Two MAD COW farmers jailed for BSE fraud JAILED FOR 3 YEARS

[bse-tester]

Merry Christmas to one and all and remember kids, let us all learn to play nice together and remember that we all want to see the same results at the end of the day - safe products, increased markets along with good prices for all of the products.

Arguing makes for sorry bedfellows some old king once said on his way to the chopping block!! So the moral of that is something like - "Let us all not lose our heads on this issue!"

Randy, Scotch however, is mother's milk to some - but as for me, I like it once in a while but not all the time. I actually prefer Ice Tea Zero!!! BSE Free of course.

Have a great holiday season.
Ron.

 

[Sandhusker]

well, i guess that's all you have, too. the rest of the world seems to have its opinion.

I know how many we've tested and how many we've found.

 

[Murgen]

Testing steers for a sperm count is useless!

 

[Bill]

Testing steers for a sperm count is useless!

:lol: :lol: :lol:

R-Klan called for increased testing on June 7th of what year Sandhusker?

Where were their statememnts or cries of outrage when USDA said they were REDUCING testing? Nonexistant. They don't want an increase in testing in the US any more than the packers do because they will find more!

One passing comment is nothing more than like winking at a pretty girl. If you want something to actually happen you have to follow through to be taken seriously.

 

[Anonymous]

One little comment is nothing more than like winking at a pretty girl. If you want something to actually happen you have to follow through to be taken seriously.

Bill- At least the R-CALF guys are winking at the girls-- instead of like the Canucks that are not only crawling in bed with their Packer boyfriends, but are even buying the Vaseline :wink: :shock:

 

[don]

so june 7 of what year??????

 

[Sandhusker]

Testing steers for a sperm count is useless!

:lol: :lol: :lol:

R-Klan called for increased testing on June 7th of what year Sandhusker?

Where were their statememnts or cries of outrage when USDA said they were REDUCING testing? Nonexistant. They don't want an increase in testing in the US any more than the packers do because they will find more!

One passing comment is nothing more than like winking at a pretty girl. If you want something to actually happen you have to follow through to be taken seriously.

If some of you Canucks ever got a hankering to actually find out what R-CALF said and/or advocates, all you have to do is check out the website.

 

[don]

predictable response. kind of like sh. lol.

 

[Sandhusker]

predictable response. kind of like sh. lol.

Geeeze, Don, I just told you where to get the info. If you had checked on the site just a few minutes last night, you wouldn't of made the misinformed comment that you did.

There's a whole lot of misinformed comments made on R-CALF not just by Canadians, but by some clowns down here as well. If anybody wants to really know what R-CALF said on a topic, it's easy to find out. The problem is, folks don't really want to know - they just want to bad-mouth and then they expect members to do the research they should of done all along.

 

[don]

if you don't want to answer just say you don't want to answer. we'll understand. :wink:

 

[Sandhusker]

if you don't want to answer just say you don't want to answer. we'll understand. :wink:

Answer what? If you have a question, why not get on the site and take a look? It would do you some good - I can tell you don't know much about R-CALF.

 

[Sandhusker]

so june 7 of what year??????

I don't know what year - it makes no difference. Put in any date that you like. That was R-CALF's stand then and it hasn't changed.

 

[flounder]

Assessment of the Equivalence of the Canadian Beef Inspection System

Last year, my testimony discussed OIG's findings from our audit of APHIS' oversight of the importation of beef products from Canada. Our work on that audit led us to conduct an evaluation of FSIS' assessment of the equivalence of the Canadian food safety inspection system, which we issued in December 2005.

The then FSIS Administrator and the Under Secretary for Food Safety had identified concerns with the Canadian inspection system in late 2003. Our audit determined that FSIS did not fully address the issues raised by USDA officials in a timely manner. For example, in July 2003 FSIS found that Canadian inspection officials were not enforcing certain pathogen reduction and HACCP system regulations. These same types of concerns were identified again in June 2005.

At the time of our audit, FSIS did not have protocols for evaluating deficiencies in a foreign country's inspection system which could be used to question the system's equivalence to U.S. standards. In addition, FSIS had not instituted compensating controls (such as increased port-of-entry testing) to strengthen public health protections while

7

deficiencies were present. During the period of January 2003–May 2005, 4.4 billion pounds of Canadian processed product entered the U.S., even though FSIS officials questioned the equivalence of the Canadian inspection system.

FSIS agreed with OIG's five recommendations, which included implementing protocols to determine which deficiencies would lead FSIS to question whether a foreign country's inspection system is equivalent to the U.S. system. In response to the report, FSIS committed to develop these protocols by March 2006 and to implement them immediately thereafter.

Oversight of FSIS Recalls

For the past several years we have testified about our continuing work regarding adulterated beef product recalls. In July 2004, a Pennsylvania firm initiated a recall of approximately 170,000 pounds of ground beef patties because of mislabeling. Approximately one-fourth of this product was made, in part, from beef trim from Canada which was not eligible for import to the U.S., following the detection of a Canadian cow with BSE. In May 2005, we reported on the adequacy of FSIS' effectiveness checks and the agency's oversight of the recall. Overall, we concluded that FSIS had strengthened its procedures regarding the agency's oversight of recalls. However, we noted that FSIS personnel did not determine the amount of product purchased by firms on 26 of the 58 completed effectiveness checks. This resulted in reduced assurance that mislabeled product was completely retrieved from distribution. Agency officials concurred with the firms' assertions that the product had been removed from the marketplace. In response to

8

our recommendations, FSIS agreed to provide more specific direction to its personnel on identifying and evaluating the amount of product purchased.

The Subcommittee has been interested in OIG's investigation of a Pennsylvania company's recall of meat products. This remains an ongoing civil fraud investigation and we will be pleased to provide information on its resolution to the Subcommittee upon its conclusion.



http://appropriations.house.gov/_files/FongTestimony.pdf



2005



Coordination between USDA Agencies Necessary for Effective Protection of Food Safety, Public Health, and Agriculture Trade. In our August 2004 audit review of the Bovine Spongiform Encephalopathy (BSE) Surveillance Program – Phase I, we reviewed the BSE plan in place and the plans for the expanded program. We made 19 recommendations to address limitations in the surveillance plan, make full disclosure of assumptions, and better define the animal population to be tested. Agreement on the recommendations was achieved at report issuance. Although many steps are being taken to improve the BSE surveillance program, the Animal and Plant Health Inspection Service (APHIS) and the Food Safety and Inspection Service (FSIS) need to closely coordinate their activities to protect the safety of our food supply and agriculture markets.

4

In February 2005, we reported that from August 2003 to April 2004, APHIS officials allowed a gradual expansion in the types of Canadian beef products approved for import into the United States. Additionally, APHIS allowed an expansion in the type of Canadian facilities that would be allowed to produce items for export to the United States. However, FSIS and APHIS did not always communicate effectively about the eligibility status of products imported, which resulted in ineligible product being brought into the United States. APHIS and FSIS agreed with the report's recommendations.

In September 2004, we initiated an audit to evaluate whether USDA enforcement of the ban on specified risk materials in meat products, the administration of its testing program, and the controls to prevent central nervous system (CNS) tissue in advanced meat recovery product have been effectively implemented to reduce the public health risk, provide consumer protection, and monitor the success of adopted prevention and control measures. We also started an audit to evaluate whether the newly expanded BSE Surveillance Program is accomplishing its intended objectives and has been effectively implemented and administered.

DEPARTMENTAL/AGENCY ACCOMPLISHMENTS/PLANS: In carrying out their mandate, RMA and FSA have established a working group to develop a comprehensive information management system (CIMS), which will combine the agencies' separate program data (e.g., acreage, type of crop, producer, past claims, etc.). In addition to developing an integrated comprehensive information management system, this effort has included re-defining data common to, and needed by, both agencies and data unique to each agency and developing a common format for such data. In the long term, NRCS will be invited to participate in CIMS. The success of this effort will critically depend on a unified, integrated approach to information collection and systems development.

APHIS agreed that additional discussion and clarification of the BSE surveillance program objectives and assumptions would contribute to public understanding of its efforts. Both FSIS and APHIS have issued instructions to field personnel that clearly state the policy to sample all cattle condemned on ante mortem inspection (except veal calves condemned for non-CNS reasons). Personnel in both APHIS and FSIS have been trained on the sample collection process. The APHIS and FSIS Administrators signed a Memorandum of Understanding on July 6, 2005, relative to cooperation in surveillance programs.

For research misconduct, the Department agreed, as recommended in our report, that a centralized body for implementing a research misconduct policy will be established within the Department. The office of the Under Secretary for Research, Education, and Economics will be accountable for coordinating research misconduct policies and procedures.

ACTIONS NEEDED TO ADDRESS THE CHALLENGE: Top Departmental leadership is critical to effecting the cultural changes necessary to the success of a unified approach to USDA program administration. The Department must foster improved interagency communication and data sharing in order to increase efficiency and to preclude the agencies from inadvertently working at odds with one another.

5



http://www.usda.gov/oig/webdocs/MgmtChallFinal050902.pdf



GAO-06-157R FDA Feed Testing Program

October 11, 2005

The Honorable Saxby Chambliss

Chairman

The Honorable Tom Harkin

Ranking Democratic Member

Committee on Agriculture, Nutrition, and Forestry

United States Senate

The Honorable Thad Cochran

United States Senate

The Honorable Richard J. Durbin

United States Senate

Subject: Mad Cow Disease: An Evaluation of a Small Feed Testing Program FDA

Implemented in 2003 With Recommendations for Making the Program a Better

Oversight Tool

In 1997, the Food and Drug Administration (FDA) banned the use of most proteins

derived from mammals (referred to as prohibited material) in feed intended for cattle

and other ruminants.1 The feed-ban rule is one of the primary actions taken by the

federal government to protect U.S. cattle from bovine spongiform encephalopathy

(BSE),2 commonly known as mad cow disease, which is believed to be spread through

feed that contains malformed protein found in certain tissue—particularly brain and

central nervous system tissue—of BSE-infected animals.3 Earlier this year, mad cow

disease was found for the first time in a 12-year old animal born and raised in the United

States.

In January 2002, we reported on the effectiveness of federal actions to prevent the

introduction and spread of BSE in the United States and identified a number of areas

where improvements were needed to strengthen FDA's oversight of firms in the feed

1Ruminants are animals with four-chambered stomachs, including, but not limited to, cattle, buffalo, sheep,

goats, deer, elk, and antelope. For the purpose of this report, "cattle" refers to cattle and all other

ruminant animals and "cattle feed" refers to feed for cattle and other ruminant animals.

2

21 C.F.R. §589.2000.

3

Adding protein (derived from animals or plants) to feed is a common nutritional practice used to speed

animal growth.

United States Government Accountability Office

Washington, DC 20548

2 GAO-06-157R FDA Feed Testing Program

industry.4 In February 2005, we issued a follow-up report that examined the

effectiveness of FDA's actions since the 2002 report to ensure industry compliance with

the feed-ban rule and protect U.S. cattle from BSE.5 Our report concluded that while

FDA has taken a number of positive steps, its processes still have room for improvement.

Our February 2005 report also noted that FDA had begun a small, discrete feed testing

program in August 2003. We reported that we would provide information on this new

feed testing program, which FDA described as a unique effort, once FDA provided us

with data on the feed tests. FDA later gave us the information we required to examine

those feed testing activities. Accordingly, this report assesses FDA's small feed testing

program and examines the extent to which this feed testing program helps FDA better

assure industry compliance with the feed-ban rule. This report is the final component of

our follow-up work on FDA's BSE prevention efforts.

FDA established the feed testing program in an assignment memorandum issued in

August 2003, entitled Assignment Memorandum—Sample Assignment for Domestic

Products, which contained instructions for implementing the program. The purpose of

the feed testing program was to collect and analyze cattle and other types of animal feed

and feed ingredients to determine whether feed that could be fed to cattle might contain

material prohibited by FDA's feed-ban rule. Under the program, FDA collected 641 feed

samples through the end of fiscal year 2004 and planned to collect 900 feed samples

during fiscal year 2005.

The 2003 guidance gave FDA's district offices responsibility for collecting samples and

submitting them to an FDA laboratory where analysts test the samples using a procedure

called feed microscopy—a visual (microscopic) examination for potentially prohibited

material, such as particles of bone, hair, or muscle fiber from certain animals. If an

analyst detects what appears to be prohibited material, the findings are confirmed by a

second analyst. According to FDA officials, some samples were tested using a more

specialized method called polymerase chain reaction (PCR), a test that FDA has been

piloting, which can differentiate ruminant DNA from other animal DNA.6

The guidance noted that because FDA had designated a number of cattle-derived

exemptions to the feed-ban rule, including blood, milk protein, and plate waste, the

laboratory tests could not definitively determine violations but, rather, could identify

potential violations. The guidance directs the districts to conduct follow-up reviews on

each potential violation to determine whether the facility represented by the sample

actually violates the feed ban. On the basis of the follow-up reviews, the districts assign

final compliance determinations—that the facility where the sample was collected has

complied with or has violated the feed-ban rule.

In June 2005, FDA issued a directive that all feed sample analysis and follow-up actions

4GAO, Mad Cow Disease: Improvements in the Animal Feed Ban and Other Regulatory Areas Would

Strengthen U.S. Prevention Efforts, GAO-02-183 (Washington, D.C.: Jan. 25, 2002).

5

GAO, Mad Cow Disease: FDA's Management of the Feed Ban Has Improved, but Oversight Weaknesses

Continue to Limit Program Effectiveness, GAO-05-101, (Washington, D.C.: Feb. 25, 2005).

6The PCR test works by aiding in the differentiation of mitochondrial DNA between animal species.

3 GAO-06-157R FDA Feed Testing Program

be recorded in FDA's central data system—the Field Accomplishments and Compliance

Tracking System (FACTS)—and that districts complete follow-up reviews of potential

violations within 30 working days. In July 2005, FDA issued a revised assignment

memorandum that, among other things, enhances the testing protocol by adopting the

PCR test for sample retesting and directs districts to provide sufficient narrative

explanation in FACTS to explain their final determination on samples that laboratories

identify as potential violations.

For the purpose of this report, we use the term "feed testing program" to distinguish the

samples FDA collected for the feed-testing assignments from samples FDA and states

collected in conjunction with routine BSE inspections. We included only the samples

that FDA collected for the assignments. To examine the extent to which FDA's feed

testing program provides better assurance of industry compliance with the feed-ban rule,

we reviewed FDA's data on 1,206 samples collected through June 2005. We identified

989 feed samples collected by FDA's district offices and analyzed by FDA laboratories

between August 2003 and June 2005, under the feed testing assignment/program

implemented under the August 2003 guidance document. We compared sample

collection, analysis, and follow-up with the program instructions in the August 2003

assignment memorandum. In order to assess FDA's timeliness in analyzing feed samples

and to determine results of these analyses, we analyzed data on feed sample collection

and laboratory analysis maintained in FACTS on the 989 feed samples. In order to assess

the types of follow-up activities carried out by the districts and the basis for their final

determinations on potential violations, we obtained and analyzed additional electronic

files from FDA districts and discussed those activities and determinations with officials

in the 19 FDA district offices. We also obtained detailed district-specific data and

information on sample collection, follow-up, and enforcement activities in interviews

with the officials in the 19 FDA district offices and discussed this information with FDA

headquarters officials. To assess the reliability of the FACTS data, we analyzed the feed

sample records in this database as of June 7, 2005. We analyzed the data to identify

problems with completeness, accuracy, or timeliness of data entry, and reviewed system

documentation on controls. We determined that the data were sufficiently reliable for

the purposes of this report. The testing program data assessed for this report, including

documentation in FACTS, spreadsheets maintained by individual district offices,

documents describing district follow-up actions for individual samples, and all written

guidance documents, were provided in response to our specific requests for all such

documentation and data related to the feed testing program. Finally, we examined the

feed testing program guidance that FDA provided in the June 2005 field management

directive and the July 2005 assignment memorandum and compared it with the

instructions and guidance FDA provided in the August 2003 memorandum. We

performed our work from February through August 2005 in accordance with generally

accepted government auditing standards. Our work included an assessment of FDA's

feed testing program data reliability and internal controls.

Results in Brief

The feed testing program is a small part of FDA's BSE oversight effort and is one of

several methods FDA uses to monitor for compliance with the feed-ban rule. However,

4 GAO-06-157R FDA Feed Testing Program

several weaknesses in the design and implementation of the feed testing program need to

be addressed to improve its effectiveness. Specifically, under the program guidance,

• FDA did not require districts to document their follow-up reviews or the basis for

their final determinations on samples that the laboratories identified as

potentially containing banned protein products. Although the districts may have

conducted rigorous follow-up and exercised sound judgment, the basis for their

decisions cannot be reviewed and confirmed.

• For nearly half the 989 samples, FDA took longer than 30 days from the date the

sample was collected until the date the laboratory completed its analysis—

including 21 samples that took longer than 100 days. This extended period does

not include the time FDA's districts would have spent following up on samples

that indicated potential violations. FDA and industry agree that cattle feed is

consumed very quickly. By the time FDA conducted its follow up to determine

whether a violation had occurred, the feed may have been consumed.

• FDA managers in headquarters did not adequately oversee the feed testing

program. Specifically, FDA managers did not receive periodic reports or have

other oversight controls in place to assure that the program was implemented

correctly. Moreover, FDA did not identify intended program goals and, as a

result, does not know whether or to what extent the feed testing program is

contributing to the agency's BSE oversight efforts.

FDA's June 2005 directive and July 2005 revised instructions—issued nearly 2 years into

the program—includes (1) a requirement that follow-up actions and compliance

determinations be fully documented in FDA's centralized FACTS compliance tracking

system with sufficient explanation to allow the reader to understand the basis for the

decision and (2) a time limit for districts to complete follow-up reviews.

To ensure that the feed testing program contributes to FDA's BSE oversight efforts, we

are recommending that FDA (1) fully implement the June 2005 field management

directive and July 2005 assignment memorandum, (2) assure that districts and

laboratories adhere to time limits on collecting samples, completing sample analysis, and

carrying out follow-up activities to minimize cattle's exposure to potentially

contaminated feed, and (3) require sufficient oversight by headquarters managers to

assure the program is achieving its intended goals.

In commenting on a draft of this report, FDA expressed concern that GAO was issuing a

report that focused on one small aspect of FDA's BSE oversight efforts. We agree that it

is a small component of FDA's overall efforts, but it vies for FDA's limited BSE oversight

resources. Furthermore, as we pointed out in our more comprehensive February 2005

report, we looked at this small program separately because FDA did not provide program

data in time for its inclusion in the broader report. FDA also disagreed with two of our

recommendations in a draft of this report: that it set a time period for laboratories to

complete sample analyses and that headquarters managers exercise sufficient oversight

to assure the program operates as intended. FDA indicated that it had some target

timeframes for laboratories. Because we could not pinpoint where delays were

occurring, we revised our recommendation to address the need to minimize overall

time—from sample collection through analysis and follow-up activities—in order to

minimize cattle's exposure to potentially dangerous feed. With regard to our

recommendation for better management oversight, FDA disagreed with our assertion

that the program was not sufficiently monitored and noted the activities its managers

have undertaken. We modified that recommendation to clarify what we believe is

needed in terms of management oversight.


SNIP...FULL TEXT 29 PAGES ;


http://www.gao.gov/new.items/d06157r.pdf







Audit Report

Animal and Plant Health Inspection Service

Bovine Spongiform Encephalopathy (BSE) Surveillance Program – Phase II

and

Food Safety and Inspection Service

Controls Over BSE Sampling, Specified Risk Materials, and Advanced Meat Recovery Products - Phase III

Report No. 50601-10-KC January 2006

Finding 2 Inherent Challenges in Identifying and Testing High-Risk Cattle Still Remain

Our prior report identified a number of inherent problems in identifying and testing high-risk cattle. We reported that the challenges in identifying the universe of high-risk cattle, as well as the need to design procedures to obtain an appropriate representation of samples, was critical to the success of the BSE surveillance program. The surveillance program was designed to target nonambulatory cattle, cattle showing signs of CNS disease (including cattle testing negative for rabies), cattle showing signs not inconsistent with BSE, and dead cattle. Although APHIS designed procedures to ensure FSIS condemned cattle were sampled and made a concerted effort for outreach to obtain targeted samples, industry practices not considered in the design of the surveillance program reduced assurance that targeted animals were tested for BSE.

In our prior report, we recommended that APHIS work with public health and State diagnostic laboratories to develop and test rabies-negative samples for BSE. This target group is important for determining the prevalence of BSE in the United States because rabies cases exhibit clinical signs not inconsistent with BSE; a negative rabies test means the cause of the clinical signs has not been diagnosed.

APHIS agreed with our recommendation and initiated an outreach program with the American Association of Veterinary Laboratory Diagnosticians, as well as State laboratories. APHIS also agreed to do ongoing monitoring to ensure samples were obtained from this target population.

Although APHIS increased the samples tested from this target group as compared to prior years, we found that conflicting APHIS instructions on the ages of cattle to test resulted in inconsistencies in what samples were submitted for BSE testing. Therefore, some laboratories did not refer their rabies negative samples to APHIS in order to maximize the number tested for this critical target population. In addition, APHIS did not monitor the number of submissions of rabies negative samples for BSE testing from specific laboratories.


According to the Procedure Manual for BSE Surveillance, dated October 2004, the target population includes:


Central nervous system (CNS) signs and/or rabies negative - sample animals of any age (emphasis added):


a. Diagnostic laboratories –samples submitted due to evidence of CNS clinical signs.



snip......



APHIS notes that for the current surveillance program, it had established regional goals and APHIS was not trying to meet particular sampling levels in particular States. However, we believe that it would be advantageous for APHIS to monitor collection data and increase outreach when large geographical areas such as the above States do not provide samples in proportion to the numbers and types of cattle in the population.

We also disagree with APHIS/FSIS' contention that because they have tested over 375,000 of their 446,000 estimate of high risk cattle, few in the high-risk population are being missed, including those that might be pre-screened before entering a slaughter facility's property. In our prior audit, we reported that APHIS underestimated the high-risk population; we found that this estimate should have been closer to 1 million animals (see Finding 1). We recognize that BSE samples are provided on a voluntary basis; however, APHIS should consider industry practice in any further maintenance surveillance effort. Animals unsuitable for slaughter exhibiting symptoms not inconsistent with BSE should be sampled and their clinical signs recorded. However, this cited industry practice results in rejected animals not being made available to either APHIS or FSIS veterinarians for their observation and identification of clinical signs exhibited ante mortem. Although these animals may be sampled later at other collection sites, the animals are provided post mortem without information as to relevant clinical signs exhibited ante mortem. For these reasons, we believe APHIS needs to

USDA/OIG-A/50601-10-KC Page 27

observe these animals ante mortem when possible to assure the animals from the target population are ultimately sampled and the clinical signs evaluated.



snip...



http://www.usda.gov/oig/webdocs/50601-10-KC.pdf



IN COMMERCE 2006



Subject: MAD COW FDA FEED WARNING LETTER NO. 2007-NOL-01 October 26, 2006 H.J. Baker & Bro., Inc.
Date: November 7, 2006 at 9:08 am PST
Food and Drug Administration

New Orleans District

404 BNA Drive, Building 200, Suite 500

Nashville, TN 37217

Telephone: 615-366-7801

Facsimile: 615-366-7802

October 26, 2006

WARNING LETTER NO. 2007-NOL-01

FEDERAL EXPRESS

OVERNIGHT DELIVERY

Mr. Christopher V. B. Smith

Corporate President, CEO

H. J. Baker & Bro., Inc.

228 Saugatuck Avenue

Westport, Connecticut 06880

Dear Mr. Smith:

On June 6, 8, 12-15, and 23, 2006, a U.S . Food and Drug Administration (FDA) investigator inspected

your animal feed protein supplement manufacturing facility, located at 603 Railroad Avenue,

Albertville, Alabama. The inspection revealed significant deviations from the requirements set forth in

Title 21, Code ofFederal Regulations, Part 589.2000 (21 CFR 589.2000), Animal Proteins Prohibited in

Ruminant Feed. This regulation is intended to prevent the establishment and amplification of Bovine

Spongiform Encephalopathy (BSE). You failed to follow the requirements of this regulation, resulting

in products being manufactured and distributed by your facility because they are adulterated within the

meaning of Section 402(a)(4) [21 USC 342(a)(4)] of the Federal Food, Drug, and Cosmetic Act (the

Act) and misbranded within the meaning of Section 403(a)(1) [21 USC 343(a)(1)] of the Act.

Our investigation determined adulteration resulted from the failure of your firm to establish and

implement measures sufficient to prevent commingling or cross-contamination . The adulterated feed

was subsequently misbranded because it was not properly labeled. Specifically, we found :

" Your firm failed to establish and use cleanout procedures or other means to prevent carry-over of

products which contain or may contain protein derived from mammalian tissues into animal protein

or feeds which may be used for ruminants, as required by 21 CFR 589.2000(e)(1)(iii)(B) .

Specifically, you failed to establish and use such measures for a screw auger installed in February

2005 . This auger is used to convey both prohibited and non-prohibited material to bulk storage bins.

In addition, you failed to follow the cleanout procedure your firm had developed for the receiving

systems. Your feed is, therefore, adulterated under Section 402(a)(4) [21 USC 342(a)(4)] of the Act.

" You failed to label all products which contained or may have contained prohibited materials with the

BSE cautionary statement, "Do not feed to cattle or other ruminants," as required by 21 CFR

589.2000(e)(1)(i) . Such products are misbranded under Section 403(3) [21 USC 343(a)(1)] of the

Act. These misbranded products include the three Pro-Pak products mentioned below, as well as

Page 2 - H. J . Baker & Bro., Inc., Albertville, Alabama Warning Letter No. 2007-NOL-O 1

those bulk loads of individual feed ingredients processed through this common screw auger and

distributed between the time it was installed in February 2005, and June 9, 2006 .

This letter is not intended to serve as an all-inclusive list of violations at your facility. As a

manufacturer of materials intended for animal feed use, you are responsible for ensuring your overall

operation and the products you manufacture and distribute are in compliance with the law. You should take prompt action to correct these violations, and you should establish a system whereby violations do not recur. Failure to promptly correct these violations may result in regulatory action, such as seizure and/or injunction, without further notice.

We acknowledge your June 16, 2006, voluntary recall of three products you manufactured from

February 2005 to June 2006. The three products recalled were: Pro-Lak Protein Concentrate for

Lactating Dairy Animals; Pro-Amino II for PreFresh and Lactating Cows; and, Pro-Pak Marine & Animal Protein Concentrate for Use in Animal Feed. Recall effectiveness checks and other measures

will determine the merit of this recall . We recognize you now label all products with the required BSE

cautionary statement and we also acknowledge your intent, given verbally to New Orleans District

management of the FDA, to discontinue the production of supplements which do not contain prohibited

materials. In your written response to this letter, please confirm in writing you have taken these steps.

You should notify this office in writing within 15 working days of receiving this letter, outlining the specific steps you have taken to bring your firm into compliance with the law, including the steps we acknowledge above and any additional steps you have taken. Your response should include an

explanation of each step taken to correct the violations and prevent their recurrence. If corrective action cannot be completed within 15 working days, state the reason for the delay and the date by which the corrections will be completed. Include copies of any available documentation demonstrating corrections have been made.

Your reply should be directed to Kari L. Batey, Compliance Officer, at the address above. If you have

questions regarding any issue in this letter, please contact Ms. Batey at (615) 366-7808.

Sincerely,

,

Carol S . Sanchez

Acting District Director

New Orleans District

Enclosure: Form FDA 483

cc: Craig R. Waterhouse

Plant Manager

H.J. Baker & Bros., Inc.

603 Railroad Avenue

Albertville, Alabama 35951-3419


http://www.fda.gov/foi/warning_letters/g6104d.pdf



MORE 2006 FEED BAN VIOLATIONS BELOW, ''IN COMMERCE'' ;


Subject: MAD COW FEED RECALL USA SEPT 6, 2006 1961.72 TONS IN COMMERCE AL,
TN, AND WV
Date: September 6, 2006 at 7:58 am PST

PRODUCT
a) EVSRC Custom dairy feed, Recall # V-130-6;
b) Performance Chick Starter, Recall # V-131-6;
c) Performance Quail Grower, Recall # V-132-6;
d) Performance Pheasant Finisher, Recall # V-133-6.
CODE
None
RECALLING FIRM/MANUFACTURER
Donaldson & Hasenbein/dba J&R Feed Service, Inc., Cullman, AL, by telephone
on June 23, 2006 and by letter dated July 19, 2006. Firm initiated recall is
complete.
REASON
Dairy and poultry feeds were possibly contaminated with ruminant based
protein.
VOLUME OF PRODUCT IN COMMERCE
477.72 tons
DISTRIBUTION
AL
______________________________
PRODUCT
a) Dairy feed, custom, Recall # V-134-6;
b) Custom Dairy Feed with Monensin, Recall # V-135-6.
CODE
None. Bulk product
RECALLING FIRM/MANUFACTURER
Recalling Firm: Burkmann Feed, Greeneville, TN, by Telephone beginning on
June 28, 2006.
Manufacturer: H. J. Baker & Bro., Inc., Albertville, AL. Firm initiated
recall is complete.
REASON
Possible contamination of dairy feeds with ruminant derived meat and bone
meal.
VOLUME OF PRODUCT IN COMMERCE
1,484 tons
DISTRIBUTION
TN and WV


http://www.fda.gov/bbs/topics/enforce/2006/ENF00968.html




Subject: MAD COW FEED RECALLS ENFORCEMENT REPORT FOR AUGUST 9, 2006 KY, LA,
MS, AL, GA, AND TN 11,000+ TONS
Date: August 16, 2006 at 9:19 am PST

RECALLS AND FIELD CORRECTIONS: VETERINARY MEDICINE - CLASS II
______________________________
PRODUCT
Bulk custom made dairy feed, Recall # V-115-6
CODE
None
RECALLING FIRM/MANUFACTURER
Hiseville Feed & Seed Co., Hiseville, KY, by telephone and letter on or
about July 14, 2006. FDA initiated recall is ongoing.
REASON
Custom made feeds contain ingredient called Pro-Lak which may contain
ruminant derived meat and bone meal.
VOLUME OF PRODUCT IN COMMERCE
Approximately 2,223 tons
DISTRIBUTION
KY

______________________________
PRODUCT
Bulk custom made dairy feed, Recall # V-116-6
CODE
None
RECALLING FIRM/MANUFACTURER
Rips Farm Center, Tollesboro, KY, by telephone and letter on July 14, 2006.
FDA initiated recall is ongoing.
REASON
Custom made feeds contain ingredient called Pro-Lak which may contain
ruminant derived meat and bone meal.
VOLUME OF PRODUCT IN COMMERCE
1,220 tons
DISTRIBUTION
KY

______________________________
PRODUCT
Bulk custom made dairy feed, Recall # V-117-6
CODE
None
RECALLING FIRM/MANUFACTURER
Kentwood Co-op, Kentwood, LA, by telephone on June 27, 2006. FDA initiated
recall is completed.
REASON
Possible contamination of animal feed ingredients, including ingredients
that are used in feed for dairy animals, with ruminant derived meat and bone
meal.
VOLUME OF PRODUCT IN COMMERCE
40 tons
DISTRIBUTION
LA and MS

______________________________
PRODUCT
Bulk Dairy Feed, Recall V-118-6
CODE
None
RECALLING FIRM/MANUFACTURER
Cal Maine Foods, Inc., Edwards, MS, by telephone on June 26, 2006. FDA
initiated recall is complete.
REASON
Possible contamination of animal feed ingredients, including ingredients
that are used in feed for dairy animals, with ruminant derived meat and bone
meal.
VOLUME OF PRODUCT IN COMMERCE
7,150 tons
DISTRIBUTION
MS

______________________________
PRODUCT
Bulk custom dairy pre-mixes, Recall # V-119-6
CODE
None
RECALLING FIRM/MANUFACTURER
Walthall County Co-op, Tylertown, MS, by telephone on June 26, 2006. Firm
initiated recall is complete.
REASON
Possible contamination of dairy animal feeds with ruminant derived meat and
bone meal.
VOLUME OF PRODUCT IN COMMERCE
87 tons
DISTRIBUTION
MS

______________________________
PRODUCT
Bulk custom dairy pre-mixes, Recall # V-120-6
CODE
None
RECALLING FIRM/MANUFACTURER
Ware Milling Inc., Houston, MS, by telephone on June 23, 2006. Firm
initiated recall is complete.
REASON
Possible contamination of dairy animal feeds with ruminant derived meat and
bone meal.
VOLUME OF PRODUCT IN COMMERCE
350 tons
DISTRIBUTION
AL and MS

______________________________
PRODUCT
a) Tucker Milling, LLC Tm 32% Sinking Fish Grower, #2680-Pellet,
50 lb. bags, Recall # V-121-6;
b) Tucker Milling, LLC #31120, Game Bird Breeder Pellet,
50 lb. bags, Recall # V-122-6;
c) Tucker Milling, LLC #31232 Game Bird Grower,
50 lb. bags, Recall # V-123-6;
d) Tucker Milling, LLC 31227-Crumble, Game Bird Starter, BMD
Medicated, 50 lb bags, Recall # V-124-6;
e) Tucker Milling, LLC #31120, Game Bird Breeder, 50 lb bags,
Recall # V-125-6;
f) Tucker Milling, LLC #30230, 30 % Turkey Starter, 50 lb bags,
Recall # V-126-6;
g) Tucker Milling, LLC #30116, TM Broiler Finisher,
50 lb bags, Recall # V-127-6
CODE
All products manufactured from 02/01/2005 until 06/20/2006
RECALLING FIRM/MANUFACTURER
Recalling Firm: Tucker Milling LLC, Guntersville, AL, by telephone and visit
on June 20, 2006, and by letter on June 23, 2006.
Manufacturer: H. J. Baker and Brothers Inc., Stamford, CT. Firm initiated
recall is ongoing.
REASON
Poultry and fish feeds which were possibly contaminated with ruminant based
protein were not labeled as "Do not feed to ruminants".
VOLUME OF PRODUCT IN COMMERCE
7,541-50 lb bags
DISTRIBUTION
AL, GA, MS, and TN

END OF ENFORCEMENT REPORT FOR AUGUST 9, 2006

###


http://www.fda.gov/bbs/topics/ENFORCE/2006/ENF00964.html


Subject: MAD COW FEED RECALL MI MAMMALIAN PROTEIN VOLUME OF PRODUCT IN
COMMERCE 27,694,240 lbs
Date: August 6, 2006 at 6:14 pm PST
PRODUCT
Bulk custom dairy feds manufactured from concentrates, Recall # V-113-6
CODE
All dairy feeds produced between 2/1/05 and 6/16/06 and containing H. J.
Baker recalled feed products.
RECALLING FIRM/MANUFACTURER
Vita Plus Corp., Gagetown, MI, by visit beginning on June 21, 2006. Firm
initiated recall is complete.
REASON
The feed was manufactured from materials that may have been contaminated
with mammalian protein.
VOLUME OF PRODUCT IN COMMERCE
27,694,240 lbs
DISTRIBUTION
MI


END OF ENFORCEMENT REPORT FOR AUGUST 2, 2006

###


http://www.fda.gov/bbs/topics/enforce/2006/ENF00963.html


Subject: MAD COW FEED RECALL AL AND FL VOLUME OF PRODUCT IN COMMERCE 125
TONS Products manufactured from 02/01/2005 until 06/06/2006
Date: August 6, 2006 at 6:16 pm PST
PRODUCT
a) CO-OP 32% Sinking Catfish, Recall # V-100-6;
b) Performance Sheep Pell W/Decox/A/N, medicated,
net wt. 50 lbs, Recall # V-101-6;
c) Pro 40% Swine Conc Meal -- 50 lb, Recall # V-102-6;
d) CO-OP 32% Sinking Catfish Food Medicated,
Recall # V-103-6;
e) "Big Jim's" BBB Deer Ration, Big Buck Blend,
Recall # V-104-6;
f) CO-OP 40% Hog Supplement Medicated Pelleted,
Tylosin 100 grams/ton, 50 lb. bag, Recall # V-105-6;
g) Pig Starter Pell II, 18% W/MCDX Medicated 282020,
Carbadox -- 0.0055%, Recall # V-106-6;
h) CO-OP STARTER-GROWER CRUMBLES, Complete
Feed for Chickens from Hatch to 20 Weeks, Medicated,
Bacitracin Methylene Disalicylate, 25 and 50 Lbs,
Recall # V-107-6;
i) CO-OP LAYING PELLETS, Complete Feed for Laying
Chickens, Recall # 108-6;
j) CO-OP LAYING CRUMBLES, Recall # V-109-6;
k) CO-OP QUAIL FLIGHT CONDITIONER MEDICATED,
net wt 50 Lbs, Recall # V-110-6;
l) CO-OP QUAIL STARTER MEDICATED, Net Wt. 50 Lbs,
Recall # V-111-6;
m) CO-OP QUAIL GROWER MEDICATED, 50 Lbs,
Recall # V-112-6
CODE
Product manufactured from 02/01/2005 until 06/06/2006
RECALLING FIRM/MANUFACTURER
Alabama Farmers Cooperative, Inc., Decatur, AL, by telephone, fax, email and
visit on June 9, 2006. FDA initiated recall is complete.
REASON
Animal and fish feeds which were possibly contaminated with ruminant based
protein not labeled as "Do not feed to ruminants".
VOLUME OF PRODUCT IN COMMERCE
125 tons
DISTRIBUTION
AL and FL


END OF ENFORCEMENT REPORT FOR AUGUST 2, 2006

###


http://www.fda.gov/bbs/topics/enforce/2006/ENF00963.html


Subject: MAD COW FEED RECALL KY VOLUME OF PRODUCT IN COMMERCE ?????
Date: August 6, 2006 at 6:19 pm PST
PRODUCT
Bulk custom made dairy feed, Recall # V-114-6
CODE
None
RECALLING FIRM/MANUFACTURER
Burkmann Feeds LLC, Glasgow, KY, by letter on July 14, 2006. Firm initiated
recall is ongoing.
REASON
Custom made feeds contain ingredient called Pro-Lak, which may contain
ruminant derived meat and bone meal.
VOLUME OF PRODUCT IN COMMERCE
?????
DISTRIBUTION
KY
END OF ENFORCEMENT REPORT FOR AUGUST 2, 2006

###


http://www.fda.gov/bbs/topics/enforce/2006/ENF00963.html


CJD WATCH MESSAGE BOARD
TSS
MAD COW FEED RECALL USA EQUALS 10,878.06 TONS NATIONWIDE
Sun Jul 16, 2006 09:22
71.248.128.67


RECALLS AND FIELD CORRECTIONS: VETERINARY MEDICINE -- CLASS II
______________________________
PRODUCT
a) PRO-LAK, bulk weight, Protein Concentrate for Lactating Dairy Animals,
Recall # V-079-6;
b) ProAmino II, FOR PREFRESH AND LACTATING COWS, net weight 50lb (22.6 kg),
Recall # V-080-6;
c) PRO-PAK, MARINE & ANIMAL PROTEIN CONCENTRATE FOR USE IN ANIMAL
FEED, Recall # V-081-6;
d) Feather Meal, Recall # V-082-6
CODE
a) Bulk
b) None
c) Bulk
d) Bulk
RECALLING FIRM/MANUFACTURER
H. J. Baker & Bro., Inc., Albertville, AL, by telephone on June 15, 2006 and
by press release on June 16, 2006. Firm initiated recall is ongoing.
REASON
Possible contamination of animal feeds with ruminent derived meat and bone
meal.
VOLUME OF PRODUCT IN COMMERCE
10,878.06 tons
DISTRIBUTION
Nationwide

END OF ENFORCEMENT REPORT FOR July 12, 2006

###


http://www.fda.gov/bbs/topics/enforce/2006/ENF00960.html


Subject: MAD COW FEED BAN WARNING LETTER ISSUED MAY 17, 2006
Date: June 27, 2006 at 7:42 am PST
Public Health Service
Food and Drug Administration

New Orleans District
297 Plus Park Blvd.
Nashville, TN 37217

Telephone: 615-781-5380
Fax: 615-781-5391


May 17, 2006

WARNING LETTER NO. 2006-NOL-06

FEDERAL EXPRESS
OVERNIGHT DELIVERY

Mr. William Shirley, Jr., Owner
Louisiana.DBA Riegel By-Products
2621 State Street
Dallas, Texas 75204

Dear Mr. Shirley:

On February 12, 17, 21, and 22, 2006, a U.S. Food & Drug Administration
(FDA) investigator inspected your rendering plant, located at 509 Fortson
Street, Shreveport, Louisiana. The inspection revealed significant
deviations from the requirements set forth in Title 21, Code of Federal
Regulations, Part 589.2000 [21 CFR 589.2000], Animal Proteins Prohibited in
Ruminant Feed. This regulation is intended to prevent the establishment and
amplification of Bovine Spongiform Encephalopathy (BSE). You failed to
follow the requirements of this regulation; products being manufactured and
distributed by your facility are misbranded within the meaning of Section
403(a)(1) [21 USC 343(a)(1)] of the Federal Food, Drug, and Cosmetic Act
(the Act).

Our investigation found you failed to provide measures, including sufficient
written procedures, to prevent commingling or cross-contamination and to
maintain sufficient written procedures [21 CFR 589.2000(e)] because:

You failed to use clean-out procedures or other means adequate to prevent
carryover of protein derived from mammalian tissues into animal protein or
feeds which may be used for ruminants. For example, your facility uses the
same equipment to process mammalian and poultry tissues. However, you use
only hot water to clean the cookers between processing tissues from each
species. You do not clean the auger, hammer mill, grinder, and spouts after
processing mammalian tissues.

You failed to maintain written procedures specifying the clean-out
procedures or other means to prevent carryover of protein derived from
mammalian tissues into feeds which may be used for ruminants.

As a result . the poultry meal you manufacture may contain protein derived
from mammalian tissues prohibited in ruminant feed. Pursuant to 21 CFR
589.2000(e)(1)(i), any products containing or may contain protein derived
from mammalian tissues must be labeled, "Do not feed to cattle or other
ruminants." Since you failed to label a product which may contain protein
derived from mammalian tissues with the required cautionary statement. the
poultry meal is misbranded under Section 403(a)(1) [21 USC 343(a)(1)] of the
Act.

This letter is not intended as an all-inclusive list of violations at your
facility. As a manufacturer of materials intended for animal feed use, you
are responsible for ensuring your overall operation and the products you
manufacture and distribute are in compliance with the law. You should take
prompt action to correct these violations, and you should establish a system
whereby violations do not recur. Failure to promptly correct these
violations may result in regulatory action, such as seizure and/or
injunction, without further notice.

You should notify this office in writing within 15 working days of receiving
this letter, outlining the specific steps you have taken to bring your firm
into compliance with the law. Your response should include an explanation of
each step taken to correct the violations and prevent their recurrence. If
corrective action cannot be completed within 15 working days, state the
reason for the delay and the date by which the corrections will be
completed. Include copies of any available documentation demonstrating
corrections have been made.

Your reply should be directed to Mark W. Rivero, Compliance Officer, U.S.
Food and Drug Administration, 2424 Edenborn Avenue, Suite 410, Metairie,
Louisiana 70001. If you have questions regarding any issue in this letter,
please contact Mr. Rivero at (504) 219-8818, extension 103.

Sincerely,

/S

Carol S. Sanchez
Acting District Director
New Orleans District


http://www.fda.gov/foi/warning_letters/g5883d.htm



Subject: MAD COW FEED RECALL 220,740 LBS Biofix Holding Inc, Denton, TX
Date: December 22, 2006 at 8:51 am PST
PRODUCT
Harina De Carne Y Hueso Porcina 58% Proteina (Pork Meat and Bone Meal 58% Protein), 50 kg bags, Recall # V-005-2007
CODE
No lot number. Shipment Purchase Order number: BH-06-1085.
RECALLING FIRM/MANUFACTURER:
Recalling Firm: Biofix Holding Inc, Denton, TX, by letter on October 16, 2006.
Manufacturer: Allied Premium Protein, Gaffney, SC. Firm initiated recall is ongoing.
REASON
Pork Meal with potential to be contaminated with prohibited material distributed without cautionary statement.
VOLUME OF PRODUCT IN COMMERCE
220,740 lbs
DISTRIBUTION
Honduras


END OF ENFORCEMENT REPORT FOR December 20, 2006

###


http://www.fda.gov/bbs/topics/enforce/2006/ENF00983.html




NOW, look at the table and you'll see that as little as 1 mg (or 0.001 gm) caused
7% (1 of 14) of the cows to come down with BSE;


Risk of oral infection with bovine spongiform encephalopathy agent in
primates

Corinne Ida Lasmézas, Emmanuel Comoy, Stephen Hawkins, Christian Herzog,
Franck Mouthon, Timm Konold, Frédéric Auvré, Evelyne Correia, Nathalie
Lescoutra-Etchegaray, Nicole Salès, Gerald Wells, Paul Brown, Jean-Philippe
Deslys
Summary The uncertain extent of human exposure to bovine spongiform
encephalopathy (BSE)--which can lead to variant Creutzfeldt-Jakob disease
(vCJD)--is compounded by incomplete knowledge about the efficiency of oral
infection and the magnitude of any bovine-to-human biological barrier to
transmission. We therefore investigated oral transmission of BSE to
non-human primates. We gave two macaques a 5 g oral dose of brain homogenate
from a BSE-infected cow. One macaque developed vCJD-like neurological
disease 60 months after exposure, whereas the other remained free of disease
at 76 months. On the basis of these findings and data from other studies, we
made a preliminary estimate of the food exposure risk for man, which
provides additional assurance that existing public health measures can
prevent transmission of BSE to man.


snip...


BSE bovine brain inoculum

100 g 10 g 5 g 1 g 100 mg 10 mg 1 mg 0·1 mg 0·01 mg

Primate (oral route)* 1/2 (50%)

Cattle (oral route)* 10/10 (100%) 7/9 (78%) 7/10 (70%) 3/15 (20%) 1/15 (7%)
1/15 (7%)

RIII mice (ic ip route)* 17/18 (94%) 15/17 (88%) 1/14 (7%)

PrPres biochemical detection

The comparison is made on the basis of calibration of the bovine inoculum
used in our study with primates against a bovine brain inoculum with a
similar PrPres concentration that was

inoculated into mice and cattle.8 *Data are number of animals
positive/number of animals surviving at the time of clinical onset of
disease in the first positive animal (%). The accuracy of

bioassays is generally judged to be about plus or minus 1 log. ic
ip=intracerebral and intraperitoneal.

Table 1: Comparison of transmission rates in primates and cattle infected
orally with similar BSE brain inocula


Published online January 27, 2005

http://www.thelancet.com/journal/journal.isa




It is clear that the designing scientists must

also have shared Mr Bradley's surprise at the results because all the dose

levels right down to 1 gram triggered infection.


http://www.bseinquiry.gov.uk/files/ws/s145d.pdf






Working Group Report on

the Assessment of the Geographical BSE-Risk (GBR) of

CANADA

2004



snip...



- 2 -

2. EXTERNAL CHALLENGES

2.1 Import of cattle from BSE-Risk2 countries

An overview of the data on live cattle imports is presented in table 1 and is based on

data as provided in the country dossier (CD) and corresponding data on relevant exports

as available from BSE risk countries that exported to Canada. Only data from risk

periods are indicated, i.e. those periods when exports from a BSE risk country already

represented an external challenge, according to the SSC opinion on the GBR (SSC July

2000 and updated January 2002).

• According to the CD, 231 cattle were imported from UK during the years 1980 to

1990 and no cattle imports from UK were recorded after 1990.

• According to Eurostat, altogether 198 cattle have been imported from the UK during

the years 1980 to 1990, Additionally 500 were recorded in 1993; this import is

1 For the purpose of the GBR assessment the abbreviation "MBM" refers to rendering products, in particular

the commodities Meat and Bone Meal as such; Meat Meal; Bone Meal; and Greaves. With regard to imports

it refers to the customs code 230110 "flours, meals and pellets, made from meat or offal, not fit for human

2 BSE-Risk countries are all countries already assessed as GBR III or IV or with at least one confirmed

Annex to the EFSA Scientific Report (2004) 2, 1-14 on the Assessment of the

Geographical BSE Risk of Canada

- 3 -

mentioned in Eurostat and the updated UK export statistic as male calves, but not

mentioned in the original UK export statistics. According to the CD, detailed

investigations were carried out and it is very unlikely that the 500 calves have been

imported. Therefore, they were not taken into account.

• According to the CD, in 1990 all cattle imported from UK and Ireland since 1982

were placed in a monitoring program.

• Following the occurrence of the BSE index case in 1993 (imported from UK in 1987

at the age of 6 months), an attempt was made to trace all other cattle imported from

UK between 1982 and 1990.

• Of the 231 cattle imported from the UK between 1980 and 1990, 108 animals had

been slaughtered and 9 had died. From the remaining, 37 were exported, 76 were

sent to incineration and one was buried; these were not entering the rendering system

and therefore not taken into account.

• According to the CD, 16 cattle were imported from Ireland (according to Eurostat

20), of which 9 were slaughtered, 3 died. The remaining 4 were incinerated and did

therefore not enter the rendering system. According to the CD, the 6 animals which

were imported in 1990 according to Eurostat, were never imported.

• Moreover 22 cattle have been imported from Japan (through USA), of which 4 were

exported (excluded from the table) and 14 were destroyed and therefore not entering

the rendering system, 4 were slaughtered.

• Of 28 imported bovines from Denmark, 1 was destroyed and 1 was exported. Of the

19 buffalos imported in 2000, 1 was incinerated and the others were ordered to be

destroyed.

• Additionally in total 264 cattle according to the CD (276 according to other sources)

were imported from Austria, France, Germany, Hungary, Italy, The Netherlands and

Switzerland.

• The numbers imported according to the CD and Eurostat are very similar. Some

discrepancies in the year of import can be explained by an extended quarantine;

therefore it is likely that imports according to Eurostat in 1980 and imports

according to the CD in 1981 are referring to the same animals.

• Additionally, between 16.000 and 340.000 bovines have annually been imported

from US, almost all are steers and heifers. In total, between 1981 and 2003,

according to the CD more than 2.3 million, according to other sources 1.5 million

cattle have been imported.

• According to the CD, feeder/slaughter cattle represent typically more than 90% of

the imported cattle from the USA; therefore, only 10% of the imported cattle have

been taken into account.



snip...



Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the

Geographical BSE Risk of Canada

2.2 Import of MBM or MBM-containing feedstuffs from BSE-Risk

countries

An overview of the data on MBM imports is presented in table 2 and is based on data

provided in the country dossier (CD) and corresponding data on relevant exports as

available from BSE risk countries that exported to Canada. Only data from risk periods

are indicated, i.e. those periods when exports from a BSE risk country already

represented an external challenge, according to the SSC opinion on the GBR (SSC, July

2000 and updated January 2002).

According to the CD, no imports of MBM took place from UK since 1978 (initially

because of FMD regulations).

• According to Eurostat data, Canada imported 149 tons MBM from the UK in the

period of 1993 to 2001. According to up-dated MBM statistics from UK (August

2001) no mammalian MBM was exported to Canada from 1993 – 1996. As it was

illegal to export mammalian meat meal, bone meal and MBM from UK since

27/03/1996, exports indicated after that date should only have included nonmammalian

MBM. Therefore, these imports were not taken into account.

• According to the CD, imports of MBM have taken place from Denmark, Germany,

France, Japan and US.

• According to Eurostat Canada imported MBM from Denmark, Belgium, France and

Ireland.

• According to the CD further investigations concluded that all imported MBM from

Denmark consisted of pork and poultry origin and was directly imported for

aquaculture, the imported MBM from France was feather meal, the imported MBM

from Germany was poultry meal for aquaculture and the imported MBM from

Belgium was haemoglobin; therefore these imports were not taken into account.

• The main imports of MBM were of US origin, according to the CD around 250.000

tons, according to other sources around 310.000 tons between 1988 and 2003.



snip...



2.3 Overall assessment of the external challenge

The level of the external challenge that has to be met by the BSE/cattle system is

estimated according to the guidance given by the SSC in its final opinion on the GBR of

July 2000 (as updated in January 2002).

Live cattle imports:

In total the country imported according to the CD more than 2.3 million, according to

other data 1.5 million live cattle from BSE risk countries, of which 231 (CD)

respectively 698 (other sources) came from the UK. The numbers shown in table 1 are

the raw import figures and are not reflecting the adjusted imports for the assessment of

the external challenge. Broken down to 5 year periods the resulting external challenge is

as given in table 3. This assessment takes into account the different aspects discussed

above that allow to assume that certain imported cattle did not enter the domestic

BSE/cattle system, i.e. were not rendered into feed. In the case of Canada, the 500 cattle

imported from UK according to Eurostat were not taken into account and it is assumed

that all incinerated, buried, exported animals and the animals still alive did not enter the

rendering system and were therefore excluded from the external challenge.

MBM imports:

In total the country imported according to the CD around 300.000 tons, according to

other sources nearly 360.000 tons of MBM from BSE risk countries, of which 149 tons

came from the UK. The majority consisted of MBM imported from the US. The

numbers shown in table 2 are the raw import figures and are not reflecting the adjusted

imports for the assessment of the external challenge. Broken down to 5 year periods the

resulting external challenge is as given in table 3. This assessment takes into account

the different aspects discussed above that allow to assume that certain imported MBM

did not enter the domestic BSE/cattle system or did not represent an external challenge

for other reasons. As it was illegal to export mammalian meat meal, bone meal and

MBM from UK since 27/03/1996, exports indicated after that date should only have

included non-mammalian MBM. In the case of Canada all imported MBM from UK,

Germany, Belgium, Denmark and France was not taken into account.



snip...



3. STABILITY

3.1 Overall appreciation of the ability to avoid recycling of BSE

infectivity, should it enter processing

Feeding

The annual Canadian production of MBM is approximately 575,000 tons of which

approx. 40,000 tons are exported each year, mainly to USA.

Use of MBM in cattle feed

• Before the feed ban, dairy cattle received supplementary feed containing MBM

during their productive life (maximum 200-400 g MBM per day). Beef cattle in the

western part of the country do not usually receive complementary feed. Beef cattle

in the eastern part receive normally no supplement protein but the calves could have

access to creep feeds containing MBM, after weaning the ratios may have contained

supplemental protein containing MBM (100-400 g per day).

• According to the CD, MBM is mainly fed to pigs and poultry and included in pet

food.

• According to the CD, only a proportion of dairy cattle may have received MBM.

Feed bans

• Before 1997, there was no legal restriction to include MBM into cattle feed.

• An MBM-ban was introduced in August 1997; it is forbidden since to feed

mammalian MBM to ruminants except if of pure porcine, equine and non

mammalian origin, i.e. in practice a ruminant-to-ruminant ban (RMBM-ban).

Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the

Geographical BSE Risk of Canada

- 9 -

Potential for cross-contamination and measures taken against

• Cross-contamination in the about 600 feed mills is assumed to be possible as long as

cattle and pig feed is produced in the same production lines, and premises.

• Cross-contamination during transport is possible, particularly if the same trucks are

used for transporting ruminant MBM (RMBM) and non-ruminant MBM (porcine or

poultry MBM which still might be included into cattle feed) or for transporting

pig/poultry feed and cattle feed.

• On-farm cross-contamination is regarded to be possible.

• Cross-contamination of cattle feed with RMBM can not be excluded. Hence, as

reasonable worst case scenario, it has to be assumed that cattle, in particular dairy

cattle, can still be exposed to RMBM and hence to BSE-infectivity, should it enter

the feed chain.

Control of Feed bans and cross-contamination

• With the introduction of the RMBM ban (1997) the feed mills (approximately 600)

were checked for compliance with the ban, including good manufacturing practices

(GMP) and record keeping, i.e. the separation in production of MBM containing

ruminant material (RMBM) from non-ruminant MBM.

• The feed mills had previously – since 1983 – been regularly checked in relation to

production of medicated feed.

• No examinations are performed to assess cross-contamination with RMBM of the

protein (e.g. non ruminant MBM) that enters cattle feed. Differentiation would

anyway be difficult.

Rendering

Raw material used for rendering

• Ruminant material is rendered together with material from other species, but

according to the CD only in the production of MBM prohibited for use in ruminant

feeds.

• Slaughter by-products, including specified risk material (SRM) and fallen stock are

rendered.

• The country expert estimated that 20% of the rendering plants, processing 20% of

the total amount of raw material, are connected to slaughterhouses. Their raw

material is more than 98 % animal waste from these slaughterhouses while less than

2 % is fallen stock. No estimation was given for the remaining 80% of the rendering

capacity.

• There are 32 rendering plants of which 3 are processing blood exclusively.

Rendering processes

• The rendering systems (parameters) were specified for 6 plants producing mixed

MBM, none of these fulfilled the 133/20/3 standard. Of these, 5 have dedicated

facilities to produce products for use in ruminant feed and products not permitted for

use in ruminant feed.

• The remaining plants process porcine or poultry material exclusively.

SRM and fallen stock

• There is an SRM ban for human food in place since 2003.

Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the

Geographical BSE Risk of Canada

- 10 -

• However, SRM are rendered together with other slaughter waste and fallen stock.

However, according to the CD, MBM with SRM is not permitted to be fed to

ruminants.

Conclusion on the ability to avoid recycling

• Between 1980 and 1997 the Canadian system would not have been able to avoid

recycling of the BSE-agent to any measurable extent. If the BSE-agent was

introduced into the feed chain, it could have reached cattle.

• Since 1997 this ability gradually improved with the introduction of the ruminant

MBM ban and its implementation.

• Since cross-contamination cannot be excluded, and as SRM is still rendered by

processes unable to significantly reduce BSE-infectivity, the system is still unable to

avoid recycling of BSE-infectivity already present in the system or incoming.

3.2 Overall appreciation of the ability to identify BSE-cases and to

eliminate animals at risk of being infected before they are processed

Cattle population structure

• Cattle population: 12.15 Million in 1988 increasing to 14.6 Million in 2001;

• Of the total cattle population, 2.2 million are dairy cattle and 12.4 million are beef.

• The cattle population above 24 months of age: approx. 6.0 Million.

• Of the approximately 2.2 Million dairy cattle 2 Million are located in the two eastern

provinces Ontario and Quebec.

• Mixed farming (cattle and mono-gastric species) is usually not practiced; the

country expert estimated the proportion of mixed farming to be less than 1%.

• Individual regions traditionally have ID systems under provincial authorities. Brand

inspectors are present when cattle are assembled. It is estimated by the Canadians

that the level of a national, uniform ID for cattle is less than 10%; most of those

individual pedigree animals. Mandatory ID for the milk-fed veal sector was

implemented in Quebec in 1996, but does not contain information on the herd of

origin. An agreement of the relevant industries to develop a national cattle ID and

trace back strategy was reached on 1 May 1998 (starting in 2001).Since 2002, a

national identification program is existing. Al cattle leaving any farm premises must

be uniquely identified by ear tag.

BSE surveillance

• BSE was made notifiable in 1990.

• Every cow over one year of age exhibiting central nervous system signs suggestive

of BSE submitted to a laboratory or presented at an abattoir is subjected to a BSE

laboratory diagnostic test (histology and over the past years also PrPSc-based

laboratory tests).

• In addition, cattle submitted for rabies examination and found rabies negative are

examined for BSE. Samples are prepared immediately upon arrival to the federal

laboratory responsible for the rabies diagnostic for possible later BSE examination,

i.e. formalin fixation.

• Since the 1940's, a rabies control program has been in place, where farmers,

veterinarians and the general public are well educated about this neurological

Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the

Geographical BSE Risk of Canada

- 11 -

disease. In 1990, when BSE was made notifiable, this awareness was extended to

suspicions of BSE.

• Since 1993 the number of brains examined per year did exceed the number

recommended by OIE (300 - 336 for countries with a cattle population over 24

months of age of 5.0 to 7.0 Million) in all years, except in 1995 (table 4).

year 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003

samples 225 645 426 269 454 759 940 895

 

[flounder]

Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the

Geographical BSE Risk of Canada

- 11 -

disease. In 1990, when BSE was made notifiable, this awareness was extended to

suspicions of BSE.

• Since 1993 the number of brains examined per year did exceed the number

recommended by OIE (300 - 336 for countries with a cattle population over 24

months of age of 5.0 to 7.0 Million) in all years, except in 1995 (table 4).

year 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003

samples 225 645 426 269 454 759 940 895 1´020 1´581 3´377 3´361

Table 4: Number of bovine brains annually examined for CNS diseases, including BSE.

• According to the CD approx. 98% of the examined cattle were older than 24 months

and approx. 90% exhibited neurological symptoms. Although the identification

system of Canada does not document the birth date or age of the animals, according

to the CD, examination of the dentition is used to ascertain the maturity of the

animals.

• The list of neurological differential diagnoses for the 754 brains examined in 1997

included encephalitis (70 cases), encephalomalacia (19), hemophilus (7),

hemorrhage (2), listeriosis (38), meningoencephalitis (36), rabies (22), tumors (2),

other conditions (135) and no significant findings (423).

• Compensation is paid for suspect BSE cases as well as for animals ordered to be

destroyed (90-95% of market value with a maximum of 2,500 Can$ per cow).

• Diagnostic criteria developed in the United Kingdom are followed at ADRI,

Nepean. According to the very detailed protocol for the collection, fixation and

submission of Bovine Spongiform Encephalopathy (BSE) specimens at abattoirs

under inspection by the Canadian Food Inspection Agency, the specimen shall be

shipped to National Center for Foreign Animal Disease, Winnipeg, Manitoba.

• In 2003, around 3000 animals from risk populations have been tested.

• According to the CD, it is aimed to test a minimum of 8000 risk animals (animals

with clinical signs consistent with BSE, downer cows, animals died on farm animals

diseased or euthanized because of serious illness) in 2004 and then continue to

progressively increase the level of testing to 30,000.

• In May 2003, Canada reported its first case of domestic BSE. A second case was

detected in the US on 23 December 2003 and traced back to Canadian origin. Both

were born before the feed ban and originated from Western Canada.

3.3 Overall assessment of the stability

For the overall assessment of the stability, the impact of the three main stability factors

(i.e. feeding, rendering and SRM-removal) and of the additional stability factor,

surveillance, has to be estimated. Again, the guidance provided by the SSC in its

opinion on the GBR of July 2000 (as updated January 2002) is applied.

Feeding

Until 1997, it was legally possible to feed ruminant MBM to cattle and a certain fraction of

cattle feed (for calves and dairy cattle) is assumed to have contained MBM. Therefore

feeding was "Not OK". In August 1997 a ruminant MBM ban was introduced but feeding

of non-ruminant MBM to cattle remained legal as well as feeding of ruminant MBM to

non-ruminant animals. This makes control of the feed ban very difficult because laboratory

differentiation between ruminant and non ruminant MBM is difficult if not impossible.

Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the

Geographical BSE Risk of Canada

Due to the highly specialised production system in Canada, various mammalian MBM

streams can be separated. Such a feed ban would therefore be assessed as "reasonably

OK", for all regions where this highly specialised system exists. However, several areas

in Canada do have mixed farming and mixed feed mills, and in such regions, an RMBM

ban would not suffice. Additionally, official controls for cattle feeds to control for the

compliance with the ban were not started until the end of 2003. Thus, for the whole

country, the assessment of the feeding after 1997 remains "Not OK".

Rendering

The rendering industry is operating with processes that are not known to reduce infectivity.

It is therefore concluded that the rendering was and is "Not OK".

SRM-removal

SRM and fallen stock were and are rendered for feed. Therefore SRM-removal is assessed

as "Not OK"



snip...



4.2 Risk that BSE infectivity entered processing

A certain risk that BSE-infected cattle entered processing in Canada, and were at least

partly rendered for feed, occurred in the early 1990s when cattle imported from UK in

the mid 80s could have been slaughtered. This risk continued to exist, and grew

significantly in the mid 90's when domestic cattle, infected by imported MBM, reached

processing. Given the low stability of the system, the risk increased over the years with

continued imports of cattle and MBM from BSE risk countries.

4.3 Risk that BSE infectivity was recycled and propagated

A risk that BSE-infectivity was recycled and propagated exists since a processing risk

first appeared; i.e. in the early 90s. Until today this risk persists and increases fast

because of the extremely unstable BSE/cattle system in Canada.

5. CONCLUSION ON THE GEOGRAPHICAL BSE-RISK

5.1 The current GBR as function of the past stability and challenge

The current geographical BSE-risk (GBR) level is III, i.e. it is confirmed at a lower level

that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent.

This assessment deviates from the previous assessment (SSC opinion, 2000) because at

that time several exporting countries were not considered a potential risk.

snip...

full text;




http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/scr_annexes/563/sr02_biohaz02_canada_report_annex_en1.pdf





EFSA Scientific Report on the Assessment of the Geographical BSE-Risk (GBR) of the United States of America (USA)
Publication date: 20 August 2004
Adopted July 2004 (Question N° EFSA-Q-2003-083)

Report

Summary
Summary of the Scientific Report

The European Food Safety Authority and its Scientific Expert Working Group on the Assessment of the Geographical Bovine Spongiform Encephalopathy (BSE) Risk (GBR) were asked by the European Commission (EC) to provide an up-to-date scientific report on the GBR in the United States of America, i.e. the likelihood of the presence of one or more cattle being infected with BSE, pre-clinically as well as clinically, in USA. This scientific report addresses the GBR of USA as assessed in 2004 based on data covering the period 1980-2003.

The BSE agent was probably imported into USA and could have reached domestic cattle in the middle of the eighties. These cattle imported in the mid eighties could have been rendered in the late eighties and therefore led to an internal challenge in the early nineties. It is possible that imported meat and bone meal (MBM) into the USA reached domestic cattle and leads to an internal challenge in the early nineties.

A processing risk developed in the late 80s/early 90s when cattle imports from BSE risk countries were slaughtered or died and were processed (partly) into feed, together with some imports of MBM. This risk continued to exist, and grew significantly in the mid 90's when domestic cattle, infected by imported MBM, reached processing. Given the low stability of the system, the risk increased over the years with continued imports of cattle and MBM from BSE risk countries.

EFSA concludes that the current GBR level of USA is III, i.e. it is likely but not confirmed that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. As long as there are no significant changes in rendering or feeding, the stability remains extremely/very unstable. Thus, the probability of cattle to be (pre-clinically or clinically) infected with the BSE-agent persistently increases.


http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/573_en.html

SUMMARY

Summary of Scientific Report
http://www.efsa.eu.int
1 of 1
Scientific Report of the European Food Safety Authority
on the Assessment of the Geographical BSE-Risk (GBR) of
United States of America (USA)
Question N° EFSA-Q-2003-083
Adopted July 2004
Summary of scientific report
The European Food Safety Authority and its Scientific Expert Working Group on the
Assessment of the Geographical Bovine Spongiform Encephalopathy (BSE) Risk (GBR)
were asked by the European Commission (EC) to provide an up-to-date scientific report on
the GBR in the United States of America, i.e. the likelihood of the presence of one or more
cattle being infected with BSE, pre-clinically as well as clinically, in USA. This scientific
report addresses the GBR of USA as assessed in 2004 based on data covering the period
1980-2003.
The BSE agent was probably imported into USA and could have reached domestic cattle in
the middle of the eighties. These cattle imported in the mid eighties could have been rendered
in the late eighties and therefore led to an internal challenge in the early nineties. It is possible
that imported meat and bone meal (MBM) into the USA reached domestic cattle and leads to
an internal challenge in the early nineties.
A processing risk developed in the late 80s/early 90s when cattle imports from BSE risk
countries were slaughtered or died and were processed (partly) into feed, together with some
imports of MBM. This risk continued to exist, and grew significantly in the mid 90's when
domestic cattle, infected by imported MBM, reached processing. Given the low stability of
the system, the risk increased over the years with continued imports of cattle and MBM from
BSE risk countries.
EFSA concludes that the current GBR level of USA is III, i.e. it is likely but not confirmed
that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. As long as
there are no significant changes in rendering or feeding, the stability remains extremely/very
unstable. Thus, the probability of cattle to be (pre-clinically or clinically) infected with the
BSE-agent persistently increases.
Key words: BSE, geographical risk assessment, GBR, USA, third countries

http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/573/sr03_biohaz02_usa_report_summary_en1.pdf



REPORT (6 PAGES)

snip...

EFSA Scientific Report (2004) 3, 1-6 on the Assessment of the Geographical BSE Risk of
Conclusions
The European Food Safety Authority concludes:
1. The BSE agent was probably imported into USA and could have reached domestic
cattle in the middle of the eighties. This cattle imported in the mid eighties could have
been rendered in the late eighties and therefore led to an internal challenge in the early
nineties. It is possible that meat and bone meal (MBM) imported into the USA
reached domestic cattle and lead to an internal challenge in the early nineties.
2. A processing risk developed in the late 80s/early 90s when cattle imports from BSE
risk countries were slaughtered or died and were processed (partly) into feed, together
with some imports of MBM. This risk continued to exist, and grew significantly in the
mid 90's when domestic cattle, infected by imported MBM, reached processing.
Given the low stability of the system, the risk increased over the years with continued
imports of cattle and MBM from BSE risk countries.
3. The current geographical BSE risk (GBR) level is III, i.e. it is likely but not confirmed
that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent.
4. This assessment deviates from the previous assessment (SSC opinion, 2000) because
at that time several exporting countries were not considered a potential risk.
5. It is also worth noting that the current GBR conclusions are not dependent on the large
exchange of imports between USA and Canada. External challenge due to exports to
the USA from European countries varied from moderate to high. These challenges
indicate that it was likely that BSE infectivity was introduced into the North American
continent.
6. EFSA and its Scientific Expert Working group on GBR are concerned that the
available information was not confirmed by inspection missions as performed by the
Food and Veterinary office (FVO – DG SANCO) in Member States and other third
countries. They recommend including, as far as feasible, BSE-related aspects in
future inspection missions.
Expected development of the GBR
As long as there are no significant changes in rendering or feeding, the stability remains
extremely/very unstable. Thus, the probability of cattle to be (pre-clinically or clinically)
infected with the BSE-agent persistently increases.
A table summarising the reasons for the current assessment is given in the table below

snip...

http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/573/sr03_biohaz02_usa_report_v2_en1.pdf



EFSA Scientific Report on the Assessment of the Geographical BSE-Risk (GBR) of Mexico
Last updated: 08 September 2004
Adopted July 2004 (Question N° EFSA-Q-2003-083)

Report

http://www.efsa.eu.int
3 of 6
Conclusions
The European Food Safety Authority concludes:
1. The BSE agent was probably imported into Mexico and could have reached domestic
cattle. These cattle imported could have been rendered and therefore led to an internal
EFSA Scientific Report (2004) 4, 1-6 on the Assessment of the Geographical BSE Risk of
challenge in the mid to late 1990's. It is possible that imported MBM into Mexico
reached domestic cattle and leads to an internal challenge around 1993.
2. It is likely that BSE infectivity entered processing at the time of imported 'at - risk'
MBM (1993) and at the time of slaughter of imported live 'at - risk' cattle (mid to late
1990s). The high level of external challenge is maintained throughout the reference
period, and the system has not been made stable. Thus it is likely that BSE infectivity
was recycled and propagated from approximately 1993. The risk has since grown
consistently due to a maintained internal and external challenge and lack of a stable
system.
3. The current geographical BSE risk (GBR) level is III, i.e. it is likely but not confirmed
that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent.
4. EFSA and its Scientific Expert Working group on GBR are concerned that the
available information was not confirmed by inspection missions as performed by the
Food and Veterinary office (FVO – DG SANCO) in Member States and other third
countries. They recommend including, as far as feasible, BSE-related aspects in
future inspection missions.

http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/565/sr04_biohaz02_mexico_report_v2_en1.pdf


Summary

Summary of Scientific Report
http://www.efsa.eu.int
1 of 2
Scientific Report of the European Food Safety Authority
on the Assessment of the Geographical BSE-Risk (GBR) of
MEXICO
Question N° EFSA-Q-2003-083
Adopted July 2004
SUMMARY OF SCIENTIFIC REPORT
The European Food Safety Authority and its Scientific Expert Working Group on the
Assessment of the Geographical Bovine Spongiform Encephalopathy (BSE) Risk (GBR)
were asked by the European Commission (EC) to provide an up-to-date scientific report on
the GBR in Mexico, i.e. the likelihood of the presence of one or more cattle being infected
with BSE, pre-clinically as well as clinically, in Mexico. This scientific report addresses the
GBR of Mexico as assessed in 2004 based on data covering the period 1980-2003.
The BSE agent was probably imported into Mexico and could have reached domestic cattle.
These cattle imported could have been rendered and therefore led to an internal challenge in
the mid to late 1990s. It is possible that imported meat and bone meal (MBM) into Mexico
reached domestic cattle and leads to an internal challenge around 1993.
It is likely that BSE infectivity entered processing at the time of imported 'at - risk' MBM
(1993) and at the time of slaughter of imported live 'at - risk' cattle (mid to late 1990s). The
high level of external challenge is maintained throughout the reference period, and the system
has not been made stable. Thus it is likely that BSE infectivity was recycled and propagated
from approximately 1993. The risk has since grown consistently due to a maintained internal
and external challenge and lack of a stable system.
EFSA concludes that the current geographical BSE risk (GBR) level is III, i.e. it is likely
but not confirmed that domestic cattle are (clinically or pre-clinically) infected with the BSEagent.
The GBR is likely to increase due to continued internal and external challenge, coupled
with a very unstable system.
Key words: BSE, geographical risk assessment, GBR, Mexico, third countries
Summary of Scientific Report
http://www.efsa.eu.int
2 of 2


http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/565/sr04_biohaz02_mexico_report_summary_en1.pdf




Summary of the Scientific Report

The European Food Safety Authority and its Scientific Expert Working Group on the Assessment of the Geographical Bovine Spongiform Encephalopathy (BSE) Risk (GBR) were asked by the European Commission (EC) to provide an up-to-date scientific report on the GBR in Mexico, i.e. the likelihood of the presence of one or more cattle being infected with BSE, pre-clinically as well as clinically, in Mexico. This scientific report addresses the GBR of Mexico as assessed in 2004 based on data covering the period 1980-2003.

The BSE agent was probably imported into Mexico and could have reached domestic cattle. These cattle imported could have been rendered and therefore led to an internal challenge in the mid to late 1990s. It is possible that imported meat and bone meal (MBM) into Mexico reached domestic cattle and leads to an internal challenge around 1993.

It is likely that BSE infectivity entered processing at the time of imported 'at - risk' MBM (1993) and at the time of slaughter of imported live 'at - risk' cattle (mid to late 1990s). The high level of external challenge is maintained throughout the reference period, and the system has not been made stable. Thus it is likely that BSE infectivity was recycled and propagated from approximately 1993. The risk has since grown consistently due to a maintained internal and external challenge and lack of a stable system.

EFSA concludes that the current geographical BSE risk (GBR) level is III, i.e. it is likely but not confirmed that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. The GBR is likely to increase due to continued internal and external challenge, coupled with a very unstable system.

http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/565_en.html



ONE YEAR PREVIOUSLY ;

From: Terry S. Singeltary Sr. [[email protected]]
Sent: Tuesday, July 29, 2003 1:03 PM
To: [email protected]
Cc: [email protected]; [email protected].; BSE-L
Subject: Docket No. 2003N-0312 Animal Feed Safety System [TSS SUBMISSION
TO DOCKET 2003N-0312]

Greetings FDA,

snip...

PLUS, if the USA continues to flagrantly ignore the _documented_ science to date about the known TSEs in the USA (let alone the undocumented TSEs in cattle), it is my opinion, every other Country that is dealing with BSE/TSE should boycott the USA and demand that the SSC reclassify the USA BSE GBR II risk assessment to BSE/TSE GBR III 'IMMEDIATELY'. for the SSC to _flounder_ any longer on this issue, should also be regarded with great suspicion as well. NOT to leave out the OIE and it's terribly flawed system of disease surveillance. the OIE should make a move on CWD in the USA, and make a risk assessment on this as a threat to human health. the OIE should also change the mathematical formula for testing of disease. this (in my opinion and others) is terribly flawed as well. to think that a sample survey of 400 or so cattle in a population of 100 million, to think this will find anything, especially after seeing how many TSE tests it took Italy and other Countries to find 1 case of BSE (1 million rapid TSE test in less than 2 years, to find 102 BSE cases), should be proof enough to make drastic changes of this system. the OIE criteria for BSE Country classification and it's interpretation is very problematic. a text that is suppose to give guidelines, but is not understandable, cannot be considered satisfactory. the OIE told me 2 years ago that they were concerned with CWD, but said any changes might take years. well, two years have come and gone, and no change in relations with CWD as a human health risk. if we wait for politics and science to finally make this connection, we very well may die before any decisions
or changes are made. this is not acceptable. we must take the politics and the industry out of any final decisions of the Scientific community. this has been the problem from day one with this environmental man made death sentence. some of you may think i am exaggerating, but you only have to see it once, you only have to watch a loved one die from this one time, and you will never forget, OR forgive...yes, i am still very angry... but the transmission studies DO NOT lie, only the politicians and the industry do... and they are still lying to this day...TSS


http://www.fda.gov/ohrms/dockets/dockets/03n0312/03N-0312_emc-000001.txt




Terry S. Singeltary Sr.
P.O. BOX 42
Bacliff, TEXAS USA 77518

 

[Bill]

so june 7 of what year??????

I don't know what year - it makes no difference. Put in any date that you like. That was R-CALF's stand then and it hasn't changed.

So where was the gnashing of the teeth and calls for heads to roll from your Lord's in Billings when USDA said they were REDUCING testing?

IT DIDN"T HAPPEN!

Your claims of R-KLan's support of increased testing is hailarious and shows them for the joke they are.

 

[Sandhusker]

so june 7 of what year??????

I don't know what year - it makes no difference. Put in any date that you like. That was R-CALF's stand then and it hasn't changed.

So where was the gnashing of the teeth and calls for heads to roll from your Lord's in Billings when USDA said they were REDUCING testing?

IT DIDN"T HAPPEN!

Your claims of R-KLan's support of increased testing is hailarious and shows them for the joke they are.

Yeah, you're right, Bill. Bullard publicly calling on the USDA to increase testing obviously means R-CALF is opposed to further testing. He was trying to pull some reverse psych, but couldn't get it past you.

 

[Bill]

I don't know what year - it makes no difference. Put in any date that you like. That was R-CALF's stand then and it hasn't changed.

So where was the gnashing of the teeth and calls for heads to roll from your Lord's in Billings when USDA said they were REDUCING testing?

IT DIDN"T HAPPEN!

Your claims of R-KLan's support of increased testing is hailarious and shows them for the joke they are.

Yeah, you're right, Bill. Bullard publicly calling on the USDA to increase testing obviously means R-CALF is opposed to further testing. He was trying to pull some reverse psych, but couldn't get it past you.

.........and once again folks the immortal Sandhusker can't find a single R-Klan statement denouncing the USDA's intention of reducing BSE testing so he dithers and twists and spins. Nothing opposing reduced testing yet he claims R-Klan really supports increased testing because of some antiquated statement.

Send 'em more money folks! Bullard and the rest of the legal team need a bigger Christams bonus.

:lol: :lol: :lol: :lol:

 

[Sandhusker]

Ranchers-Cattlemen Action Legal Fund United Stockgrowers of America (R-CALF USA) CEO Bill Bullard today is calling on the United States Department of Agriculture to strengthen plans for testing additional cattle for bovine spongiform encephalopathy (BSE) to ensure that the source of BSE is accurately identified and that the highest risk cattle are tested. Only then can U.S. consumers and cattle be protected, should BSE-infected cattle be discovered.


Nope, Bill, not one word. SH has taught you well. :roll:

 

[Bill]

Ranchers-Cattlemen Action Legal Fund United Stockgrowers of America (R-CALF USA) CEO Bill Bullard today is calling on the United States Department of Agriculture to strengthen plans for testing additional cattle for bovine spongiform encephalopathy (BSE) to ensure that the source of BSE is accurately identified and that the highest risk cattle are tested. Only then can U.S. consumers and cattle be protected, should BSE-infected cattle be discovered.


Nope, Bill, not one word. SH has taught you well. :roll:

Yes we all know Sandhusker and that was before USDA announced plans to REDUCE testing.

Since then you haven't been able to provide a single peep out of the R-Gods about BSE testing in the US.

NADA.....NOTHING.

That shows how fickle their statement was. If R-Klan was so strong in their belief (as you would like evryone to believe) that testing should be increased dontcha think they should have said something?

 

[Sandhusker]

Bill, "Yes we all know Sandhusker and that was before USDA announced plans to REDUCE testing"

Oh, you know that? Maybe you could tell Don, he was wanting to know when that statement was made. When did the USDA announce reduced testing and when was the statement?