Overcoming Challenges Associated With Carcass Management

Mark A. King and Dennis Wilson, DVM, Bill Seekins, PhD, and Mark Hutchinson
From: 3rd International Symposium on Management of Animal Carcasses, Tissues and Related Byproducts
Connecting Research, Regulations and Response
University of California at Davis
July 21-23, 2009

What do you do if your state has a catastrophic event that results in large numbers of animal carcasses that need to be disposed of…quickly?

That was one of the primary topics addressed at the 3rd International Symposium on
Management of Animal Carcasses, Tissues and Related Byproducts. During July 21st
through July 23rd 2009, experts from around the world joined together at the University
of California, Davis campus to openly discuss the issues and challenges surrounding
carcass and byproduct management. During this 3-day event, numerous issues and
challenges were presented along with potential solutions.

The symposium included a series of “roundtable groups” (sessions) to facilitate open
discussions regarding pertinent issues surrounding carcass management. Key session
topics included: emergency carcass disposal during natural and other disasters, rendering
and landfills as viable carcass management tools, international issues related to carcass
management, and overcoming barriers to develop workable carcass disposal solutions.
Each topic was discussed over two successive days. Day one was devoted to
identification of challenges and important issues, and day two was spent identifying and
exploring potential solutions. The remainder of this paper attempts to discuss the
common challenges and solutions encapsulated during the roundtable sessions, focusing
on one key component of the overall animal emergency response strategy—Carcass

Identified Challenges and Solutions Relating to Carcass Management
The overall challenge faced by state and federal officials when an animal carcass disposal
emergency arises is being able to respond in a coordinated and effective way. This
means that appropriate disposal methods must be available and can be implemented,
resources can be marshaled, sites can be developed, appropriate interests can be involved, biosecurity issues can be resolved and the public informed; all in a very timely fashion.

How can all these things be handled at once without dropping the ball during a crisis situation?  In order for any disposal strategy to be implemented, several “key” factors must be accounted for, including:

Planning for carcass disposal emergency;
Establishing leadership organizational charts;
Development of Communication policies; and
Development of policies to promote research development

Planning- Planning is an essential component to any response. It is important to ensure
that all stakeholders are included in the discussion process. Additionally, stakeholders
need to be included in all subsequent meetings and communications that ensue. The
planning process allows you to identify any special needs of all stakeholders, including:
the generator, responding agencies, contractors, neighbors and any other interested

The list of stakeholders needs to be carefully crafted such that all potential interested
parties are given an opportunity to be part of the process. Never assume that a group or
agency does not want to be part of the process, allow them to make the choice. A few
groups to consider include: Agricultural agencies (e.g., USDA-Veterinary Services,
USDA-Natural Resource Conservation Service, State and Regional Departments of
Agriculture and Cooperative Extension), Environmental Regulatory agencies, Public
Health agencies, Emergency Management (FEMA and regional authorities), Natural
Resources agencies (Marine and Wildlife agencies), private stakeholders (transportation
officials)dairy organization, poultry, etc.), Federal, State and local Police Departments,
National Guard, FBI and Homeland Security.

Planning allows you to identify key resources, including but not limited to: Agencies and
staff to handle mortalities, appropriate individuals and organizations trained in
emergency response, biosecurity, identification and regulatory approval of suitable
disposal sites, contractors to transport mortalities to identified disposal sites, development
of “pre-disaster contracts” so that service interruptions do not occur, and auxiliary
resources (e.g., manpower, utilities, housing, sanitary, etc.).

Finally, planning prepares local response agencies to be more successful, and problems
that are addressed locally can be more efficiently and expeditiously handled than those
that involve state or federal levels. While federal resources are only needed for some of
the issues being addressed early in an event, it’s not clear whether it will escalate to the
point requiring federal involvement so it’s best to work in the federal framework and
maintain federal documentation standards. However, always remember, “All events start
locally, and end locally”. To that end, local community response capabilities should be
included in every emergency response pre-plan and teams should strive to develop a
planning guide that includes check lists to ensure proper deployment of appropriate
resources. Leadership-During a crisis event is clearly not the practical time to develop your
leadership strategy. Yet many states and regions have not developed a clear leadership
for carcass management crises. Because multiple agencies often approach carcass
management in differing ways, it is obvious that there should be a lead agency to head
the response. Because of differences in authorities and goals, a single lead agency may
not be possible. Hence, use of the Incident Command System’s (ICS), “Unified
Command” principle, allows multiple jurisdictions to work together in singular,
coordinated manner.

In most states and regions across North America, animal-rearing industries are included
under the regulatory umbrella of the Department of Agriculture. As such, these agencies
should assume primary leadership responsibility (Incident Commander) during a carcass
mortality crisis. However, many mitigating factors often make this a difficult task. For
example, carcass disposal laws vary from region to region, and may often not be based on
science. Additionally, there is in some cases a lack of required knowledge or a perceived
“Ignorance Factor” amongst the public, governmental agencies, and generators of
mortalities regarding carcass management options and the regulations surrounding the
various options.

Finally, there is often oversight by many agencies, each of which may have a differing
point of view regarding carcass management approaches; resulting in perceived or real
“turf issues”. There clearly needs to be a single-source for information storage and
dissemination that is well advertised and readily available for access by all stakeholders
and interested parties. As stated earlier, this entity is often, by default, the state or
region’s Department of Agriculture. However, as long as information is continually
updated and remains available, any entity can serve this function. Therefore, it is
recommended that regional emergency carcass management teams be developed using
ICS for their leadership format. This system is internationally recognized and facilitates
emergency response activities.

Communication-Just as planning and leadership are essential to the successful initiation
of a carcass management response, communication is the key to successful
implementation and completion of the entire response strategy. Most emergency
response failures occur due to poor or incomplete communication amongst stakeholders
prior to and during the event. Issues include lack of information or the failure to ensure
timely delivery of essential information. For example, failure to appropriately notify the
public during a crisis response runs the risk of perception issues that may damage
ongoing operations or forever tarnish community relations. Effective communications
actually begin during the planning phase where one develops the response network,
whilst also setting the tone for effective communication throughout the response effort.
Regardless, timely information updates need to be provided as a carcass response
unfolds. Failure to provide these updates may result in operational confusion (describe or
give example), perception issues (as noted above), and ultimately, the deterioration of the
operation itself. Identifying all of the interested parties requiring information beforehand
greatly facilitates overall delivery of information. Additionally, different interested parties/stakeholders may require different delivery methods (e.g., ethnic communications,
general population—news media, actual affected community-fliers, posters, town-hall
meetings, etc.). Whatever delivery method you choose, you must remember that your
audience has the right to know what’s going on, however, they do not need to be briefed
on every operational detail.

Risk Communication needs to be briefly mentioned here as well. Unidentified risks pose
one of the single-greatest wildcards respondents will face. If not recognized, addressed
and communicated to all parties early-on in the process, such problems can effectively
halt an ongoing response effort, costing valuable time and money. Risk management
involves risk identification based on the judgment of scientific and technical experts as to
whether a risk is acceptable or not. These experts simultaneously take public opinion into
account and must address the public’s concerns promptly and in an appropriate manner;
all prior to the event response. Risk Management and Risk Communication are
increasingly becoming essential in event planning as developing statutes and regulations
mandate its incorporation. The ICS is helpful in developing clear procedures for risk
assessment, management and communication.

Finally, it is important to identify an Information Officer, to function within Incident
Command, who can be the conduit for information flow from Incident Command
regarding operational updates and communications with the media and public. For larger
events, multiple information officers may be chosen from the various stakeholder
agencies to form a joint-information center. In any case, however, there should only be
one person serving as the information interface with the public and press to ensure
consistency in information delivery.

Policy-Once a disposal plan has been carefully crafted, it is important to memorialize it in
policy. Many frustrations exist with current carcass management policies. A common
complaint is that carcass laws and rules are not based on science nor are they updated as
technology improves. For example, in California, rendering is the primary authorized
method for disposal of carcasses. Use of other options is extremely limited by laws and
regulations. Development, evaluation and implementation of scientifically sound
alternatives have been hindered by the design of the regulatory process. Existing rules
make it difficult to even conduct the necessary research to evaluate other methods. In
fact, changes in law and regulation had to happen before other methods, such as
composting could even be evaluated.

In any event, during an emergency, rules and restrictions may be waived; usually by a
local governmental representative. For example, in California during a summer heat
wave in 2006, approximately 20,000 cows, along with 20,000 calves and greater than one
million chickens and turkeys all succumbed to heat related injuries and had to be
disposed of by a number of methods, including: being shuttled to other rendering
companies, composted, landfilled, and buried. In order to use options other than
rendering, eight counties passed local emergency proclamations so that they could use
alternate disposal methods as the state did not. A system allowing for periodic evaluation and updating of laws and regulations so proven technologies could be accepted for use
could lessen the need to use proclamations to resolve problems.

As noted in the above scenario, the key factor hindering policy development is lack of
information and suitable existing infrastructure to support appropriate and timely carcass
management. Just as their needs to be a lead agency or similar partnering agencies,
policy should also come from the same structuring. For example, in Maine, the
Department of Agriculture takes the lead for all carcass management issues. The Maine
Disposal Plan, however, includes numerous state agencies, municipal, industrial and
private and public entities, as stakeholders. In the event of a crisis, the Department of
Agriculture incident commander initiates the response and the appropriate agency
representatives assume their role. Throughout the whole incident, all decisions flow
through the Department of Agriculture.

Quite often, policy is dictated by funding. As a result, efforts should be made to seek out
appropriate funding as policy is being developed to ensure that all appropriate resources
are adequately provided for. One possible solution involves development of a guidance
document that could be used throughout the country to help unify response to disposal
emergencies. Minor fine-tuning might be necessary to suit a specific regions needs. The
benefit, however, would be that each area would not have to reinvent policy when faced
with a disposal emergency. In the end, carcass management teams should develop
emergency carcass management plans that are adaptable and flexible, while also sharing
management plans on a regional and international scale. The carcass management team
should be utilized to evaluate and make recommendations regarding local and state laws
and regulations regarding carcass disposal.

Research – An important strategy to make sure that emergency responders have as many
carcass disposal tools available to them as possible is to have on-going research directed
toward answering critical questions about a variety of potential carcass disposal options.
One disposal methodology that received much attention at the symposium was
composting. Although it has been proven to be an effective disposal technique in a
variety of scenarios, there are still many questions to be answered, including the possible
fate of prions in carcass compost and evaluation of the safety risks of composting
pharmaceutically euthanized animals. As technology continues to evolve, numerous
research needs will undoubtedly develop and continued financial support for research on
composting and other disposal technologies is a critical piece of being prepared for the
emergency event when it happens. One important avenue would be commnuicating with
funding agencies regarding the urgency for financial support in critical areas of carcass
management specifically related to Zoonotic diseases and environmental protection.

A common theme amongst the roundtable participants is that although there has been
considerable effort to plan for carcass disposal events, there still is much to be done.
Coordination and collaboration of planning efforts regionally and nationally would be of
assistance as long as local entities continue to have a key role in developing their appropriate solutions. Communication was recognized as the key essential element
determining success or failure of an incident response. One needs to be able to identify
and engage all stake-holders to develop solutions. Further, the public needs to be
considered in development of communications; risk communication principles need to be
applied. Through use of the Incident Command system, multiple authorities are able to
effectively lead emergency responses in a singular, coordinated fashion. Methodologies
need to be developed to allow laws and regulations to be quickly modified and to take of
advantage of the capabilities of the ICS system and to react to and implement new
emerging technologies as they become available. Lastly, all of the solutions noted thus
far rely heavily upon adequate funding sources. As such, new funding efforts are needed
to ensure that research and extended planning efforts are provided for as we progress.