Regulatory Services News Vol. 61, No. 3 Feed - Fertilizer - Milk - Seed - Seed Testing - Soil Testing Fall 2018 Director’s Digest Regulations to be revised were filed in July. If everything goes well, these There is a lot about laws and regulations that amended regulations will become effective this com- I have learned since taking this job six years ago and ing fall. As always, we will print booklets of the I am sure there is still much I don’t know. With our amended regulations to hand out and they will also mandated programs (feed, fertilizer, seed and milk) be available on our website. If you want to view the there are laws and then there are regulations. Basi- proposed amendments for these or other regulations, cally, the laws define what we do and the regulations you may view these at the Kentucky Administrative lay out how we do it. In 2017, the Kentucky legisla- Register http://www.lrc.ky.gov/kar/contents/ ture passed a new statute (13A.3102) providing for registers/registers.htm. You may also sign up to re- expiration of administrative regulations. Any regula- ceive notices of changes in regulations by subscrib- tions written on or after July 1, 2012 shall expire ing to Kentucky Reg Watch at https:// seven years after their last effective date and any reg- secure.kentucky.gov/regwatch/. ulations written before July 1, 2012 shall expire on Requiring us to review our regulations at July 1, 2019 unless they are amended or you seek least every seven years helps ensure we are staying certification that they are fine as written. on top of current market conditions. We welcome Our seed law regulations were amended in any input you might have on needed amendments. January 2017. Feed regulations were last revised in 1999, fertilizer regulations in 2000, and milk regula- Agriculture Without Animals tions in 2001. My hope is that we will review and I recently attended the national meeting of revise all regulations except seed before July 1, the American Society of Animal Science and lis- 2019. tened to several interesting presentations during the We have been working on revising the feed contemporary issues sessions. Dr. Robin White from regulations for a little over a year. The pet food reg- VPI presented results of her research on “Nutritional ulations (12 KAR Chapter 3) were filed in June and and greenhouse gas impacts of removing animals the livestock feed regulations (12 KAR Chapter 2) Continued on page 3 What’s Inside Division Contact Information . 2 Potential Fertilizer Regulation Changes . 4 Seed Germination Averages. 5 How’s your pet food stack up?. 8 Feed Facility Inspections under FSMA . 8 What is a FERN laboratory?. 10 KAES Annual Report, part 2. 12 Division Contact Information Inspectors Phone: (859) 257-2785 Mark Barrow Fax: (859) 323-9931 [email protected] Executive Director Nathan Keith Dr. Darrell D. Johnson [email protected] [email protected] John Flood Auditor [email protected] Robert Counts, Jr. [email protected] Brad Johnston [email protected] Feed & Milk Programs Dr. Alan Harrison-Director David Mason [email protected] [email protected] Kristen Green, Registration Specialist Warren Pinkston [email protected] [email protected] Bob Hickerson, Milk Inspector Terry Prather [email protected] [email protected] David Tompkins, Feed/Fertilizer Lab Supervisor Bart Young [email protected] [email protected] Kristin Brock, Milk Laboratory Supervisor Laboratories & Soils Program [email protected] Dr. Frank Sikora-Director [email protected] Michelle Young, Staff Assistant Feed [email protected] Dr. Solomon Kariuki-Lab Manager [email protected] Dusty Stewart, Staff Assistant Milk [email protected] Diane Hunter, Soils Lab Supervisor [email protected] Fertilizer & Seed Programs Stephen McMurry-Director Quality Control Director [email protected] Dr. Sharon Webb [email protected] Tina Tillery, Seed Laboratory Supervisor [email protected] June Crawford, Staff Assistant Fertilizer [email protected] Fax: (859) 257-9478 Marilyn Smith, Staff Assistant Seed [email protected] Fax: (859) 257-7351 Inspector Coordinator Jim True [email protected] 2 — Regulatory Services News, Third Quarter 2018 Director’s Digest, continued from US Agriculture”. It’s no secret that animal agri- can’t use which is why they are often referred to culture has been under fire for its contribution to as nature’s recycler. Many byproducts used by greenhouse gases and that meat is an unhealthy ruminants would have to be disposed of in a plant source of nutrition. The 2015 Dietary Guidelines Ad- only system. visory Committee claimed that plant-based diets Comparing ecological footprints/pound of product would promote health and improve long-term sustain- is not a fair comparison as a pound of meat has ability of the US food supply. This and other reports different nutritional properties than a pound of imply that modification or elimination of animal agri- broccoli. culture would offer benefits to society with minimal Ruminants allow harvesting of 25% more land and acceptable deleterious effects. area since much of the acreage harvested by rumi- Dr. White and Dr. Mary Beth Hall did a com- nants is not suitable for crops. prehensive study to evaluate what would really hap- Bioavailability of many nutrients is higher in ani- pen if we eliminated animal agriculture in the US. mal products versus plant products. Many assumptions have to be made in this type of Animals provide more than food. A multitude of work and in this case they assumed that land used for animal-derived products are used in adhesives, animals would be converted to production of grains, ceramics, cosmetics, fertilizer, germicides, can- legumes, fruits and vegetables. dies, refining sugar, textiles, upholstery, photo- It’s hard to reduce an eight page report into a graphic films, ointments, paper, heart valves, and few paragraphs but there were some key points that I other products. found important. Removing animal agriculture from the US would reduce greenhouse gas emissions but Also cited in many reports is that humans would only by 2.6%. There are inefficiencies in converting be healthier without meat in their diet. One example feed to meat, milk and eggs so going to all plant food is people who self-report over consuming meat have a would increase total food production by 23% but 20% higher risk of coronary heart disease due to satu- there are key nutrients provided in animal proteins rated fats. Overconsumption of many things can re- that would have to be supplemented in an all plant sult in increased risk of death. As I heard a wise man food diet. Formulating diets for humans from all once say: “Quantity and frequency is a key to avoid- plant foods would provide a greater excess of dietary ing many problems.” A dietary interpretation of this energy and would be lacking in several essential nu- is: “If you eat or drink too much of something too trients. Without animal-derived foods, domestic sup- often, it will cause problems.” A well balanced diet plies of calcium, several essential fatty acids, vita- is critical to good health and a long life. You can be mins A and B12 were insufficient to meet the require- healthy on an all plant food diet, with proper supple- ments of the US population. For the deficient fatty mentation, but animal-source foods can be a valuable acids and vitamin B12, animal products are the only part of a healthy diet. As illustrated in the next sec- nonsupplemental sources commonly found in human tion, animal source foods provide high quality protein diets. and are a source of the most deficient micronutrients Some other often overlooked benefits of ani- in the human diet. mal agriculture include: Animal production is often criticized but Animal agriculture employs more than 1.6 million many of the critiques do not consider all facets of Americans. what animal production contributes. Kudos to Drs. Annual US exports of animal products has a value White and Hall for a fair analysis of life without ani- of 31.8 billion dollars, equivalent to 22% of the mal agriculture. If you want to read the complete ar- income from all agricultural exports. ticle it is available at http://www.pnas.org/ Ruminants utilize feed and land that other animals content/114/48/E10301. Continued on page 4 Regulatory Services News, Third Quarter 2018 — 3 Directors Digest, continued receiving milk. Be thankful for the quantity and quality of Importance of animal-source foods for meet- food most of us have available and please look for ing global nutritional, educational and economic needs opportunities to help those less fortunate both do- This was the title of another presentation I mestically and abroad. The Kentucky Hunger Ini- tiative through our own Kentucky Department of attended and in addition to pointing out the benefits Agriculture is a source to help the hungry in Ken- of animal source foods, it helped me realize how of- tucky. Heifer International is one organization ten we take for granted the availability and choices trying to make a difference globally. of foods that we have in this country. Stunting, or chronic undernutrition, is responsible for about 45% Dr. Darrell Johnson of deaths in children under the age of five and affects Executive Director approximately 160 million children. Stunting can Potential Fertilizer Regulation Changes begin in utero due to undernutrition of the mother and is also a big problem between six and twenty- As mentioned in an earlier article, new regulations three months of age when children begin consuming have been established by the Kentucky General solid food. Much of this stunting occurs in the de- Assembly which requires administrative regula- veloping areas of Africa and Southeast Asia where tions to be reviewed at least every seven years.