• If you are having problems logging in please use the Contact Us in the lower right hand corner of the forum page for assistance.

FDA's BSE Risk List

  • Thread starter Thread starter Anonymous
  • Start date Start date
A

Anonymous

Guest
This is from the Fort Wayned News Sentinal

--------------------------------------------

Posted on Fri, Apr. 07, 2006
Can gelatin transmit `mad cow disease'?
BY RICHARD HARKNESS
Knight Ridder Newspapers
Q: The recent case of mad cow disease in Alabama has me worried. Is it safe to take prescription and OTC products made with gelatin capsules?

A: The Alabama finding is the third confirmed case of the fatal, brain-wasting disease in cows in the United States.

Gelatin is derived from the skin and bones of cattle and pigs.

It's used in making capsule and tablet formulations of prescription and OTC medicines and dietary supplements. It's also widely used in the manufacture of foods and cosmetics.

The consensus seems to be that gelatin carries a very low risk of potential disease transmission to humans, and there have been no reports of such cases.

Cow-derived gelatin comes from the hide and bones, tissues that don't seem to be high-risk.

Even so, it should be said that cross-contamination from higher-risk tissues (if infected) during the manufacturing process might be possible if adequate safeguards are not in place.

More on which animal tissues are higher-risk in a minute.

According to an FDA advisory panel, most of the gelatin produced in the United States is made from the skin of pigs, and is not considered a risk.

However, products typically list "gelatin" or "collagen hydrolysate" in their ingredients list without disclosing whether it's derived from cows or pigs. There's no government regulation that requires such disclosure.

Some products are available as "vegicaps," which are made from plant sources and contain no animal byproducts.

That said, let's look at mad cow disease in more detail.

Mad cow disease (BSE is the scientific name) has become a worldwide worry, with a host of countries reporting cases, leading to the slaughter of thousands of cows to prevent its spread.

Other animals also can harbor the disease. It's called scrapie in sheep and chronic wasting disease in deer and elk.

In fact, the origin of the disease in cows is thought to have been sheep-rendered animal feed given to cattle. Another possible source was an infected antelope that died in a British safari park in the 1970s, its carcass rendered for use as protein-rich cattle feed.

The danger to people is that the cow disease has been linked to the human brain disease called variant Creutzfeldt-Jakob disease, apparently spread by eating beef from affected cows. The infected brain takes on a sponge-like appearance as it becomes riddled with holes.

Prevention is the only treatment. Normal methods used against infectious diseases don't work. The causative agent is thought to be an abnormal protein called a prion that creates toxic plaques in the brain.

The FDA lists the following animal tissues in order of their suspected disease-spreading potential:

Category I (High infectivity): brain, spinal cord

Category II (Medium infectivity): ileum, lymph nodes, proximal colon, spleen, tonsil, dura mater (membrane covering brain and spinal cord), pineal gland, placenta, cerebrospinal fluid, pituitary gland, adrenal gland

Category III (Low infectivity): distal colon, nasal mucosa, sciatic nerve, bone marrow, liver, lung, pancreas, thymus gland.



--------------------------------------------------------------------------------
 
On a really wierd note, here: My aunt used a hair care product that was called placenta plus back about 10 or 15 years ago. Of course, working with cattle I knew what a placenta was and was really stunned by it being in a hair product. Do we actually have a list of products that have placenta in them and are they Human placentas or cattle placentas and are they a risk material we should be using these ways?
 
On an even wierder note, my sister-in-law was in the hospital having a baby. The lady next to her in the room named her newborn daughter "Placenta" because she had heard the word in the delivery room and liked it.

We now have a future "Democrat" in some classroom in Alabama with the name "Placenta" to go along with all the "La Keisha's", Juwanna's", "Aundray's", and "Kioneshian's". :???:
 
Mike said:
On an even wierder note, my sister-in-law was in the hospital having a baby. The lady next to her in the room named her newborn daughter "Placenta" because she had heard the word in the delivery room and liked it.

We now have a future "Democrat" in some classroom in Alabama with the name "Placenta" to go along with all the "La Keisha's", Juwanna's", "Aundray's", and "Kioneshian's". :???:

Shows you what lack of education can do for you.

Ima and Ura Hogg were named on purpose by the Tx Governor, kinda like a boy name Sue. Placenta goes a little too far. What if she had heard prolapsed uterus or something?
 
econ wrote;

On a really wierd note, here: My aunt used a hair care product that was called placenta plus back about 10 or 15 years ago. Of course, working with cattle I knew what a placenta was and was really stunned by it being in a hair product. Do we actually have a list of products that have placenta in them and are they Human placentas or cattle placentas and are they a risk material we should be using these ways?

=============================

strange, we were just speaking of this exact thing last night. we had our 5th grandchild last night :D my daughter-in-law was a beautitician and they were speaking of this exact thing, ya know, during the birthing and stuff, hell i left about that time.........now that is weird. i just leaned over to a friend of my son and said, and yep, it's highly infectious in prion/TSE diseases too, and he just kinda looked at me funny, so i just left it there, i knew he did not know what the hell i was speaking of, and neither would anyone else except a few there.........tss



IA #17-04, REVISION, 5/20/03, IMPORT ALERT #17-04,"DETENTION WITHOUT PHYSICAL
EXAMINATION OF BULK SHIPMENTS OF HIGH-RISK BOVINE TISSUE FROM
BSE-COUNTRIES--BOVINE SPONGIFORM ENCEPHALOPATHY"



TYPE OF ALERT: DETENTION WITHOUT PHYSICAL EXAMINATION

(NOTE: This import Alert contains guidance to FDA field
personnel only. It does not establish any requirements, or
create any rights or obligations on FDA or on regulated
entities.)

PRODUCT: Bulk shipments of high-risk bovine tissues and
tissue-derived ingredients (see Attachment A for a list of
affected products).

PRODUCT CODE: 17Y--99, meat and meat products, N.E.C.
53P--01, Bovine (bovine amniotic fluid), cosmetic raw
materials. (Review of EEPS entry data indicates that this
code may also be used for bovine placenta)
53P--02, Collagen, cosmetic raw materials
54G--01, Bovine, animal byproducts/extracts
54G--99, Animal byproducts/extracts, N.E.C.

PROBLEM: POISONOUS/DELETERIOUS SUBSTANCE - N.E.C. (PSNC)

OASIS CHARGE
CODES: DIET INGRE; INGRED FIL; COSMETIC; BSE FILTH; INSAN BSE.

PAC: 03819C for product codes 17Y--99, 54G--01,
54G--99
29002 for product codes 53P--01, 53P--02

PAF: MIC (microbiological hazards)

COUNTRIES: ALBANIA (AL), ANDORRA (AD), AUSTRIA (AT), BELGIUM (BE),
BOSNIA-HERZEGOVINA (BA), BULGARIA (BG), CANADA (CA), CROATIA
(HR), the CZECH REPUBLIC (CS), DENMARK (DK), the FEDERAL
REPUBLIC OF YUGOSLAVIA (YU), FINLAND (FI), FRANCE (FR),
GERMANY (DE), GREECE (GR), HUNGARY (HU), IRELAND, REPUBLIC
of (IE), ISRAEL (IL), ITALY (IT), JAPAN (JP), LEICHSTENSTEIN
(LI), LUXEMBOURG (LU), the former YUGOSLAV REPUBLIC OF
MACEDONIA (MK), MONACO (MC), NETHERLANDS (NL), NORWAY (NO),
OMAN (OM), POLAND (PL), PORTUGAL (PT), ROMANIA (RO), SAN
MARINO (SM), the SLOVAK REPUBLIC (SLOVAKIA) (SK), SLOVENIA
(SI), SPAIN (ES), SWEDEN (SE), SWITZERLAND (CH) UNITED
KINGDOM (Great Britain & Northern Ireland, and Falkland
Islands) (GB)

NOTE: The United States Department of Agriculture issued an
interim rule on January 6, 1998. The interim rule restricts
the importation of ruminants, meat and meat products from
ruminants, and certain ruminant products and byproducts not
only from countries and other regions in which BSE is known
to exist, but also from countries and other regions which,
because of import requirements less restrictive than those
that would be acceptable for import into the United States
and/or because of inadequate surveillance, present a
significant risk. Countries listed above are BSE affected
countries and/or have less restrictive import requirements
than those that would be acceptable in the U.S. The list of
countries may change and the Import Alert will be revised
accordingly.

MANUFACTURER/
SHIPPER: All, from the designated countries

MANUFACTURER/
SHIPPER I.D.#: N/A

CHARGES: As ingredients in dietary supplements, charge: "The article
is subject to refusal of admission pursuant to Section
801(a)(3) in that it appears to be for use as an ingredient
in a dietary supplement and appears to be or may be
otherwise unfit for food [Adulteration, Section 402(a)(3)]."

AND

"The article is subject to refusal of admission pursuant to
Section 801(a)(3) in that it appears to be for use as an
ingredient in a dietary supplement and may have been
prepared, packed or held under insanitary conditions whereby
it may have become contaminated with filth, or whereby it
may have been rendered injurious to health [Adulteration,
Section 402(a)(4)]."

As ingredients in cosmetics, charge: "The article is subject
to refusal of admission pursuant to Section 801(a)(3) in
that it appears to be for use as an ingredient in a cosmetic
product and appears to have or may have been prepared,
packed, or held under insanitary conditions whereby it may
have become contaminated with filth, or whereby it may have
been rendered injurious to health [Adulteration, Section
601(c)."

If final disposition of the bulk lot is undetermined,
charge: "The article is subject to refusal of admission
pursuant to Section 801(a)(3) in that it appears to be unfit
for food [Adulteration, Section 402(a)(3)]."

AND

"The article is subject to refusal of admission pursuant to
Section 801(a)(3) in that it appears to have been prepared,
packed or held under insanitary conditions whereby it may
have been rendered injurious to health [Adulteration,
402(a)(4)]".

RECOMMENDING
OFFICE: CFSAN, DFPPE, Import Programs Branch (HFS-637)


REASON FOR\
ALERT: BSE has been identified in more than 100,000 cattle in the
United Kingdom and, to a much lesser extent, in several
other countries. This neurological disease is a
transmissible spongiform encephalopathy (TSE) and is
similar to other TSEs such as scrapie in sheep and
Creutzfeldt-Jakob Disease (CJD) in humans. The spongiform
encephalopathies are uniformly fatal and no rapid diagnostic
test for infection in living animals or humans is presently
available. Current scientific information indicates that
the causative agent is extremely resistant to activation by
normal disinfection or sterilization procedures. A range of
research projects into the exact nature of both the BSE
agent and other TSE agents, host range, patterns of
pathogenicity, and development of rapid ante mortem
diagnostic tests is ongoing.

Since 1991, USDA has prohibited the importation into the
U.S. of certain tissues and organs from ruminants from
countries where BSE exists. (refer to 9 CFR 94.18). On
January 6, 1998, USDA issued an interim rule listing other
countries because of import requirements less restrictive
than those that would be acceptable for importation into the
U.S. and/or because of inadequate surveillance, which would
present a significant risk. USDA's regulations are intended
to protect livestock in the United States from contracting
TSEs and address known or strongly suspected modes of
transmission. The USDA regulations permit, under certain
conditions, the importation of some cosmetic ingredients
(i.e., collagen, collagen products, amniotic liquids or
extracts, placental liquids or extracts, serum albumin, and
serocolostrum) derived from ruminants from BSE-countries
(see 9 CFR 95.4).

The USDA regulations do not apply to imports of:

o cosmetic products that are packaged and ready for
sale;

o bovine-derived materials intended for human
consumption as either finished dietary supplement
products or for use as ingredients in dietary
supplements; or

o human food (except meat, i.e., skeletal muscle).

In March 1996, the Spongiform Encephalopathy Advisory
Committee of the UK reported that 10 cases of CJD in the UK
are likely linked to exposure BSE before the UK ban in 1989.

The FDA has recommended that manufacturers who use bovine
by-products voluntarily investigate the geographic
source(s) of any bovine or bovine material used in their
products (generally neural or glandular tissue or tissue
extracts). The Agency also suggested that each manufacturer
develop a plan "to assure, with a high degree of certainty,"
that such materials are not from BSE-countries, as
identified by USDA's APHIS, or from scrapie-infected sheep
flocks, either foreign or domestic.

FDA considers further protective steps to be reasonable and,
in an August 17, 1994, letter (Attachment B), recommended
that manufacturers and importers of dietary supplements,
cosmetic products, and raw materials for these finished
product develop plans for ensuring, with a high degree of
certainty, that specific bovine-derived materials from
BSE-countries are not being used.

Attachment A is an expanded list of those tissues presenting
the highest known risk of infectivity, e.g., high-risk
tissue, which are the subject of this import alert.
Additional tissues may be added to this list as studies
warrant and this import alert will be revised accordingly.

FDA will be gathering information on the development of BSE
plans for all bovine - derived tissues and documenting the
use of high-risk tissue from BSE-countries during domestic
inspections under both the cosmetics and dietary supplements
compliance programs. Due to the difficulty in verifying the
presence of high-risk tissues in finished dietary
supplements or cosmetic products, this import alert is
limited to bulk lots of these tissues from BSE-affected or
at risk countries listed above. However, if during wharf
examinations or label reviews high-risk bovine tissues are
noted in the ingredients statement, districts should follow
the procedure in the Guidance section of this alert to
notify CFSAN.

The United States Department of Agriculture issued an
interim rule on January 6, 1998. The interim rule restricts
the importation of ruminants, meat and meat products from
ruminants, and certain ruminant products and byproducts not
only from countries and other regions in which BSE is known
to exist, but also from countries and other regions which,
because of import requirements less restrictive than those
that would be acceptable for import into the United States
and/or because of inadequate surveillance, present a
significant risk.


GUIDANCE: Districts may detain the shipment without physical
examination, if the high-risk bovine tissue or ingredient,
as listed in Attachment A, originated from one of the
following Countries: Albania, Andorra, Austria, Belgium,
Bosnia-Herzegovina, Bulgaria, Croatia, the Czech Republic,
Denmark, the Federal Republic of Yugoslavia, Finland,
France, Germany, Greece, Hungary, Ireland, Israel, Republic
of, Italy, Japan, Leichtenstein, Luxembourg, the Former
Yugoslav Republic of Macedonia, Monaco, Netherlands, Norway,
Oman, Poland, Portugal, Romania, San Marino, the Slovak
Republic (Slovakia), Slovenia, Spain, Sweden, Switzerland
and United Kingdom. If an entry is detained and the importer
or manufacturer has not provided within sixty (60) days
documentation that establishes that the bovine derived
tissue used in the product came from BSE-free cattle or from
a non BSE affected or at risk country, districts should
attempt to determine the status of the entry and, where
possible, reach a final determination as to the entry. Sixty
(60) days should be ample time for an importer or
manufacturer to provide such documentation.

Districts may provide a copy of the Agency's August 17,
1994, letter (Attachment B) to importer's for their use in
developing plans to assure that future shipments of bovine
tissues are obtained from non-BSE countries.

Districts should be alert to entries of finished products
from BSE affected countries which contain high-risk bovine
tissues listed in the ingredients. When conducting field
examinations and/or label reviews of finished products, such
as dietary supplements or cosmetics that contain high-risk
bovine tissues, contact Rosemary Gary, CFSAN/Import Branch,
at 301-436-2413 with product identity, high-risk bovine
tissue used as ingredient, manufacturer/shipper, country of
origin, and importer of record and for further guidance.

For any issues and/or questions regarding science, science
policy, sample collection, analyses, preparation, analytical
methodology or confirmation tests, districts should contact
the Division of Field Science at 301-443-3320 or 443-3007.

PRIORITIZATION
GUIDANCE: III

FOI: No purging necessary

PREPARED BY: Linda Wisniowski, DIOP, 301-443-6553; Frank Sikorsky,
Rosemary Gary, DFPPE/Import Programs Branch, 301-436-2413

KEYWORDS: Bovine Spongiform Encephalopathy, BSE, High-Risk Tissue,
Animal, Glandular, Bovine

DATE LOADED
INTO FIARS: June 12, 2002



ATTACHMENT A

HIGH-RISK BOVINE TISSUE AND TISSUE-DERIVED INGREDIENTS

Adrenal gland
Bone marrow
Brain
Brain extract
Cerebellum
Cerebrospinal fluid
Cranial nerves
Colon (proximal and distal)
Dura mater
Eye
Hypothalamus
Ileum
Lymph nodes
Nasal mucosa
Olfactory bulb or gland
Pineal gland
Pituitary gland
Placenta
Spinal cord
Spleen
Suprarenal gland
Tonsil Attachment B

August 17, 1994

Food and Drug Administration
Rockville, MD 20857



To Manufacturers and Importers of Dietary Supplements:
To Manufacturers and Importers of Cosmetics:


The Food and Drug Administration (FDA) is recommending that firms that
manufacture or import dietary supplements and cosmetics containing specific
bovine tissues (see Appendix A) ensure that such tissues do not come from
cattle born, raised, or slaughtered in countries where bovine spongiform
encephalopathy (BSE) exists (BSE-countries). Extracts of these tissues and
ingredients derived from these tissues are also of concern. The recommended
actions are precautionary measures to reduce potential risk of human exposure
to, or transmission of, the agent which causes BSE in cattle.

At this time, FDA is not extending the recommendation in this
letter to dairy products or gelatin, because available evidence
does not suggest transmission via these foods. Furthermore, meat
(i.e., skeletal muscle) is not covered by this letter. For
guidance on importation of meat and other products regulated by
the United States Department of Agriculture (USDA), refer to Title 9 of the
Code of Federal Regulations.

The Agency is providing the following information to explain why
it believes that BSE may potentially be a concern with certain
dietary supplements and cosmetic products. BSE has been identified in more
than 100,000 cattle in the United Kingdom and, to a much lesser extent, in
several other countries. This neurological disease is a transmissible
spongiform encephalopathy (TSE) and is similar to other TSEs such as scrapie
in sheep and Creutzfeldt-Jakob Disease (CJD) in humans. The spongiform
encephalopathies are uniformly fatal and no rapid diagnostic test for
infection in living animals or humans is presently available. Current
scientific information indicates that the causative agent is extremely
resistant to inactivation by normal disinfection or sterilization procedures.
A range of research projects into the exact nature of both the BSE agent and
other TSE agents, host range, patterns of pathogenicity, and development of
rapid ante mortem diagnostic tests is ongoing.

Since 1991, USDA has prohibited the importation into the U.S. of
certain tissues and organs from ruminants from countries where BSE exists
(BSE-countries; see 9 CFR 94.18). USDA's regulations are intended to protect
livestock in the United States from
contracting TSEs and address known or strongly suspected modes of
transmission. For the up-to-date listing of BSE-countries please
contact USDA, Animal and Plant Health Inspection Service (APHIS)
at (301) 436-7830.

The USDA regulations permit, under certain conditions, the
importation of some cosmetic ingredients (i.e., collagen, collagen products,
amniotic liquids or extracts, placental liquids or extracts, serum albumin,
and serocolostrum) derived from ruminants from BSE-countries; see 9 CFR 95.4.

The USDA regulations do not apply to imports of:

cosmetic products that are packaged and ready for sale;

bovine-derived materials intended for human consumption
as either finished dietary supplement products or for use as
ingredients in dietary supplements; or

human food (except meat, i.e., skeletal muscle).

While documented transmission of the causative agents of BSE or
scrapie to humans has not been reported to date, the FDA wrote to
manufacturers of dietary supplements in November 1992, alerting
them to the developing concern about TSEs in animals and CJD in
man. That letter recommended that manufacturers voluntarily
investigate the geographic source(s) of any bovine or ovine
material used in their products (generally neural or glandular
tissue or tissue extracts). The Agency also suggested that each
manufacturer develop a plan "to assure, with a high degree of
certainty," that such materials are not from BSE-countries, as
identified by USDA's APHIS, or from scrapie-infected sheep flocks, either
foreign or domestic.

FDA now considers further protective steps to be reasonable and is restating
and expanding its recommendation to manufacturers and importers of dietary
supplements and their ingredients, to develop plans for ensuring, with a high
degree of certainty, that specific bovine-derived materials (see Appendix A)
from BSE-countries are not being used. The Agency is also recommending that
manufacturers and importers of cosmetic products and their ingredients develop
the same type of plans. FDA is not, at this time, recommending restrictions on
the use of ovine-derived materials in the manufacture of dietary supplement
and cosmetic products and ingredients, as the epidemiological evidence now
appears convincing that scrapie is not related to TSEs in humans.

FDA believes it is prudent to expand its recommendation to
cosmetics and cosmetic ingredients because extracts of listed
tissues, e.g. sphingolipids isolated from brain tissue and
extracts of bovine placenta, are used in cosmetics. Additionally,
FDA is unaware of data demonstrating that processing techniques
used in the manufacture of cosmetics will inactivate TSE agents.
Further, little is known about the potential human risk of
transmission from topical application of cosmetics containing TSE
agents to intact, broken or abraded skin.

To assist manufacturers and importers whose products are within
the scope of this recommendation in developing their plans, the
following guidance is provided:

. To ensure that bovine-derived materials (listed in appendix A)
used in the product(s) are from non BSE-countries, identify all
countries where the animals used were born, raised or slaughtered.
The supplier of the bovine-derived materials should provide the
necessary records.

b. Maintain traceable records for each lot of bovine-derived material
and records of products containing the materials.

. Maintain records for those products manufactured at foreign sites
or by foreign manufacturers which contain bovine-derived
materials.

The Agency recommends that manufacturers and importers of dietary
supplements and cosmetic products and ingredients used in the
manufacture of these products develop their plans within the next
two months and notify the Agency, in writing, that their plans
have been developed. The designated contact is Dr. Elisa Elliot,
Science Policy Analyst, Executive Operations Staff, HFS-22, Center for Food
Safety and Applied Nutrition, FDA, 200 C Street, S.W., Washington, DC, 20204
or FAX (202) 205-5025. FDA recommends that the plans be implemented as soon
after development as possible, and be available for review by the Agency
during inspections.

The Agency is continuing to examine all available information
about TSEs and will provide additional guidance as necessary. If
you need more information please contact Dr. Elliot by telephone
at (202) 205-5140.

We appreciate your attention to and cooperation in this matter.

Sincerely,

/s/
Linda A. Suydam
Interim Deputy Commissioner for
Operations


May 9, 1996

TO MANUFACTURERS AND IMPORTERS OF DIETARY SUPPLEMENTS:
TO MANUFACTURERS AND IMPORTERS OF COSMETICS:


As the media have widely reported, the British government announced on March
20, 1996, that new information had been gathered about bovine spongiform
encephalopathy (BSE) in cattle that suggests a possible relationship between
BSE and ten cases of a newly identified form of Creutzfeldt-Jakob disease
(CJD), a similar fatal transmissible spongiform encephalopathy (TSE) in
humans. To serve our mutual interest in protecting public health, the Food
and Drug Administration (FDA) believes it is prudent to reiterate concerns we
have previously expressed on this issue.

BSE is a transmissible neurologic disorder of cattle and is prevalent in
certain parts of the world. This neurological disease is one of a number of
transmissible spongiform encephalopathies (TSE) known and is similar to other
TSEs such as scrapie in sheep and CJD in humans. It is believed that the
spread of BSE in cattle in some countries, particularly Great Britain, was
caused by the feeding of infected cattle and sheep tissues to cattle. While
transmission of the causative agent of BSE to humans has not been definitively
documented to date, inter-species transfer has been demonstrated (e.g., mice
can be infected by exposure to infected bovine tissues). Recent developments
in Great Britain raise serious questions regarding potential hazards of the
consumption of animal tissues containing the causative agent of BSE.

Although there is still no definitive evidence that the consumption of bovine
tissues that contain the transmissible agent for BSE cause CJD in humans, FDA
is concerned that appropriate measures to eliminate the use of bovine tissues
from BSE-countries be instituted industry-wide.

We strongly recommend that firms manufacturing or importing dietary
supplements which contain specific bovine tissues (see appendix A), including
extracts or substances derived from such tissues, take whatever steps are
necessary to assure themselves and the public that such ingredients do not
come from cattle born, raised, or slaughtered in countries where BSE exists.
FDA believes that immediate and concrete steps should be taken by
manufacturers to reduce the potential risk of human exposure to the infectious
agent which causes BSE in cattle.

The list of countries where BSE is known to exist is maintained by the U.S.
Department of Agriculture (USDA) and codified in Title 9, Code of Federal
Regulations, Part 94.18. The following is the current list:

USDA LIST OF COUNTRIES WHERE BSE EXISTS
(Current as of May 1996)

Great Britain (including Northern Ireland and the Falklands)
Switzerland
France
Republic of Ireland
Oman
Portugal

A range of research projects into the exact nature of both the BSE agent and
other TSE agents is ongoing. Available scientific information indicates that
these agents are extremely resistant to inactivation by normal disinfection or
sterilization procedures. A number of dietary supplement products use
bovine-derived tissues or extracts of such tissues as ingredients. These
ingredients include, for example, specific tissues and organs or their
extracts (e.g., liver powder, "orchic" extracts, ovaries, eye tissue, mammary
tissue), glandular powders or extracts (e.g., adrenal gland, thyroid gland),
or specific substances extracted from glands or tissues (e.g., melatonin
extracted from the pineal gland).

At a future date, we will contact you with guidance on how best to provide
assurance that your products do not contain potentially BSE-infected
materials.

We appreciate your attention to and cooperation in this matter. If you need
more information, please contact Dr. Elisa Elliot by telephone at (202)
205-5140.

Sincerely yours,


/s/
Michael A. Friedman, M.D.
Deputy Commissioner for Operations
EnclosureAppendix A

List of Tissues With Suspected Infectivity

Category I (High infectivity)

o brain
o spinal cord

Category II (Medium infectivity)

o ileum
o lymph nodes
o proximal colon
o spleen
o tonsil
o dura mater
o pineal gland
o placenta
o cerebrospinal fluid
o pituitary gland
o adrenal gland

Category III (Low infectivity)

o distal colon
o nasal mucosa
o sciatic nerve
o bone marrow
o liver
o lung
o pancreas
o thymus gland

List taken from Report of a WHO Consultation on Public Health
Issues Related to Animal and Human Spongiform Encephalopathies,
World Health Organization, Office of International Epizootics,
Geneva, Switzerland, November 12-14, 1991.

http://www.fda.gov/ora/fiars/ora_import_ia1704.html



The potential for transmission of BSE through the placenta of
experimentally infected sheep will be evaluated (FY2005).

4. What were the most significant accomplishments this past year?
A. Genetics can be an important component of TSE control programs if
some polymorphisms in the prion gene are associated with reduced disease
incidence. In conjunction with Colorado State University, private
landowners (the Richard Edwards family), the Canadian Food Inspection
Agency, and the Nebraska Department of Game and Parks, the Animal
Disease Research Unit identified susceptible prion genotypes in elk,
white tailed deer and mule deer, characterized the first reported prion
pseudogene in placental mammals, and developed protocols for
differentiating between the functional gene and the pseudogene. We
demonstrated that all reported genotypes of mule deer are susceptible,
identified the single genotype in white tailed deer associated with a
reduced susceptibility to disease and demonstrated that elk of the most
resistant genotype can be affected by disease under some farm
conditions. This accomplishment supports the state and federal
regulatory agencies' control programs, and allows research laboratories
to correctly genotype cervid livestock.

B. Diagnostic testing is performed on a limited number of tissues and
correct identification of the most appropriate target tissue for each
species is critical for accurate surveillance. In collaboration with
Colorado State University, the Canadian Food Inspection Agency, and the
Nebraska Division of Game and Parks, the Animal Disease Research Unit
described the distribution of PrP-Sc in large populations of captive elk
and free ranging white tailed deer. This study demonstrated that the
most accurate testing of elk requires examination of the both the brain
and the retropharyngeal lymph node but testing of white tailed deer can
be accomplished by examination of the retropharyngeal lymph node alone.
This work provides the scientific basis for tissue selection for
diagnostic testing of elk and white tailed deer, complementing the
previous study on mule deer testing.

2) Although the transmission routes of CWD are unknown, placentas shed
by infected deer or elk are potential sources of environmental
contamination. Testing of reproductive tissues for assessing prion
contamination is performed in collaboration with Colorado State
University and the University of Idaho. These studies have shown no
evidence that CWD is transmitted by contact with the placenta of
infected females, as is seen in sheep scrapie.

3) Large and small carnivores feed on dead deer and elk in the CWD
endemic area. If these animals are susceptible to a TSE following oral
exposure to the agent in the tissues of dead deer or elk, they represent
another reservoir of disease. Under a cooperative agreement with the
University of Washington, mink were exposed to tissues from CWD-positive
elk. The incubation period is expected to exceed 18 months and results
are expected in FY2005.

C. Significant activities that support special target populations.

None

D. Progress Report opportunity to submit additional programmatic
information to your Area Office and NPS (optional for all in-house (¿D¿)
projects and the projects listed in Appendix A; mandatory for all other
subordinate projects).

None

5. Describe the major accomplishments over the life of the project,
including their predicted or actual impact.
Diagnostic test development: Postmortem diagnostic test methodology was
developed and transferred to the regulatory agencies for use in the U.S.
The test was modified for use in live deer, although the test requires
general anesthesia and re-trapping of deer found to be positive.
Monoclonal antibodies useful in assays on routinely formalin fixed
tissue from infected sheep, deer, elk, cattle, humans, mink, domestic
cats and a wide variety of captive wildlife potentially exposed to prion
diseases were developed. The technology was transferred to USDA, Animal
Plant Health Inspection Service, which contracts with a network of 20
veterinary diagnostic laboratories to provide surveillance for CWD in
the US. Gold standard testing of cattle for BSE is conducted only at the
National Veterinary Services Laboratory in Ames, IA. The technology and
antibodies are also used by the Canadian Food Inspection Agency in
Nepean, Ontario, and the Foreign Animal Disease Diagnostic Laboratory in
Winnipeg.

CWD genetics: We provided the first report of a processed prion
pseudogene in livestock, allowing research laboratories and wildlife
managers to correctly identify the prion functional gene in wildlife.
Using the appropriate testing technology, we demonstrated that none of
the reported genotypes of cervids are associated with disease resistance
and genetic measures cannot be a component of the federal CWD control
program. However, one genotype in elk is associated with very low
disease prevalence and it is possible that selection for this genotype
in captive elk with very minor potential exposure to CWD would reduce
the disease incidence.

6. What science and/or technologies have been transferred and to whom?
When is the science and/or technology likely to become available to the
end-user (industry, farmer, other scientists)? What are the constraints,
if known, to the adoption and durability of the technology products?
The antiprion monoclonal antibodies have been licensed to private
companies for development of immunohistochemistry and enzyme linked
immunosorbent assays. An IHC test for BSE using one of the monoclonal
antibodies is licensed and marketed internationally. In the US, TSE
testing is conducted by the federal government or by federally approved
laboratories. All the IHC testing performed in the US for livestock TSEs
is performed with the technology and antibody reagents developed by this
project.

7. List your most important publications in the popular press and
presentations to organizations and articles written about your work.
1. BSE diagnostic testing in the US. Invited presentation to the 12th
Annual Food Safety Farm to Table Conference, May 2004, Moscow, ID

2. BSE Testing Technology. Invited presentation to the Beef Industry
Food Safety Council Industry Summit on Bovine Spongiform Encephalopathy,
Fort Worth, TX, April 26, 2004

3. Is BSE in sheep at threat to the US sheep industry? Invited
presentation to the Sheep and Goat Health Committee Seminar, National
Institute for Animal Agriculture, April 4, 2004, Salt Lake City, UT

4. Prion susceptibility genetics in three cervid species, invited
presentation to the Annual meeting of the American College of Veterinary
Pathologists, Banff, Canada, November 15, 2003

Review Publications
O'Rourke, K.I., Spraker, T.R., Hamburg, L.K., Besser, T.E., Brayton,
K.A., Knowles, D.P. 2004. Polymorphisms in the prion precursor
functional gene but not the pseudogene are associated with susceptibilty
to chronic wasting disease in white-tailed deer. Journal of General
Virology. 85:1339-1346.


Brayton, K.A., O'Rourke, K.I., Lyda, A.K., Miller, M.W., Knowles, D.P. A
processed pseudogene contributes to apparent mule deer prion gene
heterogeneity. Gene. 2003. v. 326. p. 167-173.

Hamir, A.N., Miller, J.M., O'Rourke, K.I., Bartz, J.C., Stack, M.J.,
Chaplin, M.J. 2004. Transmission of transmissible mink encephalopathy
(TME) to raccoons (Procyon lotor) by intracerebral inoculation. Journal
of Veterinary Diagnostic Investigation. 16(1):57-63.


http://www.ars.usda.gov/research/projects/projects.htm?ACCN_NO=404978&showpars=true&fy=2004


http://72.14.203.104/search?q=cache:YAENXYpsmDUJ:www.ngpc.state.ne.us/cgi-bin/ultimatebb.cgi%3Fubb%3Dget_topic%3Bf%3D12%3Bt%3D000387+bse+tse+placenta+tss&hl=en&gl=us&ct=clnk&cd=11


http://www.ngpc.state.ne.us/cgi-bin/ultimatebb.cgi?ubb=get_topic;f=12;t=000387




III.3.2.OTHER MEDICINAL PRODUCTS DERIVED FROM TSE-SUSCEPTIBLE SPECIESAnimal sources of material used in medicinal products vary, but mostlyare derived from cattle. There is thus at least a possibility thatunless strict precautions are taken, disease could be transmitted inthis way. It cannot be ruled out that no case ever arose by this means,but it is clear that the majority did not, even at the very beginning ofthe BSE epidemic before publication of information on BSE, and beforeany legislation was in place (Wilesmith et al., 1988). The highest risktissue is bovine brain from a clinically affected animal or one in theimmediate pre-clinical phase. Posterior pituitary extract (now preparedbiosynthetically), was available and used in veterinary practice mainlyin adult female cattle at the time of parturition, to assist treatmentof retained placenta or to assist in milk let down. However, noassociation was found between its use and the occurrence of BSE(Wilesmith et al., 1988).http://europa.eu.int/comm/food/fs/sc/ssc/out236_en.pdf

http://www.agobservatory.org/library.cfm?refID=30407


experimentally challenged orally with the agent of BSE, ileum and bonemarrow have also been shown to contain infectivity (21,24,29<www.cdc.gov/ncidod/EID/vo....htm#21>). In classicalstudies of scrapie in sheep and goats, infectivity was detected in thenervous and lymphoreticular systems, placenta, adrenal gland, nasalmucosa, lung, pancreas, liver, bone marrow, thymus, and alimentarytract, although most of the non-neural, non-lymphoreticular peripheraltissues contained only low titers of agent (30<www.cdc.gov/ncidod/EID/vo...htm#21>,31<www.cdc.gov/ncidod/EID/vo....htm#31>).

http://72.14.203.104/search?q=cache:q8iRf_5jiZMJ:p079.ezboard.com/fwolftracksproductionsfrm2.showMessage%3FtopicID%3D361.topic+bse+tse+placenta+tss&hl=en&gl=us&ct=clnk&cd=16

http://p079.ezboard.com/fwolftracksproductionsfrm2.showMessage?topicID=361.topic


DIAGNOSIS AND REPORTING OF CJD... Singeltary, Sr. et al JAMA 2001 http://jama.ama-assn.org/cgi/content/full/285/6/733?maxtoshow=&HITS=10&hits=10&RESULTFORMAT=&fulltext=dignosing+and+reporting+creutzfeldt+jakob+disease&searchid=1048865596978_1528&stored_search=&FIRSTINDEX=0&journalcode=jama
Sporadic CJD said grossly under-reported in USTue, 13 Feb 2001 JAMA Vol. 285 No. 6, February 14, 2001 Letters
Diagnosis and Reporting of Creutzfeldt-Jakob Disease

http://www.mad-cow.org/00/feb01_news_mid.html#mmm




tss
 
Tue, 13 Feb 2001 JAMA Vol. 285 No. 6, February 14, 2001 Letters

Diagnosis and Reporting of Creutzfeldt-Jakob Disease

http://jama.ama-assn.org/cgi/content/full/285/6/733?maxtoshow=&HITS=10&hits=10&RESULTFORMAT=&fulltext=dignosing+and+reporting+creutzfeldt+jakob+disease&searchid=1048865596978_1528&stored_search=&FIRSTINDEX=0&journalcode=jama




reply to Singeltary et al 2001 ;

Mr Singeltary and Ms Kraemer express an underlying concern that our recently reported mortality surveillance estimate of about 1 CJD case per million population per year in the United States since 1985 may greatly underestimate the true incidence of this disease. Based on evidence from epidemiologic investigations both within and outside the United States, we believe that these national estimates are reasonably accurate. .............end



THE PATHOLOGICAL PROTEIN 2003



--------------------------------------------------------------------------------

May 2003

A bizarre misshapen protein



snip...



CHAPTER 14

Laying Odds

Are prion diseases more prevalent than we thought?
Researchers and government officials badly underestimated the threat
that mad cow disease posed when it first appeared in Britain. They
didn't think bovine spongiform encephalopathy was a zoonosisan
animal disease that can sicken people. The 1996 news that BSE could
infect humans with a new form of Creutzfeldt-Jakob disease stunned
the world. It also got some biomedical researchers wondering whether
sporadic CJD may really be a manifestation of a zoonotic sickness.
Might it be caused by the ingestion of prions, as variant CJD is?

Revisiting Sporadic CJD

It's not hard to get Terry Singeltary going......



snip...


A Case for Undercounting

The difficulty in establishing causal links in sporadic prion diseasesif
there are any in the first placeunderlines the importance of thorough
surveillance. The U.K. has an active program, and when a victim of CJD
is reported, one of Robert Will's colleagues visits and questions the
victim's family. "No one has looked for CJD systematically in the U.S.,"
the NIH's Paul Brown noted. "Ever."6 The U.S., through the Centers
for Disease Control and Prevention, has generally maintained a more
passive system, collecting information from death certificates from the
National Center for Health Statistics. Because CJD is invariably fatal,
mortality data is considered to be an effective means of tabulating
cases. The CDC assessed the accuracy of such data by comparing the
numbers with figures garnered through an active search in 1996: Teams
covering five regions of the U.S. contacted the specialists involved and
reviewed medical records for CJD cases between 1991 and 1995.
Comparing the actively garnered data with the death certificate infor-
mation showed that "we miss about 14 percent," said CDC epidemiolo-
gist Lawrence Schonberger. "That's improving. Doctors are becoming
more knowledgeable," thanks to increased scientific and media atten-
tion given to prion diseases.7

The active surveillance study of 1996, however, only looked at cases
in which physicians attributed the deaths to CJD. Misdiagnosed
patients or patients who never saw a neurologist were not tabulated
thus CJD may be grossly underreported. Many neurological ailments
share symptoms, especially early on. According to various studies,
autopsies have found that CJD is misdiagnosed as other ills, such as
dementia or Alzheimer's disease, 5 to 13 percent of the time. The CDC
finds that around 50,000 Americans die from Alzheimer's each year

228 CHAPTER 14

(about 4 million have the disease, according to the Alzheimer's
Association). Therefore, one could argue that thousands of CJD cases
are being missed. (On the flip side, CJD could be mistakenly diagnosed
as Alzheimer's disease or dementia, but the number of CJD patients is
so small that they wouldn't dramatically skew the statistics for other
neurological ills.)

In part to address the issue of misdiagnosis, CJD families have asked
the CDC to place the disease on the national list of officially notifiable
illnesses, which tends to include more contagious conditions such as
AIDS, tuberculosis, hepatitis, and viral forms of encephalitis.
Currently, only some states impose this requirement. CDC officials
have discounted the utility of such an approach, arguing that it would
duplicate the mortality data, which is more accurate than early diag-
noses of CJD, anyway. Moreover, mandatory reporting of CJD cases
does not necessarily guarantee the end to missed cases.8
One clue suggests that the passive system is undercounting CJD in
the U.S.: racial difference. The number of black CJD victims is about 38
percent that of white victims. Rather than sporadic CJD being a one-
in-a-million lottery, it's more like one-in-2.5-million for African-
Americans. Access to medical care might be one reason. Schonberger
recounted that the CDC had asked other countries with substantial
black populations to submit CJD figures for comparison but found that
the surveillance in those countries was inadequate. "We haven't been
able to find any comparable literature on this issue, so it's still up in the
air," Schonberger said. On the other hand, Alzheimer's disease is more
common among black people than whites, with an estimated higher
prevalence ranging from 14 percent to almost 100 percent, according to
a February 2002 report by the Alzheimer's Association. Are some black
CJD cases being misdiagnosed as Alzheimer's?

Answering critics like Terry Singeltary, who feels that the U.S. under-
counts CJD, Schonberger _conceded_ that the current surveillance system
has errors but stated that most of the errors will be confined to the older
population. ..............



snip...



The Pathological Protein: Mad Cow, Chronic Wasting, and Other Deadly Prion Diseases, Philip Yam

Philip Yam
News Editor
Scientific American
www.sciam.com


http://www.thepathologicalprotein.com/



http://www.thepathologicalprotein.com/_wsn/page3.html



TSS
 
----- Original Message -----
From: "Terry S. Singeltary Sr." <[email protected]>
To: <[email protected]>
Sent: Tuesday, April 11, 2006 9:41 AM
Subject: vCJD: PrP genotype analysis of positive appendix tissue samples from a retrospective prevalence study


##################### Bovine Spongiform Encephalopathy #####################


Subject: vCJD: PrP genotype analysis of positive appendix tissue samples from a retrospective prevalence study
Date: April 11, 2006 at 7:13 am PSTtss

Variant Creutzfeldt-Jakob disease: prion protein genotype analysis of

positive appendix tissue samples from a retrospective prevalence

study

James W Ironside, Matthew T Bishop, Kelly Connolly, Doha Hegazy, Suzanne Lowrie, Margaret Le Grice, Diane L

Ritchie, Linda McCardle, David A Hilton

Abstract

Objective To perform prion protein gene (PRNP) codon 129

analysis in DNA extracted from appendix tissue samples that

had tested positive for disease associated prion protein.

Design Reanalysis of positive cases identified in a retrospective

anonymised unlinked prevalence study of variant

Creutzfeldt-Jakob disease (vCJD) in the United Kingdom.

Study samples 3 positive appendix tissue samples out of

12 674 samples of appendix and tonsil tested for disease

associated prion protein. The patients from whom these

samples were obtained were aged 20-29 years at the time of

surgery, which took place in 1996-9.

Setting Pathology departments in two tertiary centres in

England and Scotland.

Results Adequate DNA was available for analysis in two of the

three specimens, both of which were homozygous for valine at

codon 129 in the PRNP.

Conclusions This is the first indication that the valine

homozygous subgroup at codon 129 in the PRNP is susceptible

to vCJD infection. All tested clinical cases of vCJD have so far

occurred in the methionine homozygous subgroup, and a

single case of probable iatrogenic vCJD infection has been

identified in one patient who was a methionine/valine

heterozygote at this genetic locus. People infected with vCJD

with a valine homozygous codon 129 PRNP genotype may have

a prolonged incubation period, during which horizontal spread

of the infection could occur either from blood donations or

from contaminated surgical instruments used on these

individuals during the asymptomatic phase of the illness.


snip...


Discussion

These results give the first indication that PRNP codon 129

valine homozygotes may be susceptible to vCJD infection.

Though the immunohistochemical technique used in our earlier

study seems to be specific for disease associated prion protein,6 it

is unlikely to be 100% sensitive, suggesting that the true

prevalence of vCJD infection in the UK population may be even

higher than earlier estimated (3/12 674).2 Genetic studies of

kuru, another orally transmitted human prion disease, found

that PRNP codon 129 MV and VV genotypes were associated

with longer incubation periods than the MM genotype.7 As the

ethical approval for our study placed restraints on the identification

of individual cases, we are not able to state with certainty the

age of the patients in the positive cases at the time of surgery.We

can, however, state that they were aged 20-29 years at the time of

surgery, which took place in 1996-9. No clinical cases of vCJD at

any age have yet been identified in PRNP codon 129 valine

homozygotes, indicating the need for continued surveillance of

all cases of vCJD in the UK.

Though it is inadvisable to overinterpret the data from only

three positive cases in this study, it is perhaps surprising (given

the relative prevalences of PRNP codon 129 genotypes in the

general population) that both the positive cases analysed here

were valine homozygotes. Though this may represent a chance

finding, we should consider the possibility of differences in the

peripheral pathogenesis of vCJD that depend on the PRNP

codon 129 genotype. The patient who developed asymptomatic

vCJD infection after red blood cell transfusion was a codon 129

heterozygote in whom both tonsil and appendix tissues were

negative on staining for disease associated prion protein with

methods identical to those used in this study, though the spleen

and lymph nodes gave positive results.3 PRNP polymorphisms in

sheep infected with scrapie also have a major influence on the

incubation period and timing and distribution of disease associated

prion protein in lymphoid tissues during the incubation

period.8

A prolonged incubation period after infection with vCJD is

likely to result in an asymptomatic carrier state (which cannot yet

be identified), which represents a potential risk for horizontal

transmission of vCJD infection by blood transfusion, blood

products, or contaminated surgical instruments. These uncertainties

further underline the need for continued surveillance of

vCJD in the UK (including surveillance for subclinical or asymptomatic

infection9), a requirement to continue to reduce the possibility

of secondary iatrogenic transmission, and the inclusion of

carrier states and susceptibility to vCJD infection in all PRNP

codon 129 genotypes in future disease modelling.

Contributors: JWI and DAH were responsible for the prevalence study and

the analysis of the results, including the selection of the cases for analysis,

and drafted and modified the manuscript.MTB established the methods for

DNA extraction and analysis, designed and executed the validation study,

and drafted and modified the manuscript. KC and DH performed the DNA

extraction on the test materials and in the validation study, and modified the

manuscript. MLeG, SL, DLR, and LMcC identified cases for the validation

study and prepared the paraffin sections for DNA analysis and modified the

manuscript. JWI is guarantor.

Funding: The prevalence study was funded by the Department of Health

(1216963 DAH; 1216982 JWI).

Competing interest: None declared.

Ethical approval: The prevalence study received approval from the South

and West multi-centre research ethics committee (MREC reference

99/6/32) and for each of the centres included, appropriate local research

ethics committee approval.


http://bmj.bmjjournals.com/cgi/rapidpdf/bmj.38804.511644.55v1




TSS

#################### https://lists.aegee.org/bse-l.html ####################
 

Latest posts

Back
Top