Subject: UK's first case of H-type BSE confirmed by DEFRA
Date: March 9, 2007 at 11:03 am PST
UK's first case of H-type BSE confirmed by DEFRA
09/03/2007 16:28:00
FWi
DEFRA has reported the UK’s first case of H-type Bovine Spongiform Encephalopathy. During routine research carried out by the Veterinary Laboratories Agency, test results revealed a single case of H-type BSE in 2005.
News of this form of BSE, which produces no clinical signs and has only been found in older animals, was announced at a VLA symposium on prion diseases of domestic livestock in June 2006.
To date 18 cases of the H-type strain have been identified in 12 countries worldwide including several other European countries, Japan, Canada and the United States of America.
According to statement from DEFRA the cow died on a farm in Dumfries and Galloway at 13 years of age. The carcass was then sampled and tested for BSE in accordance with EU requirements for testing all fallen stock aged over 24 months.
Test results confirmed the presence of BSE. The carcass was incinerated and the offspring from this cow were culled in line with current BSE regulations.
In August 2006 the VLA began a retrospective examination of brain samples taken from previous BSE cases as part of a research programme designed to analyse different types of BSE in the national herd.
It was this exercise that identified the presence of a H-type case. All forms of BSE are treated identically therefore no additional action would have been required in this case.
The Spongiform Encephalopathy Advisory Committee will examine all the available data on this case during a discussion of different forms of BSE worldwide at their next meeting on 10 May 2007.
by Andrew Watts (About this Author)
http://www.fwi.co.uk/Articles/2007/03/09/102241/uks-first-case-of-h-type-bse-confirmed-by-defra.html
U.K. TSE RESEARCH 2005-2008
http://www.defra.gov.uk/animalh/Bse/pdf/tse-strategy0606.pdf
BSE cases in older cattle which resemble the two different atypical. BSE phenotypes that have recently been described in France. (designated H-type) and ...
http://www.seac.gov.uk/papers/96-2.pdf
----- Original Message -----
From: XXXXXXXX XXXXXXXXXXXX(SEAC)
To: '[email protected]'
Sent: Friday, February 23, 2007 8:13 AM
Subject: RE: SEAC ANNUAL REPORT 2006
Dear Mr Singeltary
Thank you for your email about a possible relationship between BASE and
sCJD.
SEAC is continually informed about and considers the emerging science on
both animal and human TSEs. The committee regularly receives updates from
the UK's National CJD Surveillance Centre Unit on the epidemiology of vCJD
and sCJD and is also aware of emerging research on BASE. It is envisaged
that SEAC will conduct a detailed consideration of the available science and
the possible animal and human health implications of BASE at its meeting on
10th May 2007.
Yours sincerely
XXXXXXXXXXXXXX
----------------------------------------------------------------------------
----
From: Terry S. Singeltary Sr. [mailto:[email protected]]
Sent: 02 February 2007 16:44
To: Bovine Spongiform Encephalopathy
Cc: SEACsecretariat (AHEG); [email protected];
[email protected]; [email protected]; Sustainable Agriculture
Network Discussion Group
Subject: SEAC ANNUAL REPORT 2006
Date: February 2, 2007 at 8:25 am PST
SEAC ANNUAL REPORT 2006 (ignoring the obvious)
http://www.seac.gov.uk/publicats/annualreport2006.pdf
i guess the sporadic CJD cases have all be resolved, and the route and cause
classified.
to this day, i cannot figure this out. if BSE farmers died from sporadic
CJD, and now another study seems to point
that BSE and BASE may be the same thing, and that BASE does not produce vCJD
like pathology, but pathology resembling that of sporadic CJD, then why does
SEAC still seem to put sporadic CJD on the back burners ??? IN fact, SEAC
could not even speak about it in there 2006 report. would it not seem
prudent to mention these findings in this 2006 SEAC report ;
Other work presented suggested that BSE and bovine amyloidotic spongiform
encephalopathy (BASE) MAY BE RELATED. A mutation had been identified in the
prion protein gene in an AMERICAN BASE CASE THAT WAS SIMILAR IN NATURE TO A
MUTATION FOUND IN CASES OF SPORADIC CJD.
snip...
http://www.seac.gov.uk/minutes/95.pdf
***These results indicate that BASE is transmissible to humans and suggest
that BASE is more virulent than
classical BSE in humans.***
6:30 Close of Day One
http://www.healthtech.com/2007/tse/day1.asp
64. A member noted that at the recent Neuroprion meeting, a study was
presented showing that in transgenic mice BSE passaged in sheep may be more
virulent and infectious to a wider range of species than bovine derived BSE.
http://www.seac.gov.uk/minutes/95.pdf
Asante/Collinge et al, that BSE transmission to the 129-methionine
genotype can lead to an alternate phenotype that is indistinguishable
from type 2 PrPSc, the commonest _sporadic_ CJD;
http://www.fda.gov/ohrms/dockets/ac/03/slides/3923s1_OPH.htm
I STILL think to ignore these findings below is not only rediculous, but
indeed very suspicious ;
CJD FARMERS WIFE 1989
http://www.bseinquiry.gov.uk/files/yb/1989/10/13007001.pdf
http://www.bseinquiry.gov.uk/files/yb/1989/10/13003001.pdf
cover-up of 4th farm worker ???
http://www.bseinquiry.gov.uk/files/yb/1995/10/23006001.pdf
http://www.bseinquiry.gov.uk/files/yb/1995/10/20006001.pdf
CONFIRMATION OF CJD IN FOURTH FARMER
http://www.bseinquiry.gov.uk/files/yb/1995/11/03008001.pdf
now story changes from;
SEAC concluded that, if the fourth case were confirmed, it would be
worrying, especially as all four farmers with CJD would have had BSE
cases on their farms.
to;
This is not unexpected...
was another farmer expected?
http://www.bseinquiry.gov.uk/files/yb/1995/11/13010001.pdf
4th farmer, and 1st teenager
http://www.bseinquiry.gov.uk/files/yb/1996/02/27003001.pdf
2. snip...
Over a 5 year period, which is the time period on which the advice
from Professor Smith and Dr. Gore was based, and assuming a
population of 120,000 dairy farm workers, and an annual incidence
of 1 per million cases of CJD in the general population, a
DAIRY FARM WORKER IS 5 TIMES MORE LIKELY THAN
an individual in the general population to develop CJD. Using the
actual current annual incidence of CJD in the UK of 0.7 per
million, this figure becomes 7.5 TIMES.
3. You will recall that the advice provided by Professor Smith in
1993 and by Dr. Gore this month used the sub-population of dairy
farm workers who had had a case of BSE on their farms -
63,000, which is approximately half the number of dairy farm
workers - as a denominator. If the above sums are repeated using
this denominator population, taking an annual incidence in the general
population of 1 per million the observed rate in this sub-population
is 10 TIMES, and taking an annual incidence of 0.7 per million,
IT IS 15 TIMES (THE ''WORST CASE'' SCENARIO) than
that in the general population...
http://www.bseinquiry.gov.uk/files/yb/1995/01/31004001.pdf
CJD YOUNG PEOPLE
in the USA, a 16 year old in 1978;
ALSO IN USA;
(20 year old died from sCJD in USA in 1980 and a 16 year
old in 1981. see second url below)
in France, a 19 year old in 1982;
in Canada, a 14 year old of UK origin in 1988;
in Poland, cases in people aged 19, 23, and 27 were identified in
a retrospective study (published 1991), having been originally
misdiagnosed with a viral encephalitis;
Creutzfeldt's first patient in 1923 was aged 23.
http://www.bseinquiry.gov.uk/files/yb/1995/10/27013001.pdf
20 year old died from sCJD in USA in 1980 and a 16 year
old in 1981. A 19 year old died from sCJD in
France in 1985. There is no evidence of an iatrogenic
cause for those cases....
http://www.bseinquiry.gov.uk/files/yb/1995/10/04004001.pdf
FOR SEAC TO continue to flounder with this ukbsenvcjd only theory, when we
know that sporadic CJD's were proven long ago to transmit via the medical
and surgical arena, will only continue to spread this agent around the globe
via a multitude of proven routes and sources.
IN my opinion, for SEAC to continue to go down this same road, year after
year, and continue to ignore sporadic CJD's, and continue to say that "BSE
in the UK sheep population is most likely to be zero, or very low if present
at all." "Consequently, any impact of the schemes on human health from
removing BSE from sheep is likely to be negligible." when in fact they do
not know. and in fact science is showing that in "transgenic mice BSE
passaged in sheep may be more virulent and infectious to a wider range of
species than bovine derived BSE." IN my opinion this continued neglect of
other TSEs in human and animals, the continued belief in this ukbsenvcjd
only theory, and the risk thereof, is reckless, dangerous, and in my mind,
criminal. SEAC has failed the public terribly in this regard. ...TSS
----- Original Message -----
From: "Terry S. Singeltary Sr."
To:
Sent: Friday, February 02, 2007 10:43 AM
Subject: SEAC ANNUAL REPORT 2006
Date: February 2, 2007 at 8:25 am PST
SEAC ANNUAL REPORT 2006 (ignoring the obvious)
http://www.seac.gov.uk/publicats/annualreport2006.pdf
SOME HISTORY ON THE USA CJD QUESTIONNAIRE
http://www.ask.com/web?q=cjd+questionnaire+tss&qsrc=1&o=0&l=dir
http://www.google.com/search?num=30&hl=en&lr=&as_qdr=d&edition=us&q=cjd+questionnaire+TSS&btnG=Search
One reason for this was the _inaccuracy_ in coding of cases correctly
certified as CJD Coding is carried out by staff who are not medically
qualified and it is not surprising that coding errors occur in the
processing of large numbers of certificates. In 1982, 12,000
certificates per week were processed at the office of population
censuses and surveys bu 15 coders and 6 checkers (Alderson et al., 1983).
The occurrence of both inter- and intra-observer coding errors has been
described (Curb et al., 1983) and the _inaccuracies_ of BOTH
certification and coding discovered in this study _support_ the
introduction of a more accurate system of death certificates and
a more detailed and specific coding system...
snip...
http://www.bseinquiry.gov.uk/files/mb/m26/tab01.pdf
''Answering critics like Terry Singeltary, who feels that the US
undercounts CJD, Schonberger _conceded_ that the current surveillance
system has errors but stated that most of the errors will be confined to
the older population''...
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SAD THAT OLDER FOLKS SEEM TO BE EXPENDABLE IN RELATIONS TO TSEs.
IF YOUR NOT YOUNG, IF IT's NOT THE UKBSENVCJD ONLY STRAIN, YOUR OUTA LUCK.
YOUR SPORADIC, YOUR SPONTANEOUS, in short, your expendable. ...
> Number of BSE cases in the EU-25 down again by more than 40 percent in 2006.
> This decreasing trend now seems to occur throughout the EU-25
http://www.fas.usda.gov/gainfiles/200703/146280315.pdf
SEEMS the drastic reduction in BSE cases in the EU due to feed ban would dispute the spontaneous event for BSE, so what do they try and do, convince everyone there is a new strain that happens spontaneously, what a hoot. why not a new strain via the same damn route and source i.e. tainted feed just different strain of agent in feed, or maybe vertical and or horizontal route and or source. but to just throw our hands up in the air and say "OH, it just happens on it's on due to some whaco event of a spontanoeus good protein misfolding into a bad one'' and then replicating themselves into more bad apples, just because we find a new strain of mad cow in the bovine that IS related to sporadic CJDs, flies in the face of past science. it does not compute. and if you go back to those mad cow farmers and one wife, with BSE that died from sporadic CJD, now that does compute.
lets do some pondering here, lets say just for BSe, lets just say this BASE is spontaneous, would this not be the final gold straw in prusiners pie. would every country out there then be subject to 100% testing if say this spontaneous theory was proven, and shoot his cdi testing up big time, and others $$$ holy mad cow, just think about it, over 20+ strains of scrapie, atypical scrapies, BSE in sheep and goat, holy smokes, then you have the multiple strains of CWD they have just about finally confirmed of deer and elk, but how many strains there, alot of testing would have to be done if ever proven to be a spontaneous event. but how can it be spontaneous in one and not the others $$$
i have ask prusiner this very thing, with no answer. how many of the 85%+ of all human TSE i.e. sporadic CJD, how many do you believe to be a spontaneous event, from no route and source, knowing that we have to date 6 different phenotypes of sporadic CJD ??? what, 2%, 10%, 25%, 50%, 75%, or all of the sporadic CJDs spontaneous ??? no explanation yet from him, but i'm still waiting. ...
see Prusiner ;
http://www.agobservatory.org/library.cfm?refID=30405
see singeltary question to prusiner ;
Greetings,as a lay person;-) i am thankful for Dr. Prusiners report below. I only wish that he would elaborate on the spontaneous aspect of sporadic CJD and how many of the 85%+ of all CJDs does he think happens spontaneously without route and source of the agent? I am concerned that people who read this, will come to the conclusion that all sporadic CJDs are a spontaneousmutation, when in reality all sporadic CJD is, is CJD from unknown route and source and they could be many. in fact, there could be many phenotypes of CJD that are now called sporadic CJD...
http://www.agobservatory.org/library.cfm?refID=30406
THE USDA JUNE 2004 ENHANCED BSE SURVEILLANCE PROGRAM WAS TERRIBLY FLAWED ;
CDC DR. PAUL BROWN TSE EXPERT COMMENTS 2006
The U.S. Department of Agriculture was quick to assure the public earlier
this week that the third case of mad cow disease did not pose a risk to
them, but what federal officials have not acknowledged is that this latest
case indicates the deadly disease has been circulating in U.S. herds for at
least a decade.
The second case, which was detected last year in a Texas cow and which USDA
officials were reluctant to verify, was approximately 12 years old.
These two cases (the latest was detected in an Alabama cow) present a
picture of the disease having been here for 10 years or so, since it is
thought that cows usually contract the disease from contaminated feed they
consume as calves. The concern is that humans can contract a fatal,
incurable, brain-wasting illness from consuming beef products contaminated
with the mad cow pathogen.
"The fact the Texas cow showed up fairly clearly implied the existence of
other undetected cases," Dr. Paul Brown, former medical director of the
National Institutes of Health's Laboratory for Central Nervous System
Studies and an expert on mad cow-like diseases, told United Press
International. "The question was, 'How many?' and we still can't answer
that."
Brown, who is preparing a scientific paper based on the latest two mad cow
cases to estimate the maximum number of infected cows that occurred in the
United States, said he has "absolutely no confidence in USDA tests before
one year ago" because of the agency's reluctance to retest the Texas cow
that initially tested positive.
USDA officials finally retested the cow and confirmed it was infected seven
months later, but only at the insistence of the agency's inspector general.
"Everything they did on the Texas cow makes everything USDA did before 2005
suspect," Brown said. ...snip...end
http://www.upi.com/ConsumerHealthDaily/view.php?StoryID=20060315-055557-1284r
CDC - Bovine Spongiform Encephalopathy and Variant Creutzfeldt ...
Dr. Paul Brown is Senior Research Scientist in the Laboratory of Central
Nervous System ... Address for correspondence: Paul Brown, Building 36, Room
4A-05, ...
http://www.cdc.gov/ncidod/eid/vol7no1/brown.htm
PAUL BROWN COMMENT TO ME ON THIS ISSUE
Tuesday, September 12, 2006 11:10 AM
"Actually, Terry, I have been critical of the USDA handling of the mad cow issue for some years,
and with Linda Detwiler and others sent lengthy detailed critiques and recommendations to both the
USDA and the Canadian Food Agency."
OR, what the Honorable Phyllis Fong of the OIG found ;
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
http://www.usda.gov/oig/webdocs/50601-10-KC.pdf
THE SEVEN SCIENTIST REPORT ***
http://www.fda.gov/ohrms/dockets/dockets/02n0273/02n-0273-EC244-Attach-1.pdf
Subject: [Docket No. FSIS-2006-0011] FSIS Harvard Risk Assessment of Bovine
Spongiform Encephalopathy (BSE)
http://www.fsis.usda.gov/OPPDE/Comments/2006-0011/2006-0011-1.pdf
[Docket No. 03-025IFA] FSIS Prohibition of the Use of Specified Risk
Materials for Human Food and Requirement for the Disposition of
Non-Ambulatory Disabled Cattle
9/13/2005
http://www.fsis.usda.gov/OPPDE/Comments/03-025IFA/03-025IFA-2.pdf
Docket No. 03-080-1 -- USDA ISSUES PROPOSED RULE TO ALLOW LIVE ANIMAL IMPORTS FROM CANADA 11/03/2003 01:19 PM
https://web01.aphis.usda.gov/BSEcom.nsf/0/b78ba677e2b0c12185256dd300649f9d?OpenDocument&AutoFramed
Docket No, 04-047-l Regulatory Identification No. (RIN) 091O-AF46 NEW BSE SAFEGUARDS 07/11/2004 09:34 PM
https://web01.aphis.usda.gov/regpublic.nsf/168556f5aa7a82ba85256ed00044eb1f/eff9eff1f7c5cf2b87256ecf000df08d?OpenDocument
Importation of Whole Cuts of Boneless Beef From Japan
[Docket No. 05-004-2] RIN 0579-AB93
snip...
Peripheral Nerves
Issue: Two commenters stated that the underlying assumption of the
proposed rule, that whole cuts of boneless beef from Japan will not
contain tissues that may carry the BSE agent, is no longer valid
because researchers have found peripheral nervous system tissues,
including facial and sciatic nerves, that contain BSE infectivity.\2\
One of these commenters requested APHIS to explain whether and what
additional mitigation measures are needed to reduce the risks that
these tissues may be present in Japanese beef. This commenter further
requested an additional comment period to obtain public comment
regarding the manner by which APHIS intends to treat this new
scientific finding.
---------------------------------------------------------------------------
\2\ Bushmann, A., and Gruschup, M.; Highly Bovine Spongiform
Encephalopathy-Sensitive Transgenic Mice Confirm the Essential
Restriction of Infectivity to the Nervous System in Clinically
Diseased Cattle. The Journal of Infectious Diseases, 192: 934-42,
September 1, 2005.
---------------------------------------------------------------------------
Response: APHIS is familiar with the results of the study mentioned
by the commenters in which mice, genetically engineered to be highly
susceptible to BSE and to overexpress the bovine prion protein, were
inoculated with tissues from a BSE-infected cow. This study
demonstrated low levels of infectivity in the mouse assay in the facial
and sciatic nerves of the peripheral nervous system. APHIS has
evaluated these findings in the context of the potential occurrence of
infectivity in the peripheral nerves of cattle and the corresponding
risks of the presence of infectivity in such tissues resulting in
cattle or human exposure to the BSE agent. The results from these
experiments in genetically engineered mice should be interpreted with
caution, as the findings may be influenced by the overexpression of
prion proteins and may not accurately predict the natural distribution
of BSE infectivity in cattle. Further, the overexpression of prion
proteins in transgenic mice may not accurately mimic the natural
disease process because the transgenic overexpressing mice have been
shown to develop spontaneous lethal neurological disease involving
spongiform changes in the brain and muscle degeneration.\3\ In
addition, the route of administration to the mice was both
intraperitoneal and intracerebral, which are two very efficient routes
of infection as compared to oral consumption. Given these factors,
APHIS has determined that the finding of BSE infectivity in facial and
sciatic nerves of the transgenic mice is not directly applicable to
cattle naturally infected with BSE. Therefore, we do not consider it
necessary to make any adjustments to the risk analysis for this
rulemaking or to extend the comment period to solicit additional public
comment on this issue.
---------------------------------------------------------------------------
\3\ Westaway, D., et al.; (1994) Degeneration of Skeletal
Muscle, Peripheral Nerves, and the Central Nervous System in
Transgenic Mice Overexpressing Wild-type Prion Proteins. Cell 76, 117-129.
---------------------------------------------------------------------------
Blood
Issue: Two commenters expressed concern that there has been a
limited amount of research conducted on BSE infectivity in blood. One
of these commenters cited a report that discussed, among other things,
the detection of infectivity in sheep experimentally infected with BSE
via blood transfusions.\4\ This commenter also stated that the agent
that causes Creutzfeldt-Jakob disease (CJD), a chronic and fatal
neurodegenerative disease of humans, was detected in blood, and
questioned whether the BSE agent could be detected in blood as well.
The other commenter cited a study that detected infectivity in hamsters
experimentally infected with scrapie.\5\ This commenter requested that
APHIS ban the use of blood in cattle feed.
---------------------------------------------------------------------------
\4\ Pattison, J., et al.; UK Strategy for Research and
Development on Human and Animal Health Aspects of Transmissible
Spongiform Encephalopathies, 2005-2008. Available at
http://www.mrc.ac.uk/pdf-about-tse_uk_strategy_june2005.pdf.
\5\ Castilla, J., et al.; Detection of Prions in Blood. Nature
Medicine, doi: 10.1038/nm1286, August 28, 2005, at 3.
---------------------------------------------------------------------------
Response: As stated in our risk analysis, the pathogenesis studies
of naturally and experimentally infected cattle have not detected BSE
infectivity in blood.
The first study mentioned by the commenter above demonstrated
transmission of disease from sheep experimentally infected with BSE to
another sheep via blood transfusions. We note that there are widely
acknowledged differences between the distribution of BSE infectivity in
the tissues of cattle and sheep. In addition, there is a significant
difference in susceptibility to infection based on the route of
transmission. Infection via oral consumption may be 10,000 times less
efficient than infection via intravenous injection, such as a blood
transfusion.
Both the United Kingdom's Department for Environment, Food and
Rural Affairs' Spongiform Encephalopathy Advisory Committee (SEAC) and
the European Commission's Scientific Steering Committee (SSC), which
are scientific advisory committees, evaluated the findings of
transmission of infectivity via blood transfusions in sheep
experimentally infected with BSE and concluded that
[[Page 73907]]
these findings did not indicate that additional mitigation measures
were necessary to protect public health.\6\ Therefore, based on
currently available information, APHIS considers it unlikely that the
experimental observations in sheep reflect a biologically significant
event for cattle or affect the safety of whole cuts of boneless beef
derived from cattle born, raised, and slaughtered in Japan.
---------------------------------------------------------------------------
\6\ Spongiform Encephalopathy Advisory Committee, Oct. 19, 2000,
Summary of SEAC Committee Meeting 29 September 2000. Available at
http://www.defra.gov.uk/news/seac/seac500.htm.
European Commission Scientific Steering Committee; The
Implications of the Recent Papers on Transmission of BSE by Blood
Transfusion in Sheep (Houston et al., 2000; Hunter et al., 2002),
Adopted by the SSC at its Meeting of 12-13 September. Available at
http://europa.eu.int/comm/food/fs/sc/ssc/out280_en.pdf.
---------------------------------------------------------------------------
The study on scrapie-infected hamsters noted by the commenter
describes a process by which the abnormal prion protein can be
amplified and detected using current testing methods, such as a Western
blot. In this study, blood from hamsters experimentally infected with a
scrapie strain was collected when the animals demonstrated clinical
signs of disease. These blood samples were incubated with excess normal
prion protein from brain tissue for multiple cycles. If abnormal
protein is present in blood, it will convert the normal brain prion to
abnormal prion, yielding an increased amount of abnormal prion that can
be more easily detected. In this manner, the presence of abnormal prion
protein in the initial blood samples, which was present in levels too
low to detect using routine test methods, was demonstrated. While this
finding has many possibilities related to the development of diagnostic
tests, it does not demonstrate BSE infectivity in blood. We also note
that the international community largely considers that studies using
transmissible spongiform encephalopathies (TSEs) other than BSE in non-
bovine animals cannot be directly extrapolated to BSE in cattle because
of the significant interactions between the host species and the prion
strain involved.
Feed regulations in the United States are under the authority of
the Food and Drug Administration (FDA), not APHIS. Therefore, the
commenter's request that APHIS ban the use of blood in cattle feed
falls outside the scope of this rulemaking. For these reasons, we are
not making any changes to the rule based on these comments.
snip...
Issue: Two commenters raised questions regarding the origin of CJD
in humans. One commenter noted that there are different strains of TSEs
being discovered in ruminants, and that new atypical strains of TSE in
cattle look similar to sporadic CJD in humans. Another commenter asked
if APHIS has considered whether sporadic CJD in humans might be caused
by atypical cases of TSEs that have been found in animals. This
commenter further questioned whether blood and other tissues may carry
BSE infectivity in cattle infected with atypical strains of the BSE
agent or other TSE agents.
Response: Sporadic CJD is the most common form of CJD. It has been
found in every country in the world where it has been looked for
including countries that are generally considered by the international
scientific community to be free of BSE and other TSEs (for example,
Australia and New Zealand). In general, it affects about one person per
million. No association between sporadic CJD and consumption of animal
products in general and/or infected or contaminated bovine products has
ever been documented. It is currently believed that sporadic CJD arises
through the spontaneous conversion of PrPC (normal cellular
prion protein) to PrPSC in an individual.\13\ In contrast,
atypical cases of BSE in cattle are rare and have been reported in only
few countries that experience BSE, such as Italy, Belgium, Japan, and
France. It has been speculated that the spontaneous or sporadic form of
BSE could exist in cattle, as well as humans.\14\
---------------------------------------------------------------------------
\13\ Stahl, N. and Prusiner, S.B.; (1991) FASEB-J. 5: 2799-807.
\14\ Biacabe; 2004 EMBO reports, Vol. 5, No. 1.
---------------------------------------------------------------------------
[[Page 73916]]
APHIS agrees with the commenter that reports indicate that some of
the atypical BSE cases, in particular the bovine amyloidotic spongiform
encephalopathy (BASE), and sporadic CJD have similar PrPSC
patterns. APHIS evaluated the findings in the context of risk of
exposure to cattle and humans. Currently, the relevance of the atypical
cases is unknown, but at this time there is no indication that any
control measures--such as feed bans or SRM requirements--should be
modified based on these cases. Additionally, although atypical cases of
BSE and sporadic CJD share similarities at this point, there is no
evidence that they are linked.
Issue: One commenter expressed concern over the number of citations
issued for various SRM violations during the June 2004 enhanced BSE
surveillance program in the United States. This commenter questioned
whether these incidents of noncompliance may have led to infective
materials entering the human or animal food chains. This commenter
cited the case of BSE detected in a 12-year-old cow in Texas as
evidence that infective materials may have entered the food chain. The
commenter suggested that noncompliance reports should be made more
easily available to the public in the future.
Response: FSIS inspectors are responsible for verifying the
effectiveness of an establishment's procedures. If FSIS personnel
determine that an establishment's procedures are ineffective in
preventing cross-contamination, the inspectors will take appropriate
action. We note that none of the meat from the 12-year-old BSE-infected
cow in Texas mentioned by the commenter entered the human food or
animal feed chains.
snip...full text ;
http://www.epa.gov/fedrgstr/EPA-IMPACT/2005/December/Day-14/i24057.htm
Importation of Whole Cuts of Boneless Beef from Japan [Docket No. 05-004-1] RIN 0579-AB93 TSS SUBMISSION
http://docket.epa.gov/edkfed/do/EDKStaffItemDetailView?objectId=090007d480993808
http://docket.epa.gov/edkfed/do/EDKStaffAttachDownloadPDF?objectId=090007d480993808
http://docket.epa.gov/edkfed/do/EDKStaffCollectionDetailView?objectId=0b0007d48096b40d
Docket No. 05-004-1 RIN 0579-AB93 BSE TSS was Received
I would kindly like to comment on [Docket No. 05-004-1] RIN 0579-AB93 ;
PROPOSED RULES
Exportation and importation of animals and animal products:
Whole cuts of boneless beef from-
Japan,
48494-48500 [05-16422]
[Federal Register: August 18, 2005 (Volume 70, Number 159)]
[Proposed Rules]
[Page 48494-48500]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr18au05-7]
========================================================================
Proposed Rules
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.
========================================================================
[[Page 48494]]
DEPARTMENT OF AGRICULTURE
Animal and Plant Health Inspection Service
9 CFR Part 94
[Docket No. 05-004-1]
RIN 0579-AB93
Importation of Whole Cuts of Boneless Beef from Japan
AGENCY: Animal and Plant Health Inspection Service, USDA.
ACTION: Proposed rule.
-----------------------------------------------------------------------
SUMMARY: We are proposing to amend the regulations governing the
importation of meat and other edible animal products by allowing, under
certain conditions, the importation of whole cuts of boneless beef from
Japan. We are proposing this action in response to a request from the
Government of Japan and after conducting an analysis of the risk that
indicates that such beef can be safely imported from Japan under the
conditions described in this proposal.
DATES: We will consider all comments that we receive on or before
September 19, 2005.
ADDRESSES: You may submit comments by any of the following methods:
EDOCKET: Go to http://www.epa.gov/feddocket to submit or
snip...
BSE infectivity has never been demonstrated in the muscle tissue of
cattle experimentally or naturally infected with BSE at any stage of
the disease. Studies performed using TSEs other than BSE in non-bovine
animals have detected prions in muscle tissue. However, the
international scientific community largely considers that these studies
cannot be directly extrapolated to BSE in cattle because of the
significant interactions between the host species and the prion strain
involved.
Pathogenesis studies of naturally and experimentally infected
cattle have not detected BSE infectivity in blood. However,
transmission of BSE was demonstrated in sheep that received a
transfusion of a large volume of blood drawn from other sheep that were
experimentally infected with the BSE agent. The United Kingdom's
Department for Environment, Food and Rural Affairs' Spongiform
Encephalopathy Advisory Committee (SEAC) and the European Commission's
Scientific Steering Committee (SSC), which are scientific advisory
committees, evaluated the implication of this finding in relation to
food safety.\5\ The SEAC concluded that the finding did not represent
grounds for recommending any changes to the current control measures
for BSE. The SSC determined that the research results do not support
the hypothesis that bovine blood or muscle meat constitute a risk to
human health.\6\
snip...
BSE Risk Factors for Whole Cuts of Boneless Beef
The most significant risk management strategy for ensuring the
safety of whole cuts of boneless beef is the prevention of cross-
contamination of the beef with SRMs during stunning and slaughter of
the animal. Control measures that prevent contamination of such beef
involve the establishment of procedures for the removal of SRMs,
prohibitions on air-injection stunning and pithing, and splitting of
carcasses. These potential pathways for contamination and the control
measures that prevent contamination are described in detail in the risk
analysis for this rulemaking.
SRM Removal. Research has demonstrated that SRMs from infected
cattle may contain BSE infectivity. Because infectivity has not been
demonstrated in muscle tissue, the most important mitigation measure
for whole cuts of boneless beef is the careful removal and segregation
of SRMs. Removal of SRMs in a manner that avoids contamination of the
beef with SRMs minimizes the risk of exposure to materials that have
been demonstrated to contain the BSE agent in cattle.
snip...
Variant Creutzfeldt-Jakob disease (vCJD), a chronic and fatal
neurodegenerative disease of humans, has been linked since 1996 through
epidemiological, neuropathological, and experimental data to exposure
to the BSE agent, most likely through consumption of cattle products
contaminated with the agent before BSE control measures were in place.
To date, approximately 170 probable and confirmed cases of vCJD have
been identified worldwide. The majority of these cases have either been
identified in the United Kingdom or were linked to exposure that
occurred in the United Kingdom, and all cases have been linked to
exposure in countries with native cases of BSE. Some studies estimate
that more than 1 million cattle may have been infected with BSE
throughout the epidemic in the United Kingdom. This number of infected
cattle could have introduced a significant amount of infectivity into
the human food supply. Yet, the low number of cases of vCJD identified
to date indicates that there is a substantial species barrier that
protects humans from widespread illness due to exposure to the BSE
agent.
snip...
International Guidelines on BSE
International guidelines for trade in animal and animal products
are developed by the World Organization for Animal Health (formerly
known as the Office International des Epizooties (OIE)), which is
recognized by the World Trade Organization (WTO) as the international
organization responsible for the development of standards, guidelines,
and recommendations with respect to animal health and zoonoses
(diseases that are transmissible from animals to humans). The OIE
guidelines for trade in terrestrial animals (mammals, birds, and bees)
are detailed in the Terrestrial Animal Health Code (available on the
internet at http://www.oie.int). The guidelines on BSE are contained in
Chapter 2.3.13 of the Code and supplemented by Appendix 3.8.4 of the
Code.
snip...end
http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/2005/05-16422.htm
http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/2005/pdf/05-16422.pdf
Greetings again APHIS ET AL,
THIS is not correct. IN fact, there are several factors i would like to kindly address. .......
SNIP...
WE MUST ADHERE TO THE BSE GBR RISK ASSESSMENTS, WE MUST WORK TO ENHANCE THOSE BSE GBR RISK ASSESSMENTS TO INCLUDE ALL ANIMAL TSEs, USDA/APHIS/GW ET ALs BSE MRR (Minimal Risk Region) should be REPEALED/DISBANDED/TRASHED/NADA and done away with for good. The BSE MRR policy is nothing more than a legal tool to trade all strains of TSEs globally...
Terry S. Singeltary Sr.
P.O. Box 42
Bacliff, Texas USA 77518
Your Comment with Title "[Docket No. 05-004-1] RIN 0579-AB93 BSE TSS " was Received.
The Identifier Assigned is "APHIS-2005-0073-0009".
An Electronic File was Attached to this Submission.
Please note that it may take between 24 and 72 hours for the EDOCKET staff to process your comment before it is available publicly through EDOCKET. You can use the identifier noted above to find your comment through the Quick or Advanced Search pages when it is available. ...........
http://www.aphis.usda.gov/lpa/news/2005/08/japanbeef_vs.html
EPA: Federal Register: Importation of Whole Cuts of Boneless Beef ...Importation of Whole Cuts of Boneless Beef From Japan , Federal Register document. ... we published in the Federal Register (70 FR 48494-48500, Docket No. ...
http://www.epa.gov/fedrgstr/EPA-IMPACT/2005/December/Day-14/i24057.htm
Importation of Whole Cuts of Boneless Beef from Japan [Docket No. 05-004-1] RIN 0579-AB93 TSS SUBMISSION
next 3 urls now dead ;
http://docket.epa.gov/edkfed/do/EDKStaffItemDetailView?objectId=090007d480993808
http://docket.epa.gov/edkfed/do/EDKStaffAttachDownloadPDF?objectId=090007d480993808
http://docket.epa.gov/edkfed/do/EDKStaffCollectionDetailView?objectId=0b0007d48096b40d
"[Docket No. 05-004-1] RIN 0579-AB93 BSE TSS " was Received
BSE; MRR; IMPORTATION OF LIVE BOVINES AND PRODUCTS DERIVED FROM BOVINES [Docket No. APHIS-2006-0041] RIN 0579-AC01
APHIS-2006-0041-0006 Comment from Terry S Singletary Sr 01/09/2007 PUBLIC SUBMISSIONS
http://www.regulations.gov/fdmspublic/ContentViewer?objectId=09000064801f3412&disposition=attachment&contentType=crtext
APHIS-2006-0041-0006.1 Attachment to Singletary comment 01/09/2007 PUBLIC SUBMISSIONS
http://www.regulations.gov/fdmspublic/ContentViewer?objectId=09000064801f3413&disposition=attachment&contentType=msw8
TSS
Date: March 9, 2007 at 11:03 am PST
UK's first case of H-type BSE confirmed by DEFRA
09/03/2007 16:28:00
FWi
DEFRA has reported the UK’s first case of H-type Bovine Spongiform Encephalopathy. During routine research carried out by the Veterinary Laboratories Agency, test results revealed a single case of H-type BSE in 2005.
News of this form of BSE, which produces no clinical signs and has only been found in older animals, was announced at a VLA symposium on prion diseases of domestic livestock in June 2006.
To date 18 cases of the H-type strain have been identified in 12 countries worldwide including several other European countries, Japan, Canada and the United States of America.
According to statement from DEFRA the cow died on a farm in Dumfries and Galloway at 13 years of age. The carcass was then sampled and tested for BSE in accordance with EU requirements for testing all fallen stock aged over 24 months.
Test results confirmed the presence of BSE. The carcass was incinerated and the offspring from this cow were culled in line with current BSE regulations.
In August 2006 the VLA began a retrospective examination of brain samples taken from previous BSE cases as part of a research programme designed to analyse different types of BSE in the national herd.
It was this exercise that identified the presence of a H-type case. All forms of BSE are treated identically therefore no additional action would have been required in this case.
The Spongiform Encephalopathy Advisory Committee will examine all the available data on this case during a discussion of different forms of BSE worldwide at their next meeting on 10 May 2007.
by Andrew Watts (About this Author)
http://www.fwi.co.uk/Articles/2007/03/09/102241/uks-first-case-of-h-type-bse-confirmed-by-defra.html
U.K. TSE RESEARCH 2005-2008
http://www.defra.gov.uk/animalh/Bse/pdf/tse-strategy0606.pdf
BSE cases in older cattle which resemble the two different atypical. BSE phenotypes that have recently been described in France. (designated H-type) and ...
http://www.seac.gov.uk/papers/96-2.pdf
----- Original Message -----
From: XXXXXXXX XXXXXXXXXXXX(SEAC)
To: '[email protected]'
Sent: Friday, February 23, 2007 8:13 AM
Subject: RE: SEAC ANNUAL REPORT 2006
Dear Mr Singeltary
Thank you for your email about a possible relationship between BASE and
sCJD.
SEAC is continually informed about and considers the emerging science on
both animal and human TSEs. The committee regularly receives updates from
the UK's National CJD Surveillance Centre Unit on the epidemiology of vCJD
and sCJD and is also aware of emerging research on BASE. It is envisaged
that SEAC will conduct a detailed consideration of the available science and
the possible animal and human health implications of BASE at its meeting on
10th May 2007.
Yours sincerely
XXXXXXXXXXXXXX
----------------------------------------------------------------------------
----
From: Terry S. Singeltary Sr. [mailto:[email protected]]
Sent: 02 February 2007 16:44
To: Bovine Spongiform Encephalopathy
Cc: SEACsecretariat (AHEG); [email protected];
[email protected]; [email protected]; Sustainable Agriculture
Network Discussion Group
Subject: SEAC ANNUAL REPORT 2006
Date: February 2, 2007 at 8:25 am PST
SEAC ANNUAL REPORT 2006 (ignoring the obvious)
http://www.seac.gov.uk/publicats/annualreport2006.pdf
i guess the sporadic CJD cases have all be resolved, and the route and cause
classified.
to this day, i cannot figure this out. if BSE farmers died from sporadic
CJD, and now another study seems to point
that BSE and BASE may be the same thing, and that BASE does not produce vCJD
like pathology, but pathology resembling that of sporadic CJD, then why does
SEAC still seem to put sporadic CJD on the back burners ??? IN fact, SEAC
could not even speak about it in there 2006 report. would it not seem
prudent to mention these findings in this 2006 SEAC report ;
Other work presented suggested that BSE and bovine amyloidotic spongiform
encephalopathy (BASE) MAY BE RELATED. A mutation had been identified in the
prion protein gene in an AMERICAN BASE CASE THAT WAS SIMILAR IN NATURE TO A
MUTATION FOUND IN CASES OF SPORADIC CJD.
snip...
http://www.seac.gov.uk/minutes/95.pdf
***These results indicate that BASE is transmissible to humans and suggest
that BASE is more virulent than
classical BSE in humans.***
6:30 Close of Day One
http://www.healthtech.com/2007/tse/day1.asp
64. A member noted that at the recent Neuroprion meeting, a study was
presented showing that in transgenic mice BSE passaged in sheep may be more
virulent and infectious to a wider range of species than bovine derived BSE.
http://www.seac.gov.uk/minutes/95.pdf
Asante/Collinge et al, that BSE transmission to the 129-methionine
genotype can lead to an alternate phenotype that is indistinguishable
from type 2 PrPSc, the commonest _sporadic_ CJD;
http://www.fda.gov/ohrms/dockets/ac/03/slides/3923s1_OPH.htm
I STILL think to ignore these findings below is not only rediculous, but
indeed very suspicious ;
CJD FARMERS WIFE 1989
http://www.bseinquiry.gov.uk/files/yb/1989/10/13007001.pdf
http://www.bseinquiry.gov.uk/files/yb/1989/10/13003001.pdf
cover-up of 4th farm worker ???
http://www.bseinquiry.gov.uk/files/yb/1995/10/23006001.pdf
http://www.bseinquiry.gov.uk/files/yb/1995/10/20006001.pdf
CONFIRMATION OF CJD IN FOURTH FARMER
http://www.bseinquiry.gov.uk/files/yb/1995/11/03008001.pdf
now story changes from;
SEAC concluded that, if the fourth case were confirmed, it would be
worrying, especially as all four farmers with CJD would have had BSE
cases on their farms.
to;
This is not unexpected...
was another farmer expected?
http://www.bseinquiry.gov.uk/files/yb/1995/11/13010001.pdf
4th farmer, and 1st teenager
http://www.bseinquiry.gov.uk/files/yb/1996/02/27003001.pdf
2. snip...
Over a 5 year period, which is the time period on which the advice
from Professor Smith and Dr. Gore was based, and assuming a
population of 120,000 dairy farm workers, and an annual incidence
of 1 per million cases of CJD in the general population, a
DAIRY FARM WORKER IS 5 TIMES MORE LIKELY THAN
an individual in the general population to develop CJD. Using the
actual current annual incidence of CJD in the UK of 0.7 per
million, this figure becomes 7.5 TIMES.
3. You will recall that the advice provided by Professor Smith in
1993 and by Dr. Gore this month used the sub-population of dairy
farm workers who had had a case of BSE on their farms -
63,000, which is approximately half the number of dairy farm
workers - as a denominator. If the above sums are repeated using
this denominator population, taking an annual incidence in the general
population of 1 per million the observed rate in this sub-population
is 10 TIMES, and taking an annual incidence of 0.7 per million,
IT IS 15 TIMES (THE ''WORST CASE'' SCENARIO) than
that in the general population...
http://www.bseinquiry.gov.uk/files/yb/1995/01/31004001.pdf
CJD YOUNG PEOPLE
in the USA, a 16 year old in 1978;
ALSO IN USA;
(20 year old died from sCJD in USA in 1980 and a 16 year
old in 1981. see second url below)
in France, a 19 year old in 1982;
in Canada, a 14 year old of UK origin in 1988;
in Poland, cases in people aged 19, 23, and 27 were identified in
a retrospective study (published 1991), having been originally
misdiagnosed with a viral encephalitis;
Creutzfeldt's first patient in 1923 was aged 23.
http://www.bseinquiry.gov.uk/files/yb/1995/10/27013001.pdf
20 year old died from sCJD in USA in 1980 and a 16 year
old in 1981. A 19 year old died from sCJD in
France in 1985. There is no evidence of an iatrogenic
cause for those cases....
http://www.bseinquiry.gov.uk/files/yb/1995/10/04004001.pdf
FOR SEAC TO continue to flounder with this ukbsenvcjd only theory, when we
know that sporadic CJD's were proven long ago to transmit via the medical
and surgical arena, will only continue to spread this agent around the globe
via a multitude of proven routes and sources.
IN my opinion, for SEAC to continue to go down this same road, year after
year, and continue to ignore sporadic CJD's, and continue to say that "BSE
in the UK sheep population is most likely to be zero, or very low if present
at all." "Consequently, any impact of the schemes on human health from
removing BSE from sheep is likely to be negligible." when in fact they do
not know. and in fact science is showing that in "transgenic mice BSE
passaged in sheep may be more virulent and infectious to a wider range of
species than bovine derived BSE." IN my opinion this continued neglect of
other TSEs in human and animals, the continued belief in this ukbsenvcjd
only theory, and the risk thereof, is reckless, dangerous, and in my mind,
criminal. SEAC has failed the public terribly in this regard. ...TSS
----- Original Message -----
From: "Terry S. Singeltary Sr."
To:
Sent: Friday, February 02, 2007 10:43 AM
Subject: SEAC ANNUAL REPORT 2006
Date: February 2, 2007 at 8:25 am PST
SEAC ANNUAL REPORT 2006 (ignoring the obvious)
http://www.seac.gov.uk/publicats/annualreport2006.pdf
SOME HISTORY ON THE USA CJD QUESTIONNAIRE
http://www.ask.com/web?q=cjd+questionnaire+tss&qsrc=1&o=0&l=dir
http://www.google.com/search?num=30&hl=en&lr=&as_qdr=d&edition=us&q=cjd+questionnaire+TSS&btnG=Search
One reason for this was the _inaccuracy_ in coding of cases correctly
certified as CJD Coding is carried out by staff who are not medically
qualified and it is not surprising that coding errors occur in the
processing of large numbers of certificates. In 1982, 12,000
certificates per week were processed at the office of population
censuses and surveys bu 15 coders and 6 checkers (Alderson et al., 1983).
The occurrence of both inter- and intra-observer coding errors has been
described (Curb et al., 1983) and the _inaccuracies_ of BOTH
certification and coding discovered in this study _support_ the
introduction of a more accurate system of death certificates and
a more detailed and specific coding system...
snip...
http://www.bseinquiry.gov.uk/files/mb/m26/tab01.pdf
''Answering critics like Terry Singeltary, who feels that the US
undercounts CJD, Schonberger _conceded_ that the current surveillance
system has errors but stated that most of the errors will be confined to
the older population''...
The Pathological Protein: Mad Cow, Chronic Wasting, and Other Deadly
Prion Diseases by Philip Yam
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copies: Joan Robinson Springer-Verlag Press and Public Relations Tel.:
+49- (0) 6221-487-8130, Fax: +49- (0) 6221-487-8141, E-mail:
[email protected] http://www.springer.de/press/newbooks/protein.html
The Pathological Protein: Mad Cow, Chronic Wasting, and Other Deadly
Prion Diseases Philip Yam List Price: $27.50 Our Price: $19.25 You Save:
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http://www.target.com/gp/detail.html/sr=1-1/qid=1054420048/ref=sr_1_1/602-9780634-9614260?asin=0387955089
SAD THAT OLDER FOLKS SEEM TO BE EXPENDABLE IN RELATIONS TO TSEs.
IF YOUR NOT YOUNG, IF IT's NOT THE UKBSENVCJD ONLY STRAIN, YOUR OUTA LUCK.
YOUR SPORADIC, YOUR SPONTANEOUS, in short, your expendable. ...
> Number of BSE cases in the EU-25 down again by more than 40 percent in 2006.
> This decreasing trend now seems to occur throughout the EU-25
http://www.fas.usda.gov/gainfiles/200703/146280315.pdf
SEEMS the drastic reduction in BSE cases in the EU due to feed ban would dispute the spontaneous event for BSE, so what do they try and do, convince everyone there is a new strain that happens spontaneously, what a hoot. why not a new strain via the same damn route and source i.e. tainted feed just different strain of agent in feed, or maybe vertical and or horizontal route and or source. but to just throw our hands up in the air and say "OH, it just happens on it's on due to some whaco event of a spontanoeus good protein misfolding into a bad one'' and then replicating themselves into more bad apples, just because we find a new strain of mad cow in the bovine that IS related to sporadic CJDs, flies in the face of past science. it does not compute. and if you go back to those mad cow farmers and one wife, with BSE that died from sporadic CJD, now that does compute.
lets do some pondering here, lets say just for BSe, lets just say this BASE is spontaneous, would this not be the final gold straw in prusiners pie. would every country out there then be subject to 100% testing if say this spontaneous theory was proven, and shoot his cdi testing up big time, and others $$$ holy mad cow, just think about it, over 20+ strains of scrapie, atypical scrapies, BSE in sheep and goat, holy smokes, then you have the multiple strains of CWD they have just about finally confirmed of deer and elk, but how many strains there, alot of testing would have to be done if ever proven to be a spontaneous event. but how can it be spontaneous in one and not the others $$$
i have ask prusiner this very thing, with no answer. how many of the 85%+ of all human TSE i.e. sporadic CJD, how many do you believe to be a spontaneous event, from no route and source, knowing that we have to date 6 different phenotypes of sporadic CJD ??? what, 2%, 10%, 25%, 50%, 75%, or all of the sporadic CJDs spontaneous ??? no explanation yet from him, but i'm still waiting. ...
see Prusiner ;
http://www.agobservatory.org/library.cfm?refID=30405
see singeltary question to prusiner ;
Greetings,as a lay person;-) i am thankful for Dr. Prusiners report below. I only wish that he would elaborate on the spontaneous aspect of sporadic CJD and how many of the 85%+ of all CJDs does he think happens spontaneously without route and source of the agent? I am concerned that people who read this, will come to the conclusion that all sporadic CJDs are a spontaneousmutation, when in reality all sporadic CJD is, is CJD from unknown route and source and they could be many. in fact, there could be many phenotypes of CJD that are now called sporadic CJD...
http://www.agobservatory.org/library.cfm?refID=30406
THE USDA JUNE 2004 ENHANCED BSE SURVEILLANCE PROGRAM WAS TERRIBLY FLAWED ;
CDC DR. PAUL BROWN TSE EXPERT COMMENTS 2006
The U.S. Department of Agriculture was quick to assure the public earlier
this week that the third case of mad cow disease did not pose a risk to
them, but what federal officials have not acknowledged is that this latest
case indicates the deadly disease has been circulating in U.S. herds for at
least a decade.
The second case, which was detected last year in a Texas cow and which USDA
officials were reluctant to verify, was approximately 12 years old.
These two cases (the latest was detected in an Alabama cow) present a
picture of the disease having been here for 10 years or so, since it is
thought that cows usually contract the disease from contaminated feed they
consume as calves. The concern is that humans can contract a fatal,
incurable, brain-wasting illness from consuming beef products contaminated
with the mad cow pathogen.
"The fact the Texas cow showed up fairly clearly implied the existence of
other undetected cases," Dr. Paul Brown, former medical director of the
National Institutes of Health's Laboratory for Central Nervous System
Studies and an expert on mad cow-like diseases, told United Press
International. "The question was, 'How many?' and we still can't answer
that."
Brown, who is preparing a scientific paper based on the latest two mad cow
cases to estimate the maximum number of infected cows that occurred in the
United States, said he has "absolutely no confidence in USDA tests before
one year ago" because of the agency's reluctance to retest the Texas cow
that initially tested positive.
USDA officials finally retested the cow and confirmed it was infected seven
months later, but only at the insistence of the agency's inspector general.
"Everything they did on the Texas cow makes everything USDA did before 2005
suspect," Brown said. ...snip...end
http://www.upi.com/ConsumerHealthDaily/view.php?StoryID=20060315-055557-1284r
CDC - Bovine Spongiform Encephalopathy and Variant Creutzfeldt ...
Dr. Paul Brown is Senior Research Scientist in the Laboratory of Central
Nervous System ... Address for correspondence: Paul Brown, Building 36, Room
4A-05, ...
http://www.cdc.gov/ncidod/eid/vol7no1/brown.htm
PAUL BROWN COMMENT TO ME ON THIS ISSUE
Tuesday, September 12, 2006 11:10 AM
"Actually, Terry, I have been critical of the USDA handling of the mad cow issue for some years,
and with Linda Detwiler and others sent lengthy detailed critiques and recommendations to both the
USDA and the Canadian Food Agency."
OR, what the Honorable Phyllis Fong of the OIG found ;
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
http://www.usda.gov/oig/webdocs/50601-10-KC.pdf
THE SEVEN SCIENTIST REPORT ***
http://www.fda.gov/ohrms/dockets/dockets/02n0273/02n-0273-EC244-Attach-1.pdf
Subject: [Docket No. FSIS-2006-0011] FSIS Harvard Risk Assessment of Bovine
Spongiform Encephalopathy (BSE)
http://www.fsis.usda.gov/OPPDE/Comments/2006-0011/2006-0011-1.pdf
[Docket No. 03-025IFA] FSIS Prohibition of the Use of Specified Risk
Materials for Human Food and Requirement for the Disposition of
Non-Ambulatory Disabled Cattle
9/13/2005
http://www.fsis.usda.gov/OPPDE/Comments/03-025IFA/03-025IFA-2.pdf
Docket No. 03-080-1 -- USDA ISSUES PROPOSED RULE TO ALLOW LIVE ANIMAL IMPORTS FROM CANADA 11/03/2003 01:19 PM
https://web01.aphis.usda.gov/BSEcom.nsf/0/b78ba677e2b0c12185256dd300649f9d?OpenDocument&AutoFramed
Docket No, 04-047-l Regulatory Identification No. (RIN) 091O-AF46 NEW BSE SAFEGUARDS 07/11/2004 09:34 PM
https://web01.aphis.usda.gov/regpublic.nsf/168556f5aa7a82ba85256ed00044eb1f/eff9eff1f7c5cf2b87256ecf000df08d?OpenDocument
Importation of Whole Cuts of Boneless Beef From Japan
[Docket No. 05-004-2] RIN 0579-AB93
snip...
Peripheral Nerves
Issue: Two commenters stated that the underlying assumption of the
proposed rule, that whole cuts of boneless beef from Japan will not
contain tissues that may carry the BSE agent, is no longer valid
because researchers have found peripheral nervous system tissues,
including facial and sciatic nerves, that contain BSE infectivity.\2\
One of these commenters requested APHIS to explain whether and what
additional mitigation measures are needed to reduce the risks that
these tissues may be present in Japanese beef. This commenter further
requested an additional comment period to obtain public comment
regarding the manner by which APHIS intends to treat this new
scientific finding.
---------------------------------------------------------------------------
\2\ Bushmann, A., and Gruschup, M.; Highly Bovine Spongiform
Encephalopathy-Sensitive Transgenic Mice Confirm the Essential
Restriction of Infectivity to the Nervous System in Clinically
Diseased Cattle. The Journal of Infectious Diseases, 192: 934-42,
September 1, 2005.
---------------------------------------------------------------------------
Response: APHIS is familiar with the results of the study mentioned
by the commenters in which mice, genetically engineered to be highly
susceptible to BSE and to overexpress the bovine prion protein, were
inoculated with tissues from a BSE-infected cow. This study
demonstrated low levels of infectivity in the mouse assay in the facial
and sciatic nerves of the peripheral nervous system. APHIS has
evaluated these findings in the context of the potential occurrence of
infectivity in the peripheral nerves of cattle and the corresponding
risks of the presence of infectivity in such tissues resulting in
cattle or human exposure to the BSE agent. The results from these
experiments in genetically engineered mice should be interpreted with
caution, as the findings may be influenced by the overexpression of
prion proteins and may not accurately predict the natural distribution
of BSE infectivity in cattle. Further, the overexpression of prion
proteins in transgenic mice may not accurately mimic the natural
disease process because the transgenic overexpressing mice have been
shown to develop spontaneous lethal neurological disease involving
spongiform changes in the brain and muscle degeneration.\3\ In
addition, the route of administration to the mice was both
intraperitoneal and intracerebral, which are two very efficient routes
of infection as compared to oral consumption. Given these factors,
APHIS has determined that the finding of BSE infectivity in facial and
sciatic nerves of the transgenic mice is not directly applicable to
cattle naturally infected with BSE. Therefore, we do not consider it
necessary to make any adjustments to the risk analysis for this
rulemaking or to extend the comment period to solicit additional public
comment on this issue.
---------------------------------------------------------------------------
\3\ Westaway, D., et al.; (1994) Degeneration of Skeletal
Muscle, Peripheral Nerves, and the Central Nervous System in
Transgenic Mice Overexpressing Wild-type Prion Proteins. Cell 76, 117-129.
---------------------------------------------------------------------------
Blood
Issue: Two commenters expressed concern that there has been a
limited amount of research conducted on BSE infectivity in blood. One
of these commenters cited a report that discussed, among other things,
the detection of infectivity in sheep experimentally infected with BSE
via blood transfusions.\4\ This commenter also stated that the agent
that causes Creutzfeldt-Jakob disease (CJD), a chronic and fatal
neurodegenerative disease of humans, was detected in blood, and
questioned whether the BSE agent could be detected in blood as well.
The other commenter cited a study that detected infectivity in hamsters
experimentally infected with scrapie.\5\ This commenter requested that
APHIS ban the use of blood in cattle feed.
---------------------------------------------------------------------------
\4\ Pattison, J., et al.; UK Strategy for Research and
Development on Human and Animal Health Aspects of Transmissible
Spongiform Encephalopathies, 2005-2008. Available at
http://www.mrc.ac.uk/pdf-about-tse_uk_strategy_june2005.pdf.
\5\ Castilla, J., et al.; Detection of Prions in Blood. Nature
Medicine, doi: 10.1038/nm1286, August 28, 2005, at 3.
---------------------------------------------------------------------------
Response: As stated in our risk analysis, the pathogenesis studies
of naturally and experimentally infected cattle have not detected BSE
infectivity in blood.
The first study mentioned by the commenter above demonstrated
transmission of disease from sheep experimentally infected with BSE to
another sheep via blood transfusions. We note that there are widely
acknowledged differences between the distribution of BSE infectivity in
the tissues of cattle and sheep. In addition, there is a significant
difference in susceptibility to infection based on the route of
transmission. Infection via oral consumption may be 10,000 times less
efficient than infection via intravenous injection, such as a blood
transfusion.
Both the United Kingdom's Department for Environment, Food and
Rural Affairs' Spongiform Encephalopathy Advisory Committee (SEAC) and
the European Commission's Scientific Steering Committee (SSC), which
are scientific advisory committees, evaluated the findings of
transmission of infectivity via blood transfusions in sheep
experimentally infected with BSE and concluded that
[[Page 73907]]
these findings did not indicate that additional mitigation measures
were necessary to protect public health.\6\ Therefore, based on
currently available information, APHIS considers it unlikely that the
experimental observations in sheep reflect a biologically significant
event for cattle or affect the safety of whole cuts of boneless beef
derived from cattle born, raised, and slaughtered in Japan.
---------------------------------------------------------------------------
\6\ Spongiform Encephalopathy Advisory Committee, Oct. 19, 2000,
Summary of SEAC Committee Meeting 29 September 2000. Available at
http://www.defra.gov.uk/news/seac/seac500.htm.
European Commission Scientific Steering Committee; The
Implications of the Recent Papers on Transmission of BSE by Blood
Transfusion in Sheep (Houston et al., 2000; Hunter et al., 2002),
Adopted by the SSC at its Meeting of 12-13 September. Available at
http://europa.eu.int/comm/food/fs/sc/ssc/out280_en.pdf.
---------------------------------------------------------------------------
The study on scrapie-infected hamsters noted by the commenter
describes a process by which the abnormal prion protein can be
amplified and detected using current testing methods, such as a Western
blot. In this study, blood from hamsters experimentally infected with a
scrapie strain was collected when the animals demonstrated clinical
signs of disease. These blood samples were incubated with excess normal
prion protein from brain tissue for multiple cycles. If abnormal
protein is present in blood, it will convert the normal brain prion to
abnormal prion, yielding an increased amount of abnormal prion that can
be more easily detected. In this manner, the presence of abnormal prion
protein in the initial blood samples, which was present in levels too
low to detect using routine test methods, was demonstrated. While this
finding has many possibilities related to the development of diagnostic
tests, it does not demonstrate BSE infectivity in blood. We also note
that the international community largely considers that studies using
transmissible spongiform encephalopathies (TSEs) other than BSE in non-
bovine animals cannot be directly extrapolated to BSE in cattle because
of the significant interactions between the host species and the prion
strain involved.
Feed regulations in the United States are under the authority of
the Food and Drug Administration (FDA), not APHIS. Therefore, the
commenter's request that APHIS ban the use of blood in cattle feed
falls outside the scope of this rulemaking. For these reasons, we are
not making any changes to the rule based on these comments.
snip...
Issue: Two commenters raised questions regarding the origin of CJD
in humans. One commenter noted that there are different strains of TSEs
being discovered in ruminants, and that new atypical strains of TSE in
cattle look similar to sporadic CJD in humans. Another commenter asked
if APHIS has considered whether sporadic CJD in humans might be caused
by atypical cases of TSEs that have been found in animals. This
commenter further questioned whether blood and other tissues may carry
BSE infectivity in cattle infected with atypical strains of the BSE
agent or other TSE agents.
Response: Sporadic CJD is the most common form of CJD. It has been
found in every country in the world where it has been looked for
including countries that are generally considered by the international
scientific community to be free of BSE and other TSEs (for example,
Australia and New Zealand). In general, it affects about one person per
million. No association between sporadic CJD and consumption of animal
products in general and/or infected or contaminated bovine products has
ever been documented. It is currently believed that sporadic CJD arises
through the spontaneous conversion of PrPC (normal cellular
prion protein) to PrPSC in an individual.\13\ In contrast,
atypical cases of BSE in cattle are rare and have been reported in only
few countries that experience BSE, such as Italy, Belgium, Japan, and
France. It has been speculated that the spontaneous or sporadic form of
BSE could exist in cattle, as well as humans.\14\
---------------------------------------------------------------------------
\13\ Stahl, N. and Prusiner, S.B.; (1991) FASEB-J. 5: 2799-807.
\14\ Biacabe; 2004 EMBO reports, Vol. 5, No. 1.
---------------------------------------------------------------------------
[[Page 73916]]
APHIS agrees with the commenter that reports indicate that some of
the atypical BSE cases, in particular the bovine amyloidotic spongiform
encephalopathy (BASE), and sporadic CJD have similar PrPSC
patterns. APHIS evaluated the findings in the context of risk of
exposure to cattle and humans. Currently, the relevance of the atypical
cases is unknown, but at this time there is no indication that any
control measures--such as feed bans or SRM requirements--should be
modified based on these cases. Additionally, although atypical cases of
BSE and sporadic CJD share similarities at this point, there is no
evidence that they are linked.
Issue: One commenter expressed concern over the number of citations
issued for various SRM violations during the June 2004 enhanced BSE
surveillance program in the United States. This commenter questioned
whether these incidents of noncompliance may have led to infective
materials entering the human or animal food chains. This commenter
cited the case of BSE detected in a 12-year-old cow in Texas as
evidence that infective materials may have entered the food chain. The
commenter suggested that noncompliance reports should be made more
easily available to the public in the future.
Response: FSIS inspectors are responsible for verifying the
effectiveness of an establishment's procedures. If FSIS personnel
determine that an establishment's procedures are ineffective in
preventing cross-contamination, the inspectors will take appropriate
action. We note that none of the meat from the 12-year-old BSE-infected
cow in Texas mentioned by the commenter entered the human food or
animal feed chains.
snip...full text ;
http://www.epa.gov/fedrgstr/EPA-IMPACT/2005/December/Day-14/i24057.htm
Importation of Whole Cuts of Boneless Beef from Japan [Docket No. 05-004-1] RIN 0579-AB93 TSS SUBMISSION
http://docket.epa.gov/edkfed/do/EDKStaffItemDetailView?objectId=090007d480993808
http://docket.epa.gov/edkfed/do/EDKStaffAttachDownloadPDF?objectId=090007d480993808
http://docket.epa.gov/edkfed/do/EDKStaffCollectionDetailView?objectId=0b0007d48096b40d
Docket No. 05-004-1 RIN 0579-AB93 BSE TSS was Received
I would kindly like to comment on [Docket No. 05-004-1] RIN 0579-AB93 ;
PROPOSED RULES
Exportation and importation of animals and animal products:
Whole cuts of boneless beef from-
Japan,
48494-48500 [05-16422]
[Federal Register: August 18, 2005 (Volume 70, Number 159)]
[Proposed Rules]
[Page 48494-48500]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr18au05-7]
========================================================================
Proposed Rules
Federal Register
________________________________________________________________________
This section of the FEDERAL REGISTER contains notices to the public of
the proposed issuance of rules and regulations. The purpose of these
notices is to give interested persons an opportunity to participate in
the rule making prior to the adoption of the final rules.
========================================================================
[[Page 48494]]
DEPARTMENT OF AGRICULTURE
Animal and Plant Health Inspection Service
9 CFR Part 94
[Docket No. 05-004-1]
RIN 0579-AB93
Importation of Whole Cuts of Boneless Beef from Japan
AGENCY: Animal and Plant Health Inspection Service, USDA.
ACTION: Proposed rule.
-----------------------------------------------------------------------
SUMMARY: We are proposing to amend the regulations governing the
importation of meat and other edible animal products by allowing, under
certain conditions, the importation of whole cuts of boneless beef from
Japan. We are proposing this action in response to a request from the
Government of Japan and after conducting an analysis of the risk that
indicates that such beef can be safely imported from Japan under the
conditions described in this proposal.
DATES: We will consider all comments that we receive on or before
September 19, 2005.
ADDRESSES: You may submit comments by any of the following methods:
EDOCKET: Go to http://www.epa.gov/feddocket to submit or
snip...
BSE infectivity has never been demonstrated in the muscle tissue of
cattle experimentally or naturally infected with BSE at any stage of
the disease. Studies performed using TSEs other than BSE in non-bovine
animals have detected prions in muscle tissue. However, the
international scientific community largely considers that these studies
cannot be directly extrapolated to BSE in cattle because of the
significant interactions between the host species and the prion strain
involved.
Pathogenesis studies of naturally and experimentally infected
cattle have not detected BSE infectivity in blood. However,
transmission of BSE was demonstrated in sheep that received a
transfusion of a large volume of blood drawn from other sheep that were
experimentally infected with the BSE agent. The United Kingdom's
Department for Environment, Food and Rural Affairs' Spongiform
Encephalopathy Advisory Committee (SEAC) and the European Commission's
Scientific Steering Committee (SSC), which are scientific advisory
committees, evaluated the implication of this finding in relation to
food safety.\5\ The SEAC concluded that the finding did not represent
grounds for recommending any changes to the current control measures
for BSE. The SSC determined that the research results do not support
the hypothesis that bovine blood or muscle meat constitute a risk to
human health.\6\
snip...
BSE Risk Factors for Whole Cuts of Boneless Beef
The most significant risk management strategy for ensuring the
safety of whole cuts of boneless beef is the prevention of cross-
contamination of the beef with SRMs during stunning and slaughter of
the animal. Control measures that prevent contamination of such beef
involve the establishment of procedures for the removal of SRMs,
prohibitions on air-injection stunning and pithing, and splitting of
carcasses. These potential pathways for contamination and the control
measures that prevent contamination are described in detail in the risk
analysis for this rulemaking.
SRM Removal. Research has demonstrated that SRMs from infected
cattle may contain BSE infectivity. Because infectivity has not been
demonstrated in muscle tissue, the most important mitigation measure
for whole cuts of boneless beef is the careful removal and segregation
of SRMs. Removal of SRMs in a manner that avoids contamination of the
beef with SRMs minimizes the risk of exposure to materials that have
been demonstrated to contain the BSE agent in cattle.
snip...
Variant Creutzfeldt-Jakob disease (vCJD), a chronic and fatal
neurodegenerative disease of humans, has been linked since 1996 through
epidemiological, neuropathological, and experimental data to exposure
to the BSE agent, most likely through consumption of cattle products
contaminated with the agent before BSE control measures were in place.
To date, approximately 170 probable and confirmed cases of vCJD have
been identified worldwide. The majority of these cases have either been
identified in the United Kingdom or were linked to exposure that
occurred in the United Kingdom, and all cases have been linked to
exposure in countries with native cases of BSE. Some studies estimate
that more than 1 million cattle may have been infected with BSE
throughout the epidemic in the United Kingdom. This number of infected
cattle could have introduced a significant amount of infectivity into
the human food supply. Yet, the low number of cases of vCJD identified
to date indicates that there is a substantial species barrier that
protects humans from widespread illness due to exposure to the BSE
agent.
snip...
International Guidelines on BSE
International guidelines for trade in animal and animal products
are developed by the World Organization for Animal Health (formerly
known as the Office International des Epizooties (OIE)), which is
recognized by the World Trade Organization (WTO) as the international
organization responsible for the development of standards, guidelines,
and recommendations with respect to animal health and zoonoses
(diseases that are transmissible from animals to humans). The OIE
guidelines for trade in terrestrial animals (mammals, birds, and bees)
are detailed in the Terrestrial Animal Health Code (available on the
internet at http://www.oie.int). The guidelines on BSE are contained in
Chapter 2.3.13 of the Code and supplemented by Appendix 3.8.4 of the
Code.
snip...end
http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/2005/05-16422.htm
http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/2005/pdf/05-16422.pdf
Greetings again APHIS ET AL,
THIS is not correct. IN fact, there are several factors i would like to kindly address. .......
SNIP...
WE MUST ADHERE TO THE BSE GBR RISK ASSESSMENTS, WE MUST WORK TO ENHANCE THOSE BSE GBR RISK ASSESSMENTS TO INCLUDE ALL ANIMAL TSEs, USDA/APHIS/GW ET ALs BSE MRR (Minimal Risk Region) should be REPEALED/DISBANDED/TRASHED/NADA and done away with for good. The BSE MRR policy is nothing more than a legal tool to trade all strains of TSEs globally...
Terry S. Singeltary Sr.
P.O. Box 42
Bacliff, Texas USA 77518
Your Comment with Title "[Docket No. 05-004-1] RIN 0579-AB93 BSE TSS " was Received.
The Identifier Assigned is "APHIS-2005-0073-0009".
An Electronic File was Attached to this Submission.
Please note that it may take between 24 and 72 hours for the EDOCKET staff to process your comment before it is available publicly through EDOCKET. You can use the identifier noted above to find your comment through the Quick or Advanced Search pages when it is available. ...........
http://www.aphis.usda.gov/lpa/news/2005/08/japanbeef_vs.html
EPA: Federal Register: Importation of Whole Cuts of Boneless Beef ...Importation of Whole Cuts of Boneless Beef From Japan , Federal Register document. ... we published in the Federal Register (70 FR 48494-48500, Docket No. ...
http://www.epa.gov/fedrgstr/EPA-IMPACT/2005/December/Day-14/i24057.htm
Importation of Whole Cuts of Boneless Beef from Japan [Docket No. 05-004-1] RIN 0579-AB93 TSS SUBMISSION
next 3 urls now dead ;
http://docket.epa.gov/edkfed/do/EDKStaffItemDetailView?objectId=090007d480993808
http://docket.epa.gov/edkfed/do/EDKStaffAttachDownloadPDF?objectId=090007d480993808
http://docket.epa.gov/edkfed/do/EDKStaffCollectionDetailView?objectId=0b0007d48096b40d
"[Docket No. 05-004-1] RIN 0579-AB93 BSE TSS " was Received
BSE; MRR; IMPORTATION OF LIVE BOVINES AND PRODUCTS DERIVED FROM BOVINES [Docket No. APHIS-2006-0041] RIN 0579-AC01
APHIS-2006-0041-0006 Comment from Terry S Singletary Sr 01/09/2007 PUBLIC SUBMISSIONS
http://www.regulations.gov/fdmspublic/ContentViewer?objectId=09000064801f3412&disposition=attachment&contentType=crtext
APHIS-2006-0041-0006.1 Attachment to Singletary comment 01/09/2007 PUBLIC SUBMISSIONS
http://www.regulations.gov/fdmspublic/ContentViewer?objectId=09000064801f3413&disposition=attachment&contentType=msw8
TSS