for these technologies, he said, have “come at the expense of traditional organic recyclers like the rendering industry.”
“Subsidizing new technologies and industries allows the unfair advantage to collect raw materials that might have already been collected by the rendering industry. Counting this expansion as progress towards goals is not accurate,” Swisher said. “It is simply taking a supply stream from one organic recycler to another.”
The American Frozen Food Institute, the Global Cold Chain Alliance, the Meat Institute, the National Fisheries Institute, the National Pork Producers Council and the Washington Red Raspberry Commission urged the agencies to “remove the distinction” given to “raw” or “fresh” fruits and vegetables when compared to “frozen” ones in the report. The groups, in a joint comment, called freezing “a powerful tool to limit food loss during post-harvest, processing, and transportation and can extend the marketability of products that otherwise might not meet visual or physical specifications required by grocery stores.”
The groups, in their comment, agreed with the agencies’ assertion that cold chain capacity is currently lacking nationwide. They said USDA should put Food and Agriculture Learning Program grants toward expanding frozen and cold storage in schools, applauding its Farm Storage Facility Loan program, which can help finance cold storage upgrades on farms.
Andrew Harig, vice president of tax, trade, sustainability and policy development at the Food Industry Association, praised the strategy’s support for food donation incentives in his comment. He encouraged federal agencies to look at expanding capacity and infrastructure to manage “surges in demand for food donations.”
“One of the lessons COVID revealed was that – while the system of food banks and food kitchens do amazing work everyday serving their communities – they can also struggle to oversee surges in demand caused by unexpected events,” Harig wrote.
Susan Backus, vice president of regulatory and scientific affairs for the Meat Institute, said improvements in storage capacity are needed at food banks, especially when it comes to meat. Meat is one of the “top three most needed foods” among food charities, though several of these organizations struggle to have enough space to safely store, pack and distribute this food type, she said.
They advocated for the development of more protein pack rooms in food banks, which are places where meat can be repacked and distributed in “consumer friendly sizes.” Eight protein pack rooms currently exist, Backus said in comments.
Harig, with the Food Industry Association, also said the group’s member companies generally support more data collection on food waste, but “are extremely wary of the creation of new mandates, obligations, and cost-centers.” Many small and midsize companies find collecting and reporting data on waste “prohibitively expensive and time-consuming,” he said.
"We encourage the agencies to approach enhancing the measurement process with a focus on creating incentive based opportunities and capacity building for the entire supply chain,” he said.
Stephanie Johnson, vice president of government relations for the National Grocers Association, said she appreciates USDA’s plan under the strategy to “provide outreach on the benefits of using tax credits to encourage the donation of food.” Small grocery stores with small staffs sometimes struggle to find the time or staff resources needed to organize food donations, she said.
“We believe that providing tax credits to make food donation a financial incentive instead of an additional cost encourages participation and will lead to an increase [in] retailer participation,” she wrote in a comment.
She also said retailers are concerned about potential legal actions that could result from donations of products that have passed the date on their label. The USDA, she said, has “committed to outreach on liability protections under amendments to the Bill Emerson Good Samaritan Food Donation Act,” but she asked the agencies participating in the strategy to look for more opportunities “across the supply chain” to educate about date labeling.
National Association of State Departments of Agriculture CEO Ted McKinney, in a comment, said federal agencies should coordinate with state departments of agriculture on implementing the goals laid out in the draft strategy. State agriculture departments, he said, are already working on minimizing food waste. He pointed to CDFA, which recently updated its website with additional information about food loss and waste, as one example.
“Tackling this problem will require federal and state agencies to work cooperatively alongside industry and community stakeholders to look at every part of the food system,” McKinney said. “Collaboration across the entire food supply chain is paramount in developing effective strategies.”
State and local food authorities are “often closer and more engaged with agriculture and food producers in their localities than national authorities,” which makes them useful partners in this effort, the Food and Agriculture Climate Alliance said in their comment.
“State and local authorities can help to tailor approaches that reflect the “reality on the ground,” increasing the chances of successful processes being implemented,” the organization’s comment said. “Efforts to address food loss and waste are going to require broad support to be successful and the unique position of state and local officials and organizations are an invaluable tool for helping achieve this buy-in.”
As part of the draft plan, USDA’s National Institute for Food and Agriculture said it would infuse the Community Food Projects Competitive Grants Program with $15 million of American Rescue Plan Act funding. The money, the draft strategy says, will "help develop links between food producers, providers, food recovery organizations and emergency feeding organizations to get surplus wholesome food to individuals via emergency food assistance organizations.”
International Fresh Produce Association Chief Science Officer Max Teplitsky, however, expressed concern about for-profit organizations not being eligible for these funds, which he says are set to go only to a few types of organizations – public food service providers, tribal organizations or private nonprofit entities.
“[T]hese restrictions on eligibility risk long-term sustainability of food loss recovery programs,” Teplitsky said in a comment. “Hundreds of years of economic theory and practice have established that there is no substitute for market-driven programs, and only market-driven programs remain sustainable once short-term public investment is redirected.”
He also said the agencies’ consumer education campaigns should not emphasize the message of “food for compost” around fruits and vegetables. Instead, he said they should be “prescriptive” and focus on promoting consumption.
“Food, especially highly nutritious foods, such as fresh fruits and vegetables, belongs on the plates of children, and not in compost piles,” he wrote.
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