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December 21, 2005
USDA Ignores Latest Scientific Evidence,
Reverses BSE Protection Measures,
Adopts Weakest Int'l. Standards for Japanese Beef Imports
(Billings, Mont.) – "The U.S. Department of Agriculture (USDA) does not have a coherent BSE protection policy and is making trade deals with BSE-affected countries based on politics, not science," said R-CALF USA president Leo McDonnell, in response to USDA's final rule that allows Japan to export boneless beef from cattle of any age into the United States.
The rule (Japan Import Rule) is titled "Importation of Whole Cuts of Boneless Beef from Japan," and was published Dec. 14 in the Federal Register (Docket No. 05-004-2).
Japan's bovine spongiform encephalopathy (BSE) epidemic continues to grow, with seven new cases reported so far in 2005, and it reported its 21st case just last week. In 2004, Japan recorded five BSE cases; 2003, four cases; 2002, two cases; and, in 2001, three cases of BSE.
"Japan's adult cattle population is only 2.05 million head, and with 21 reported BSE cases, it is obvious Japan has a significant BSE problem," McDonnell explained. "Despite these facts, this Japan Import Rule immediately allows Japan to start shipping the U.S. boneless beef, no matter how old the animal was that those beef products came from.
"This sets a dangerous precedent for the U.S. cattle industry as it makes the U.S. the only major beef-consuming country in the world to accept beef from a BSE-infected cattle herd – regardless of the scope of the disease problem in that country and without requiring the more stringent BSE risk mitigation measures recommended by the OIE (World Organization for Animal Health)," he warned.
Less than a year ago, USDA published a rule on BSE and minimal-risk regions (Final Rule) to establish conditions under which the U.S. would accept beef from countries where BSE is known to exist. The agency claimed its policy was based on the latest scientific knowledge and USDA stated that several conditions must be met before the risk of importing beef from BSE-affected countries would be reduced to an acceptable level.
Among the conditions USDA stated were necessary to protect the U.S. from the introduction of BSE was the requirement that countries must have had in place – prior to the detection of BSE – risk mitigation measures adequate to prevent the establishment of the disease.
USDA explained that because of BSE's lengthy incubation period, in countries that did not have risk mitigation measures such as a ruminant-to-ruminant feed ban prior to the detection of BSE, "by the time BSE was diagnosed in such countries and control measures were implemented, the chances that the disease had significantly spread were great."
"This is precisely the case with Japan, which did not even implement a mandatory ruminant-to-ruminant feed ban until after late 2001, when it first discovered BSE in its native herd," McDonnell pointed out. "With 21 cases of BSE, Japan's rate of BSE is now over 10 cases per million head of cattle.
"Based on USDA's own conclusions regarding BSE, Japan's BSE epidemic is not expected to peak until 5 years after Japan implemented its feed ban, putting the expected peak during 2006 or beyond," he continued. "So, despite Japan's failure to implement timely prevention measures, USDA now says that this criterion doesn't apply to Japan. And, despite the higher inherent risk of BSE in the Japanese cattle herd, the U.S. will, nonetheless, begin importing Japanese beef."
USDA supports its newly relaxed position based on the same scientific knowledge the agency had when the agency established the condition in the first place – simply that BSE has not been detected in the muscle tissues of cattle.
But this isn't all.
In addition, and again, based also on the agency's 'latest scientific knowledge,' USDA defended its decision in the Final Rule to allow imports only from countries that met the condition of a BSE minimal-risk country, based on the agency's implementation of what the USDA calls a series of interlocking and overlapping mitigation measures to minimize the risk of introducing BSE into the United States.
"This series of barriers included a requirement that only cattle and beef from cattle under 30 months of age would be allowed from minimal-risk countries – a recognition that the BSE risk is inherently higher in animals over 30 months of age," McDonnell explained. "However, USDA has tossed this important mitigation measure out the window by allowing imports of Japanese beef from animals over 30 months of age, and the agency is now attempting to defend its action by claiming that age doesn't matter after all.
"Unfortunately, however, USDA is accepting this over-30-month (OTM) Japanese beef from cattle of all breeds, including Holstein and Wagyu cattle, while imposing only the least stringent of all the risk mitigation measures recommended by the OIE," McDonnell cautioned.
"The Japan Import Rule does not require the removal of high-risk tissues such as the brains, spinal cord and vertebral columns from Japanese cattle over 12 months of age, which is the minimal practice in every other country in the world, except Canada, with multiple cases of BSE," McDonnell pointed out.
"USDA has not used any new scientific findings to support its relaxation of restrictions on Japanese imports," noted veterinarian and R-CALF USA Vice President-Elect Max Thornsberry. "Instead, the agency has merely changed its conclusions drawn from the same scientific evidence it previously used to require much more stringent mitigation measures."
In fact, Thornsberry pointed out, when R-CALF USA presented USDA with new scientific research (conducted on a naturally infected BSE cow by German researchers Anne Buschmann and Martin Groschup and published in the September 2005 issue of The Journal of Infectious Diseases) which not only reinforced previous findings but also revealed new findings showing BSE infectivity in new tissues – an obvious argument for proceeding with far more caution – USDA selectively dismissed the new scientific evidence on the basis the agency has not adequately confirmed that the scientific findings are correct.
"In other words," stressed Thornsberry, "USDA is radically abandoning its scientific risk mitigation measures and is dismissing cutting-edge science without first confirming if such actions are unnecessarily increasing the risk of BSE."
Moreover, Thornsberry said, the Japan Import Rule contradicts the agency's previous conclusions on measures needed to mitigate the BSE risk. Just months ago, USDA considered BSE surveillance testing as an essential BSE mitigation measure. However, in the Japan Import Rule – which imposes no testing requirements on Japan – USDA now reverses its position and states that surveillance is not a mitigation measure.
Thornsberry explained that Japan currently conducts what is called an ELISA screening test followed by a confirmation test using the Western blot method on all older slaughtered cattle. This testing allows Japan to remove infected cattle from the food chain, particularly older cattle. But, because the U.S. does not require imports to be subject to such testing, Japanese beef from even older, high-risk cattle may be exported to the U.S. without undergoing a screening test to ensure that beef from older, BSE-infected animals is not exported to the United States, he said.
"U.S. consumers and U.S. cattle producers deserve the utmost in protections from USDA, and this action of relaxing important heath and safety standards in order to meet political ends – despite new scientific evidence – shows the agency has lost sight of its statutory responsibilities," Thornsberry emphasized. "USDA could not be more inconsistent than is demonstrated by this rule.
In another clear example of inconsistency in the Japan Import Rule, USDA has ignored OIE's requirement that beef products not be derived from cattle that may have been fed animal feed containing ruminant byproducts. Because the Japan Import Rule does not restrict cattle that were born before Japan's 2001 feed ban, there is no provision or other assurance that cattle or beef products from cattle born and fed before the implementation of Japan's feed ban would not be exported to the United States.
"One of the most frustrating things about this to cattle producers is USDA taking this action without regard to whether this relaxation of BSE standards will adversely affect our ability to restore the other export markets that were closed to us after the December 2003 discovery in Washington state of a Canadian cow with BSE," he explained.
"What's happening here is that USDA is hoping no one will object to this radical relaxation of health standards because they want to get into the Japanese market so badly," McDonnell warned. "But USDA will now use this industry silence to support equally relaxed standards for Canada and other countries with BSE, opening the U.S. market to older cows and bulls that present a greater risk of introducing BSE."
USDA Ignores Latest Scientific Evidence,
Reverses BSE Protection Measures,
Adopts Weakest Int'l. Standards for Japanese Beef Imports
(Billings, Mont.) – "The U.S. Department of Agriculture (USDA) does not have a coherent BSE protection policy and is making trade deals with BSE-affected countries based on politics, not science," said R-CALF USA president Leo McDonnell, in response to USDA's final rule that allows Japan to export boneless beef from cattle of any age into the United States.
The rule (Japan Import Rule) is titled "Importation of Whole Cuts of Boneless Beef from Japan," and was published Dec. 14 in the Federal Register (Docket No. 05-004-2).
Japan's bovine spongiform encephalopathy (BSE) epidemic continues to grow, with seven new cases reported so far in 2005, and it reported its 21st case just last week. In 2004, Japan recorded five BSE cases; 2003, four cases; 2002, two cases; and, in 2001, three cases of BSE.
"Japan's adult cattle population is only 2.05 million head, and with 21 reported BSE cases, it is obvious Japan has a significant BSE problem," McDonnell explained. "Despite these facts, this Japan Import Rule immediately allows Japan to start shipping the U.S. boneless beef, no matter how old the animal was that those beef products came from.
"This sets a dangerous precedent for the U.S. cattle industry as it makes the U.S. the only major beef-consuming country in the world to accept beef from a BSE-infected cattle herd – regardless of the scope of the disease problem in that country and without requiring the more stringent BSE risk mitigation measures recommended by the OIE (World Organization for Animal Health)," he warned.
Less than a year ago, USDA published a rule on BSE and minimal-risk regions (Final Rule) to establish conditions under which the U.S. would accept beef from countries where BSE is known to exist. The agency claimed its policy was based on the latest scientific knowledge and USDA stated that several conditions must be met before the risk of importing beef from BSE-affected countries would be reduced to an acceptable level.
Among the conditions USDA stated were necessary to protect the U.S. from the introduction of BSE was the requirement that countries must have had in place – prior to the detection of BSE – risk mitigation measures adequate to prevent the establishment of the disease.
USDA explained that because of BSE's lengthy incubation period, in countries that did not have risk mitigation measures such as a ruminant-to-ruminant feed ban prior to the detection of BSE, "by the time BSE was diagnosed in such countries and control measures were implemented, the chances that the disease had significantly spread were great."
"This is precisely the case with Japan, which did not even implement a mandatory ruminant-to-ruminant feed ban until after late 2001, when it first discovered BSE in its native herd," McDonnell pointed out. "With 21 cases of BSE, Japan's rate of BSE is now over 10 cases per million head of cattle.
"Based on USDA's own conclusions regarding BSE, Japan's BSE epidemic is not expected to peak until 5 years after Japan implemented its feed ban, putting the expected peak during 2006 or beyond," he continued. "So, despite Japan's failure to implement timely prevention measures, USDA now says that this criterion doesn't apply to Japan. And, despite the higher inherent risk of BSE in the Japanese cattle herd, the U.S. will, nonetheless, begin importing Japanese beef."
USDA supports its newly relaxed position based on the same scientific knowledge the agency had when the agency established the condition in the first place – simply that BSE has not been detected in the muscle tissues of cattle.
But this isn't all.
In addition, and again, based also on the agency's 'latest scientific knowledge,' USDA defended its decision in the Final Rule to allow imports only from countries that met the condition of a BSE minimal-risk country, based on the agency's implementation of what the USDA calls a series of interlocking and overlapping mitigation measures to minimize the risk of introducing BSE into the United States.
"This series of barriers included a requirement that only cattle and beef from cattle under 30 months of age would be allowed from minimal-risk countries – a recognition that the BSE risk is inherently higher in animals over 30 months of age," McDonnell explained. "However, USDA has tossed this important mitigation measure out the window by allowing imports of Japanese beef from animals over 30 months of age, and the agency is now attempting to defend its action by claiming that age doesn't matter after all.
"Unfortunately, however, USDA is accepting this over-30-month (OTM) Japanese beef from cattle of all breeds, including Holstein and Wagyu cattle, while imposing only the least stringent of all the risk mitigation measures recommended by the OIE," McDonnell cautioned.
"The Japan Import Rule does not require the removal of high-risk tissues such as the brains, spinal cord and vertebral columns from Japanese cattle over 12 months of age, which is the minimal practice in every other country in the world, except Canada, with multiple cases of BSE," McDonnell pointed out.
"USDA has not used any new scientific findings to support its relaxation of restrictions on Japanese imports," noted veterinarian and R-CALF USA Vice President-Elect Max Thornsberry. "Instead, the agency has merely changed its conclusions drawn from the same scientific evidence it previously used to require much more stringent mitigation measures."
In fact, Thornsberry pointed out, when R-CALF USA presented USDA with new scientific research (conducted on a naturally infected BSE cow by German researchers Anne Buschmann and Martin Groschup and published in the September 2005 issue of The Journal of Infectious Diseases) which not only reinforced previous findings but also revealed new findings showing BSE infectivity in new tissues – an obvious argument for proceeding with far more caution – USDA selectively dismissed the new scientific evidence on the basis the agency has not adequately confirmed that the scientific findings are correct.
"In other words," stressed Thornsberry, "USDA is radically abandoning its scientific risk mitigation measures and is dismissing cutting-edge science without first confirming if such actions are unnecessarily increasing the risk of BSE."
Moreover, Thornsberry said, the Japan Import Rule contradicts the agency's previous conclusions on measures needed to mitigate the BSE risk. Just months ago, USDA considered BSE surveillance testing as an essential BSE mitigation measure. However, in the Japan Import Rule – which imposes no testing requirements on Japan – USDA now reverses its position and states that surveillance is not a mitigation measure.
Thornsberry explained that Japan currently conducts what is called an ELISA screening test followed by a confirmation test using the Western blot method on all older slaughtered cattle. This testing allows Japan to remove infected cattle from the food chain, particularly older cattle. But, because the U.S. does not require imports to be subject to such testing, Japanese beef from even older, high-risk cattle may be exported to the U.S. without undergoing a screening test to ensure that beef from older, BSE-infected animals is not exported to the United States, he said.
"U.S. consumers and U.S. cattle producers deserve the utmost in protections from USDA, and this action of relaxing important heath and safety standards in order to meet political ends – despite new scientific evidence – shows the agency has lost sight of its statutory responsibilities," Thornsberry emphasized. "USDA could not be more inconsistent than is demonstrated by this rule.
In another clear example of inconsistency in the Japan Import Rule, USDA has ignored OIE's requirement that beef products not be derived from cattle that may have been fed animal feed containing ruminant byproducts. Because the Japan Import Rule does not restrict cattle that were born before Japan's 2001 feed ban, there is no provision or other assurance that cattle or beef products from cattle born and fed before the implementation of Japan's feed ban would not be exported to the United States.
"One of the most frustrating things about this to cattle producers is USDA taking this action without regard to whether this relaxation of BSE standards will adversely affect our ability to restore the other export markets that were closed to us after the December 2003 discovery in Washington state of a Canadian cow with BSE," he explained.
"What's happening here is that USDA is hoping no one will object to this radical relaxation of health standards because they want to get into the Japanese market so badly," McDonnell warned. "But USDA will now use this industry silence to support equally relaxed standards for Canada and other countries with BSE, opening the U.S. market to older cows and bulls that present a greater risk of introducing BSE."