To start with, I'll say that I'm restricting this to the Canadian market and the CFIA. I'm sure there are logistic struggles within the US, and I simply won't know enough of them to make sound comments.
Secondly, while I've been thinking about this topic for a week or so, I've not put anything down in writing before. There are certain to be holes, and this should be considered a rough draft. Please, point out errors or shortcomings.
Edit: This is coming out a little disjointed since its 11:05 pm and I'm feeling a little worn, but with any luck you can make head or tails of it.
Who Does The Testing?
I think this should be between the company who wishes to ship product and the customer. My original thought was that even the type of BSE test to be used would be negotiated by both parties, but with the wide array of testing apparatus required, it would be difficult for the CFIA to maintain a staff who would be qualified in the use of all BSE tests. So, at least initially, the official BSE test recognized by the CFIA would be used.
For the customer who wishes the CFIA to do the testing, I believe the CFIA should operate much the same as an independent private lab does for other tests. Guarantee a certain level of response (X hundreds or thousands of tests per day), with full billing detailing of each expense. I believe the company requesting the BSE tests should pay the CFIA, as long as the CFIA maintains sound and reasonable judgement on the billings. The company can then charge the customer a premium, all or a portion of the cost of the test, depending on what they've negotiated with the customer.
Now for the company who feels they can make their own lab pay, and the customer who would prefer the company do the testing. This opens a whole can of worms, vis-a-vis reliability, accountability and accuracy. I believe that the company should be forced to be "BSE testing accredited". For those of you who are familiar with custom spray applicators, all operators of the equipment are put through a mini-school, then a written test which they must pass before they are licenced to operate the sprayer. I haven't given this much thought, but I think the people who are going to work in the lab should first be placed in positions with CFIA testing staff and learn how the tests work. Following a demonstration of knowledge, this would qualify the people to work in the companies' lab. For a given amount of time, at least until the CFIA feel the lab staff is capable of proceeding on their own, a staff of CFIA "experts" will oversee the operations within the lab. While the CFIA is on site, the company will re-imburse the CFIA for the wages of the staffers. Once the company's lab is declared fit for duty, the CFIA will then only conduct random spot checks to ensure that standards are being met. Any violation of those standards means the company loses their BSE testing ability AND (this one may be too strong) their ability to export beef at all.
I actually see an opportunity here for independent labs to open that specialize in BSE testing. Qualification same as above and if a random spot check finds that standards are being violated, the lab loses their certification. Hard line stance to ensure the integrity of the system remains in effect.
Should a company lab, or an independent lab find a positive, confirmation would be required by a CFIA lab test, since they are the governing body.
What Tests To Use?
Initially, only the currently approved by the CFIA tests will be used. However, there are beginning to be more and more rapid, batch and live animal BSE tests available from numerous sources. The CFIA must make a conscious effort to maintain knowledge of the tests, and MUST accept requests from third parties to "test a new test". I don't envision allowing a BSE test creator to petition the CFIA, but rather the test creator must "sell" his product to a company that wishes (or is already) exporting BSE tested beef. This should provide a buffer against the CFIA being hammered by dozens of fly by night companies with no truly new offerings while still allowing access to those companies with something to offer the market.
OK, I'm whupped tonight. More tomorrow.
Rod