USDA At It Again!!

[Anonymous]

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."

 

[Sandhusker]

Hate to say it, but I'm not surprised. Again, money is trump with that bunch. Trade is all that is important, they've shown that time and time again.

 

[Jason]

But all the beef imported from Japan will be from tested animals. How come you R-halfers said that was enough to send beef to Japan but now it's not enough to accept it?

 

[Anonymous]

But all the beef imported from Japan will be from tested animals. How come you R-halfers said that was enough to send beef to Japan but now it's not enough to accept it?

Jason- You didn't read it very well!!!! Again!!!

"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."

 

[Sandhusker]

But all the beef imported from Japan will be from tested animals. How come you R-halfers said that was enough to send beef to Japan but now it's not enough to accept it?

Sure, we'll accept your apology for that "R-half" comment, Jason!

 

[Jason]

It might not require it but then it said all product was OTM and tested.

 

[flounder]

R-CALF-USA Sponsored
Prion Disease Round Table
Conducted Wednesday December 11, 2003 at Denver, Colorado

On Thursday, December 11, 2003, R-CALF-USA and a number of its affiliate cattle organizations sponsored a Prion Disease Roundtable in Denver, Colorado. Dr. R. M. Thornsberry, President of the Missouri Stockgrower's Association was commissioned by R-CALF President Leo McDonnel to organize the roundtable and invite prion specialists to present information at the roundtable that would benefit the education of livestock producers throughout the United States.

Dr. Stanley Prusiner, the scientist who discovered prions, for which he won the Nobel Prize in medicine, was invited to the roundtable. Notes from Dr. Prusiner's presentation on prions and prion diseases were presented to the roundtable by Dr. Thornsberry, who had attended one of Dr. Prusiner's lectures on prion diseases. Although unable to attend the roundtable, Dr. Prusiner provided the roundtable with five papers published in prestigious peer reviewed medical and science journals. These papers were provided to all the attendees and key points from these papers were discussed at the beginning of the roundtable discussion. Dr. Prusiner emphasized normal cooking temperatures do not inactivate prions. This point is especially important when humans are exposed to Bovine Spongiform Encephalopathy (BSE) prions in the normal process of consuming beef muscle cuts that may contain significant nerve tissue. Dr. Prusiner's laboratory is currently developing a live animal test to determine whether or not an animal is carrying BSE prions prior to entering the food chain for human consumption.

Dr. Jason Bartz, an applied science researcher from Creighton University, Omaha, Nebraska, was the second presenter at the roundtable. Dr. Bartz presented current research data on prion diseases and particularly outlined the pathogenesis of prion diseases. Dr. Bartz presented data that defined the ability of prions to replicate in secondary lymphoreticular system tissues, and the ability of prions to travel throughout the nervous system, finally locating within the brain or brain stem tissues where pathological changes occur. Dr. Bartz also presented data to illustrate the severity of prion disease appears to increase as the disease is passed from animal to animal. Dr. Bartz presented data to illustrate the infectivity and persistency of prions. Prions in brain tissue were heated to 600 degrees Celsius--that is over 1200 degrees Fahrenheit--and injected into brain tissue. These heat treated prions were still capable of causing prion disease changes. In other words, there is no commonly utilized method with which to inactivate prions on surgical instruments, surfaces, pens, corrals, chutes, ground, etc. Dr. Bartz also presented data that indicates tongue lesions or sores provide the mechanism for prions to enter brain tissue through the nerve that supplies the muscle tissue of an animal's tongue. Dr. Bartz, with more sensitive immunodection, has identified prions in mì¥Á 7 ð ¿ `l
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U 0 … f ž Õ# P Õ# P $ ' ¦ ^ Ù R-CALF-USA Sponsored
Prion Disease Round Table
Conducted Wednesday December 11, 2003 at Denver, Colorado

On Thursday, December 11, 2003, R-CALF-USA and a number of its affiliate cattle organizations sponsored a Prion Disease Roundtable in Denver, Colorado. Dr. R. M. Thornsberry, President of the Missouri Stockgrower's Association was commissioned by R-CALF President Leo McDonnel to organize the roundtable and invite prion specialists to present information at the roundtable that would benefit the education of livestock producers throughout the United States.

Dr. Stanley Prusiner, the scientist who discovered prions, for which he won the Nobel Prize in medicine, was invited to the roundtable. Notes from Dr. Prusiner's presentation on prions and prion diseases were presented to the roundtable by Dr. Thornsberry, who had attended one of Dr. Prusiner's lectures on prion diseases. Although unable to attend the roundtable, Dr. Prusiner provided the roundtable with five papers published in prestigious peer revialth. That is, bovine brain, spinal cord and other potentially infected tissues may still be used in food products.

Dr. Susan Keller, Deputy State Veterinarian for North Dakota, presented the regulatory issues surrounding prion diseases including Scrapie in sheep and BSE in cattle. During a discussion on the most recent Havard Risk Assessment for BSE in the United States, Dr. Keller attempted to determine what the industry response would be to a single case of BSE in the United States. The fact that the incubation period of BSE is extremely long (possibly up to 20 years), Dr. Keller determined that responding to a single case of BSE could potentially encompass up to 20 years of regulatory activity to ensure the public that BSE was under control in the United States. Although the Havard Risk Assessment for BSE is accurate, it does not take into account the devastating effect of a single case in the United States on state regulatory function and financing. Once Canada is designated an acceptable risk country for export of meat or animals into the United States, other countries with a history of cases of BSE will also petition the United States government for the same export status.

Following the roundtable, a general consensus was reached on four topics:

1. Prion diseases are infective, especially within susceptible species. Although most animals that exhibit symptoms of prion disease die, thus ending the progression of the disease, that animal may in fact shed many prions into the environment prior to and after death.
2. Since there is no known Standard Operating Procedural method to adequately disinfect or inactivate prions, extreme caution should be taken with prion diseases, their research, and their disposal.
3. New more sensitive prion histochemial testing procedures identify prions in muscle tissue as well as lympoid and nervous tissue. This finding is reinforced by Dr. Prusiner's laboratory, which is developing a preslaughter test to identify prions in tissues prior to meat entering the food chain. This finding means human exposure to prions in certain muscle cuts of beef is possible.
4. Opening the border to Canada is questionable until high risk factors such as the feeding of blood meal, feather meal, unfiltered beef tallow, poultry manure, and non-ruminant species feeding of meat and bone meal is properly addressed by the United States Department of Agriculture and the Food and Drug Administration.

The primary impetus for this round table was the increased incidence of Chronic Wasting Disease (CWD) in deer and elk in the western United States. The question was posed: "Is Chronic Wasting Disease infectious to cattle? Is it possible for cattle to get Bovine Spongioform Encepalopathy (BSE) from deer and or elk?"

Research presented by Dr. Terry Spraker during the round table discussions indicate no natural transmission of CWD from deer or elk has been documented. Numerous studies are underway to research the possible transmission of CWD to other species. Even when brain tissue from a known CWD disease deer is injected directly into the brain of a susceptible bovine animal, the lesions that develop are not exactly like those produced by a natural BSE infection. Dr. Spraker's work with the pathology of CWD presents several interesting findings:

1. Deer or elk with CWD do not necessarily die from the disease quickly. They can appear perfectly normal while shedding large numbers of infective prions in saliva, tears, and feces. Not all deer and elk with CWD die from the prion infection of the nervous tissues; it is not always a quick acting disease. Even in cattle, a natural BSE infection may take years to actually cause the death of its victim. Do cattle also shed large numbers of BSE prions into their environment before death? Could this be the answer for why so many new cases of BSE are occurring in Europe in 2003 and 2004, even though the feeding of meat and bone meal has been discontinued since the early 1990's?

2. The prion that causes CWD in deer and elk localizes rather quickly in the progression of CWD in the tongue and the nerves that supply the tongue. CWD has been known to exist since 1967, but only recently has it been recognized as a prion disease similar to BSE. CWD appears to only infect white tailed deer, mule deer, and elk.

Dr. Spraker indicated that no human transmission of CWD has been known to occur. It does not mean it is impossible for transmission to occur to humans, but no cases have been demonstrated. A test is available for screening deer and elk harvested in a known infected area. The test is very accurate. Dr. Spraker advised against consuming deer or elk meat which has tested positive for CWD. The test is performed on deer after harvesting. No live animal test is currently available for deer or elk.

Dr. Jason Bartz provided the round table group with mountains of research studies to document the infectivity and progression of BSE and BSE like diseases in several species. Dr. Bartz demonstrated that the infective agent that causes CWD, BSE, and Scrapie in sheep is a specifically folded protein called a "prion". There are normal levels of normal prions in the tissues of almost all species. When the chemical folding of the prion becomes misshapen, the result is an abnormal prion. Repeated exposure of tissues to the abnormal prions that cause BSE, CWD, or Scrapie cause a "conversion" process to occur. The tissues become programmed to begin to produce abnormal prions faster than the tissues can clear them out of cellular structures. The end result is the death of the tissues involved. When these tissues are in the brain and spinal chord, the result is neurological disease. Usually, the patient begins to suffer memory loss and eventually develops depression symptoms. These rather minor symptoms progress into muscle strength loss, lack of muscle and skeleton coordination, and eventually complete neuro-muscular collapse. The disease eventually causes a coma followed by death. All these terrible symptoms are the direct result of cells in the brain being destroyed by accumulations of abnormal prions. The animal or human does not eat enough abnormal prions to cause all this damage. A conversion process occurs that actually converts normal prions into disease causing abnormal prions. The question is asked: How many times does a patient need to be exposed to abnormal prions before this conversion process begins? Apparently, no one knows the answer to that question.

Therein lies the problem. Dr. Stanley Prusiner believes any exposure to any level of abnormal prions can potentially stimulate the conversion process. Research studies with laboratory animals yield different answers. In some animals, it takes several exposures before the conversion process is triggered. In other more susceptible animals, two exposures appears to be all that is needed to cause the conversion process to trigger. Dr. Prusiner believes the United States Department of Agriculture should take measures to prevent any human from being exposed to any level of abnormal prions in the food supply. Knowing some people, like some laboratory animals, are more susceptible to the conversion triggering process, should stimulate the USDA to implement measures to prevent any exposure to any level of abnormal BSE prions.

Dr. Bartz presented data that was very troubling. There is no known, commonly utilized, method of sterilization that inactivates prions. Heating prion infected tissues to the point of combustion did not inactivate the prions. When the ash was injected into brain tissues of laboratory animals, it still caused prion related disease. Instruments utilized in brain surgery of prion diseased patients are discarded and never utilized again. Prion laced tissues were actually buried for several years in the ground. When disinterred, the prions were still capable of causing disease when injected into susceptible animals. Unless the prions are digested with strong base solutions or acted upon by enzymes specifically designed to break the prions down, nothing, including burning, will inactivate the prions that cause BSE, CWD, or Scrapie.

Prions are ingested and enter the lymphoreticular system tissues. These tissues are found in the tonsils and the lymph tissues associated with the intestinal tract. Once the prions enter the body they readily gain access to the nervous system and find their way to the brain. The nerve that innervates the tongue gives direct access to the upper spinal chord and brain tissues. Open sores in the mouth or on the tongue provide direct access for prions to enter the body. Direct inoculation of prions into the tongue was 100,000 fold more effective in causing disease than ingestion of prions when BSE was studied in hamsters. For obvious reasons, people with pierced lips, tongues, or gums could potentially be much more susceptible to BSE than patients without piercings.

Dr. Bartz presented data supporting the knowledge that prions are not just contained in brain or nerve tissues. Prions have been identified in muscle tissues and in individual myocytes making up muscle bundles. In Europe it is recognized that the human form of BSE is caused by eating prion tainted beef and beef byproducts, particularly those byproducts made from the brain, intestines, and spinal chord.

Dr. Bartz provided the group with research that indicated multiple passages of prion disease among and between species increased the severity of the resulting disease substantially. In other words, the more times the disease is passed from animal to animal, the worse the disease becomes. It was demonstrated that prions incapable of causing disease in one species, if passed down through several generations of another species, would cause disease in the first species when reintroduced into the initial species. That point is alarming. You cannot say with certainty that a prion disease, which appears at this time to be species specific, cannot eventually cause disease in another particular species. Prion diseases are very complex. The incubation times are long. It may be several years before scientists fully understand diseases caused by prions. In the meantime, an abundance of caution is in order.

Dr. Bartz did explain an interesting finding. Conducting research with laboratory animals, it was discovered that specific strains are not susceptible to BSE. It was discovered that these strains did not have any, or at least a very low level, of normal prions in their tissues. Without normal prions to convert into abnormal prions, these strains of laboratory animals could not be infected with BSE. No matter how many times they were exposed, they did not develop the disease. The South Koreans have released some documentation that indicates they may have discovered a similar strain of cattle that do not have any level of normal prions. If that is the case, these cattle cannot convert, and thus cannot develop BSE, no matter how much exposure to BSE prions they receive. Just the thought of developing genetic lines of cattle that cannot be caused to develop BSE should make investors stand up and take notice.

Following Dr. Bartz's alarming discussion about the infectivity and pathogenesis of prion diseases, Dr. Linda Detwiler told the round table group: "Prevention is best, but if you know it has been introduced, what can you do to limit the transmission?" Europe has experience at dealing with BSE and new variant Creutzfeldt-Jakob Disease (vCJD). vCJD is caused by humans consuming beef tainted with BSE prions. Even though the United Kingdom prohibited the feeding of bovine meat and bone meal to ruminants in 1988, they still documented nearly 300 new cases of BSE in cattle during 2003. Northern Ireland has documented 28 new cases of BSE in the first quarter of 2004 alone. Spain and Italy have both documented a number of new cases of BSE in cattle during the first few months of 2004. Where are these cases coming from? How are cattle being exposed to BSE prions if they are not being fed in the animals' feed? No one has the answer. To prevent such a tragedy in the United States we must have measures in place to prevent the occurrence of BSE and new vCJD. Dr. Detwiler discussed the importance of preventing the exposure of cattle in the United States to ruminant tissues in feed. Specific Risk Materials (SRM's) were identified as blood meal, unfiltered tallow, and composted poultry litter. At the time of the round table, all these SRM's were legal to feed in the United States and Canada. Poultry litter is of special significance since ruminant meat and bone meal is commonly utilized as a protein source in starter and grower diets. Poultry of all classes commonly lose 3% of the total diet fed to scratching out feed or wasting feed next to feeders. Besides the wasted feed that goes into the litter compost, prions that pass through the poultry digestive tract are considered intact. These prions are not destroyed or inactivated by composting. When the composted litter is fed to cattle, the prions enter the food chain.

Blood meal is collected at slaughter in troughs below the hanging carcasses. The blood itself appears to be of minor importance in the conveyance of prions, but the stunning techniques utilized in most packing plants opens the skull and allows brain tissues to seep into the blood meal while the carcass is hung upside down during the bleed out process. Bolt stunning, air injection stunning, or any other method that opens the skull provides access to prions contained in brain tissue. Even though blood meal undergoes extensive heat processing, that heating process is not capable of inactivating prions.

Tallow--melted bovine body fat-- is allowed to be added to many species' manufactured feed. Unfiltered tallow may contain nervous tissues or other tissues that contain high levels of prions. Since heat does not inactivate the prions that cause BSE, transmission of disease can occur.

Since the single case of BSE was identified in a Canadian cow imported into Washington State in late December, 2003, the USDA and the Food and Drug Administration has issued statements concerning SRM's. To date, the feeding of poultry litter is not prohibited.

Dr. Detwiler asked some very important questions:

1. Was this Canadian case an isolated case? With what we know about BSE, that is not likely.
2. If there were to be more cases, how many? And very important, if there are additional cases, how old are they and were they born before or after the ruminant species feed ban?
3. If they were born after the feed ban, why wasn't the feed ban effective?

We now know that the two recent cases of BSE in Canada were traced to a feed mill that did not abide by the ruminant species feed ban in 1996. Obviously, more than two cows were exposed to the contaminated feed. How many converted to the point that disease resulted? How can we identify those cattle that did convert? If the importation ban on Canadian cattle is lifted, how can we identify Canadian cattle within the United States and further, how can we identify the Canadian beef within the United States marketplace?

Canada still allows automated meat recovery in the making of processed meats. This recovery system utilizes high pressure water and mechanical procedures to glean the last remaining meat from a carcass. Unfortunately, in the process, nervous tissues along the spinal column are allowed to enter the meat making process. This increases the exposure to humans to potentially high levels of BSE prions.

Remember that the Roundtable was conducted prior to the second case of BSE being identified in Washington State. Dr. Susan Keller presented information on how regulatory veterinarians view prion related diseases. Dr. Keller presented data illustrating a given state's response to a single case of BSE. Much of what she presented was indeed prophetic. Much of what she presented as a potential scenario actually occurred when the BSE positive cow was identified in Washington State. Dr. Keller expressed concern for states bordering Canada and particularly expressed concerns about the current state of surveillance for BSE in the United States. Surveillance at the time of the roundtable was limited to downer cows slaughtered at USDA inspected slaughter facilities. Was testing of 20,000 to 30,000 mature cattle adequate to discover the prevalence of a disease in a population of 100,000,000 cattle? Although downer cows are in the higher risk category, data from Europe and Japan indicate BSE is being identified in younger and younger animals in those regions of the globe.

Dr. Keller stated: "We're also charged with taking any steps necessary to control, suppress, eradicate, any and all contagious and infectious diseases. Since prion diseases are indeed considered infectious, they fall under that statute. The State Veterinarian also has the responsibility, if warranted, to quarantine domestic animals and non-traditional livestock. He or she is to regulate and prohibit arrival or departure from our state of any animals that may be exposed or infected with a disease. Where this gets interesting, is when a state doesn't think the federal regulations are protecting the state's animalì¥Á 7 ð ¿ `l
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U 0 … f ž Õ# P Õ# P $ ' ¦ ^ Ù R-CALF-USA Sponsored
Prion Disease Round Table
Conducted Wednesday December 11, 2003 at Denver, Colorado

On Thursday, December 11, 2003, R-CALF-USA and a number of its affiliate cattle organizations sponsored a Prion Disease Roundtable in Denver, Colorado. Dr. R. M. Thornsberry, President of the Missouri Stockgrower's Association was commissioned by R-CALF President Leo McDonnel to organize the roundtable and invite prion specialists to present information at the roundtable that would benefit the education of livestock producers throughout the United States.

Dr. Stanley Prusiner, the scientist who discovered prions, for which he won the Nobel Prize in medicine, was invited to the roundtable. Notes from Dr. Prusiner's presentation on prions and prion diseases were presented to the roundtable by Dr. Thornsberry, who had attended one of Dr. Prusiner's lectures on prion diseases. Although unable to attend the roundtable, Dr. Prusiner provided the roundtable with five papers published in prestigious peer revientification of all imported animals was discussed during Dr. Keller's presentation.

Dr. Keller also discussed the need for a US individual animal identification program. It was stated that a voluntary system would become mandatory upon the discovery of one case of BSE in the United States. Current disease control programs for Brucellosis and Tuberculosis provide good trace back for mature cattle, but young cattle are often difficult to trace back to the farm of origin.

The round table was closed with a short discussion on the subject of acceptable risk. The odds of developing new variant CJD are very low. Less than 200 cases have been identified in all of Europe, where literally millions of cattle were slaughtered for BSE related reasons. The problem with new variant CJD lies with the lack of treatment success. Patients with nv CJD always die a slow, horrible death. Statistics mean very little to the patient with nv CJD. The chances of contracting nv CJD from eating beef from an animal with BSE the first exposure is very very low. The problem is related to how many exposures will be needed to cause conversion of a patient's normal prions into abnormal prions. Laboratory experience demonstrates the disease becomes more severe with subsequent transmissions and exposures. The best situation may be to test each animal and prevent any exposure to any level of abnormal prions.

The Prion Disease Roundtable was closed by Dr. Thornsberry after short discussion about SRM's and their current use in cattle feeds. Since the roundtable was conducted, the USDA has issued some restrictions on certain SRM's in ruminant feeds but has not enforced them to date. Since this Roundtable was conducted, prions have been identified in the muscle cells of sheep.


This summary was prepared by Dr. R. M. Thornsberry, D.V.M., moderator of the Prion Disease Roundtable. ...TSS

 

[flounder]

Preposterous

I believe that Secretary of Agriculture, Mike Johanns, is making a mistake that could be detrimental to cattle producers and beef consumers. The USDA wants the border with Canada open. It appears they will compromise all the past history of the Animal Plant Health Inspection Service to open the border with a known BSE infected country, no matter what the consequences to consumers and the beef cattle production system in the United States. Any country that has identified cases of BSE has suffered immensely. The presence of BSE in a given country decreases consumer confidence, causes disruption of export markets, and generally sows discord among the cattle production system of that specific country and its trading partners.

In Japan, the first case of BSE caused a 50 percent reduction in beef consumption, almost over night. By assuring consumers that no meat would be allowed into the system from animals that were not tested for BSE, or were of a specific age limit, the Japanese have recovered consumer confidence. They gained back that confidence by testing all animals at slaughter for BSE. The system worked, and the Japanese have identified many cases of BSE in cattle before the meat from those animals was allowed into the beef consumption system. By performing this testing, the Japanese have discovered a number of cases of BSE in their cattle population, with some cases identified to be under 30 months of age.

The Japanese have told the USDA that they will resume trade in beef with this country if we will only test the beef animals at slaughter, and like the Japanese system of testing, assure the Japanese consumers the meat originates from an animal that has tested free of BSE disease causing prions. That test is available. That test is accurate and can detect infectivity months before an animal begins exhibiting symptoms of BSE. That test costs less than $30.00 per animal tested. That test is utilized in many countries in Europe to assure consumers the beef they consume is safe. The USDA has refused to allow the use of the diagnostic test by any entity other than itself. Creekstone Farms, a high quality Certified Angus Beef purveyor, has told the USDA they will pay for the testing themselves, they will take the samples, they will submit the samples, they will manage the data, and they will provide the funds for all the costs of testing. To date, the USDA refuses to allow diagnostic testing for BSE at slaughter. The question is, why?

The USDA, the National Cattleman's Beef Association, and specifically, Secretary Mike Johanns, continues to tell Americans that BSE does not occur in animals under 30 months of age. That is a false statement!!! Research into the records of countries around the world that have the misfortune of identifying cases of BSE in their native cattle, reveals 88 cases in cattle that were 30 months of age or younger. In addition to the two recently diagnosed Japanese cases of BSE, Germany discovered two cases of BSE in cattle less than 30 months of age in 2001. While it is true that BSE is primarily a disease of older cattle, it is by no means correct to state that BSE does not occur in cattle younger than 30 months of age. It is disturbing to me, as a practicing veterinarian, that the USDA and other notable industry representatives like the National Cattleman's Beef Association, would continue to mislead the public and cattle producers by stating that BSE does not occur in cattle under 30 months of age. The known facts state otherwise.

There are those in the industry that believe it is time to negotiate with the USDA and compromise on the border issue. I do not believe any negotiating with the USDA is appropriate at this time. What would we negotiate? The USDA has gone blindly down the path of free trade and is willing to compromise our beef herd's health, our beef herd's economics, and the health of our human population by opening the border with a known BSE infected country before a live animal test is in place. I can think of no disease that veterinary specialists have eradicated successfully within the United States that was eradicated without a specific live animal test. It is true that specific risk mitigation procedures assist in eradication of diseases. Those risk mitigation procedures for BSE have been in place in Europe since 1998. In 2004, over 300 cases of BSE were identified in Great Britain alone. Obviously, risk mitigation procedures alone cannot eradicate a given disease condition in a given geographical area. This particularly applies to a disease like BSE, where the infective prion agent is nearly indestructible. The USDA knows that point quite well. I say again, what would the beef cattle industry compromise that the USDA has not already compromised to secure their free trade principles?

To eradicate a specific disease in a specific animal population, a live animal diagnostic test is important. The live animal test does not replace or supercede risk mitigation procedures, such as preventing the feeding of ruminant derived meat and bone meal to ruminant animals, but it does work hand in hand with those, and other, risk mitigation procedures to determine the disease dynamics in a given population of at-risk animals. There are presently three laboratories working on a live animal test, including Dr. Stanley Pruisner's laboratory in California. It is Dr. Pruisner's laboratory that discovered the actual agent that causes BSE, a misshapen protein called a prion. Dr. Pruisner's people tell me a live animal test is close. We have an acceptable filter for blood to filter out prions in blood transfusions. How long can it be before we can test for the prions on that filter? Surveillance is a very important part of any epidemiological system, but without a live animal test, disease eradication is much more difficult. Once the live animal test is available, the issue of animal import into the United States becomes simpler. In any disease condition, two live animal tests are usually required, at a predetermined time period, before that animal or group of animals is regarded as disease free. At the least, a live animal test would allow government agencies to identify those herds that are currently infected. Although a live animal test is not the only determining factor in disease eradication, it certainly assists in speeding up the process.

In a submission to the Food and Drug Administration on August 13, 2004, a group of three scientists that study Transmissible Spongiform Encephalopathy diseases, like BSE in cattle, Scrapie in sheep and goats, and Chronic Wasting Disease in deer and elk, have made the following statement on page 2 of that submission, and I quote: "…we do not see how this can be accomplished credibly without universal testing. Without sound data on the actual prevalence of the infection it will not be possible to track the effectiveness of any control measures that are implemented." I agree fully with this statement.

The FDA has prohibitions in place to prevent any person that has lived or spent considerable time in a BSE infected country, from giving blood. Blood transfusions are known to have spread the disease in two cases in Europe, yet, the USDA wants to allow Canadian animals under 30 months of age to cross the border, be slaughtered in US plants, allow their blood to go into our blood meal and meat and bone meal, and allow our citizens to consume the beef from those animals without any kind of diagnostic testing, either before or after slaughter. That is a paradox of standards. There are 88 known cases of BSE diagnosed in cattle 30 months of age and younger, world wide. The USDA wants to allow cattle 30 months of age and younger, from a country known to be infected with BSE, to enter our meat production system without any form of diagnostic testing. I find that preposterous!!!

I also find it preposterous that notable livestock and farm organizations are rabidly calling on our government to open the border with a known BSE infected country before a means to identify BSE positive animals is available. It is known to countries that have already experienced nearly a decade of BSE, that cattle can carry the infective agent that causes BSE before that animal exhibits symptoms of the disease to the point a veterinarian might suspect the animal was infected. That simply means, that without a live animal diagnostic test, potentially BSE infected animals, even those under 30 months of age, could enter our meat production system, appear perfectly normal, but in the process of slaughtering and processing, spread the infective prions into the meat slaughter facility.

With testing, it would be possible to identify the positive animals before the carcass was processed, thus preventing the hypothetical situation discussed previously. The USDA's primary responsibility is to protect the health and well being of the human population of this great country. Its second primary responsibility is to protect the health and well being of the animal population of this great country. Advocating for the opening of the border with a known BSE infected country without a diagnostic plan is not the method to accomplish either of those responsibilities. I think it is time the USDA left free trade issues to the State Department, and took their primary responsibilities seriously.

I do not want to frighten beef consumers. There has never been a case of BSE discovered in a native-born beef animal within the United States, and under our current regulations, the U.S. has implemented significant safety measures to prevent BSE introduction and spread. Nearly 350,000 animals born, bred, and raised in the USA have been tested for BSE. These animals were all either exhibiting some form of neurological disease or were animals that could not rise on their feet without assistance, or were otherwise dead, distressed, or dying. Most of these animals were advanced in age and were from that portion of the population dynamic that most often would exhibit a positive test to BSE. None of those 350,000 animals tested positive for BSE. By contrast, Canada has tested nearly 50,000 of the same class of animals, but the Canadians have discovered 4 indigenous cases of BSE. That is about one case for every 12,000 animals tested. What is the actual incidence of BSE in the cattle population of Canada? To date, that is an unanswered question. If the incidence is 1 in 12,000, then the possibility of receiving a BSE prion shedding animal from Canada is a real risk. Not a great risk, but a real risk.

Without a means to identify foreign beef within the United States, consumers do not have the choice to refuse to serve Canadian beef to their families. Canadian beef is entering the United States at rates nearly as high as before the first case of BSE was identified in May of 2003. That Canadian meat is boxed in Canada and sent across our border to restaurants and grocery stores in the United States. Congress enacted a Country of Origin Labeling law that was to go into effect this year. That law, through politically maneuvering, has been effectively emasculated, and has never been implemented.

I would urge beef consumers to write or telephone their US legislators and ask them to implement the County of Origin Labeling law already passed by Congress. It will give you a choice. If the USDA has its way, the United States will be forced to take beef from a number of countries that have BSE, not just Canada.

I say all that to say this. We should work with Canada to eradicate BSE where it is known to exist. A live animal test is a very important tool for this eradication process, but it is not the only tool. Continued surveillance should be mandatory, and conducted at high levels. A strengthened feed ban to prevent the possibility of recycling the BSE infective agent should be implemented. Preventing the movement of the infective, nearly indestructible BSE prions, is essential. Opening borders to free trade without diagnostic testing is an invitation to disaster. I, for one, do not want to be a part of that disaster.

R-CALF-USA continues to stand up for the beef cattle producers in the United States and Canada. A number of Canadian producers have filed a lawsuit against their own government for not enacting stricter guidelines to control BSE within Canada once BSE was discovered in their country. I believe they are correct in that endeavor. R-CALF does not dislike Canadian cattle or Canadian cattle producers. R-CALF hates BSE and its devastating effects on beef cattle production systems. Let us work with R-CALF to accomplish a common goal: The eradication of BSE where it is known to exist and the prevention of the spread of BSE to BSE free countries.

R. M. Thornsberry, D.V.M., M.B.A.


TSS

 

[flounder]

Perplexed by the USDA

I am perplexed by the United States Department of Agriculture, Animal and Plant Health Inspection Service (APHIS). At Cattlemen's Day, in Billings, Montana, on November 13, 2004, Dr. Jose Diez, Director Western Region, Veterinary Services, made a presentation to the Montana Cattlemen's Association concerning the Bovine Spongiform Encephalopathy (BSE-Mad Cow Disease) situation in the United States and Canada. Dr. Diez told the large group of cattlemen, cattlewomen, press, including press from Japan, and four practicing veterinarians, that the USDA was pursuing a "Risk Based Trade" with Canada.

This Risk Based Trade is actually an attempt to negotiate down guidelines set in place by the Office of International Epizootics (OIE). The OIE is an international group of scientists and veterinarians that set guidelines and regulations that attempt to control and limit the spread of diseases that could potentially spread from animals to humans. The OIE has very specific guidelines concerning countries that have had BSE identified within their borders. Countries that have identified natural cases of BSE, but have not completed at least 7 years of Risk Assessment, are classified as BSE Moderate Risk Countries. Since BSE is a disease with an extremely long incubation period, the 7-year waiting period is utilized to protect a BSE free country from receiving animals from a known infected country that could be harboring the disease. Potentially infected cattle could be exhibiting no symptoms of BSE, but could be incubating the disease while shedding the infective agent.

The OIE issued these complex guidelines in response to a severe outbreak of BSE in Europe, which resulted in the death or destruction of several million head of cattle. The object of the OIE guidelines is to contain the prions that cause BSE in a known geographical location and prevent their contamination to areas known to be free of BSE, while establishing guidelines for future trade in live cattle and beef. Canada is a country with five known cases of BSE: One case in the early 1990's, one case in May 2003, and one case in December 2003. Two more cases have been identified in 2004 and early 2005. Although the number of known cases is small, Canada is classified as a BSE infected country, either with Moderate or High Risk. Prions that cause BSE have potentially contaminated areas of the country of Canada. These prions probably made their way to Canada in cattle imported from Europe in the 1980's and early 1990's. Several head of cattle were imported into Canada during the hottest period of the European BSE epidemic. Fortunately, the United States did not import many cattle from Europe. The United States was capable of identifying the few head that were imported from Europe and destroyed those cattle quickly or studied them until their natural death. Canada has a much closer trading relationship with Europe, and as a result, has reaped the harvest.

Knowing all this, the USDA has taken a leading role in discussions with other countries to lower the standards of classification for medium and low risk BSE infected countries. In other words, instead of following closely the guidelines and regulations that have kept BSE out of the United States in the past, the USDA has proposed a new set of guidelines that would shorten the BSE code allowing three new classifications, based on what they term as acceptable risk. The process is designed to allow Canadian beef and live cattle into the United States without satisfying the 7-year waiting period. The USDA has determined that the risk of spreading BSE to the United States is minimal. In addition, the USDA has determined that the risk of spreading BSE into the United States is acceptable. This means they recognize the possibility of spreading BSE into the United States exists, but they believe the USDA proposed rules for dealing with Specified Risk Materials, such as bovine meat and bone meal, will contain it.

If this disease were Brucellosis, Tuberculosis, or Foot and Mouth Disease, the USDA would require several years of negative tests before allowing cattle into the US from Canada. Even within the United States itself, a state cannot be considered Brucellosis free until it has satisfied a rigorous series of tests, and several years of no reported cases. If Brucellosis was known to exist in a state, cattle would have to be tested negative before interstate movement would be allowed. In most cases, another test would be required on live animals 60 to 90 days later, and then again at 1 year. In the case of BSE and Canada, the USDA wants to reclassify Canada as a country with Proposed Negligible BSE Risk or Proposed Controlled BSE Risk. This decision is based on Canada's proposed control program. Remember that Canada discovered a case of BSE in a cow in May of 2003. After convincing the USDA that control measures were adequate, the USDA reopened trade in beef with Canada. Then another case was identified in a Canadian cow in December of 2003, which had been exported into the State of Washington. When this second case in 2003 was discovered, the USDA was supposed to shut off all beef trade with Canada until new trading rules had been established. They failed to do so.

Surveillance is an important measure for determining if a particular disease contaminates a given population of cattle. The United States has tested nearly 130,000 cattle since January 1, 2004 for BSE, and has plans to test over 200,000 higher risk animals. No positive cases have been identified. During the same time period, Canada has tested less than 10,000 head of high-risk cattle. Several countries have pressured Canada to step up surveillance. Only recently has Canada issued press releases stating the country intends to step up surveillance in 2005. In those press releases, the Canadian Agricultural officials state they expect to find more cases of BSE in Canada. If that is the case, why would the USDA be attempting to get the border open and risk contamination of US soil with BSE prions? Even if a natural case of BSE was identified within the borders of the Untied States, why would the USDA be willing to allow additional cases to enter the US from Canada? Let's put out one fire at a time, thank you.

The prions that cause BSE are basically indestructible. Research has determined that Scrapie prions buried for three years are still capable of causing disease when injected into laboratory animals. Cattle with BSE could potentially shed prions in their feces, nasal discharges, saliva, and reproductive discharges. Mirror image diseases, like Scrapie in sheep and goats and Chronic Wasting Disease in deer and elk, have been identified to spread prions to negative sheep, goats, deer, and elk by these bodily discharges. These prions could contaminate soil in paddocks, lots, feeding pens, and pastures. In Europe, it has been demonstrated that less than one intake of 10 milligrams of neural tissue can spread Mad Cow Disease from one animal to another. That is why keeping meat and bone meal out of cattle diets is so very important. Prions are ingested and replicate in lymphatic tissues in the intestinal tract before making their way to the central nervous system. There they cause the destruction of brain tissue, which results in the typical symptoms of Mad Cow Disease. The truly scary thing about all this is new variant Creutzfeldt Jakob Disease (nvCJD). The prions that cause BSE are the same prions that cause nvCJD. Although the most common mode of infection is oral ingestion of contaminated beef or beef byproducts, prions in the environment are considered biological hazards by many governments and research facilities. Patients that ingest BSE prions and develop nvCJD die a horrible death. There is no treatment for BSE or nvCJD. Dr. Stanley Prusiner, the medical researcher who discovered and identified the structure of BSE prions, has told the USDA that any exposure to BSE prions is potentially dangerous. Although consumers cannot consume enough prions to cause BSE, the prions they do consume may trigger an irreversible conversion process that converts normal cellular prions into the prions that cause nvCJD. Dr. Prusiner does not know how many exposures it takes to cause this conversion process, but some individuals with a particular genetic code are known to be extremely susceptible to developing nvCJD.

It is the mandate of USDA APHIS to protect the health of cattle and livestock within the borders of the United States. It is not their mandate to lower the standards so Canada may export cattle into the US. If this was any other disease that had three cases identified within the last 10 years, one case less than 12 months ago, the USDA would not consider allowing possibly infected cattle to cross the border into the United States. As a veterinarian I have been trained to assist the USDA in maintaining the health of the US cattle population. I have been accredited by APHIS to assist in disease control, cattle testing, and containment of disease outbreaks. I would have never guessed that USDA APHIS would be considering "Risk Based Trade". The risk is there, and it is not acceptable. The answer to the Canadian BSE problem cannot be found by potentially spreading the disease into the United States. Let's solve this disease problem in one country at a time.

Researchers are feverishly working to develop a live animal test to identify cattle carrying BSE prions. Why not wait a few months, or even a few years, until this test is available? Once Canada has performed the proper surveillance and satisfied OIE guidelines, then test each animal being imported. If the animal is negative, permanently identify the animal when it enters the US, and continue surveillance until the animal dies or is slaughtered. This method would reduce the risk of introduction of BSE prions into the United States to a minimum. At the least, proper identification would allow for trace back, slaughter of exposed animals, and control of a potentially dangerous disease.

In Europe and Japan, BSE is being identified in younger and younger animals. Mad Cow Disease prions apparently become more virulent when they are passed down to successive generations. Countries all over Europe are currently identifying new cases of BSE, even though those countries have not fed any meat and bone meal since the early 1990's. Early cases were identified in older animals. Presently, 2 or 3 generations removed, cases are being identified in animals less than 2 years of age. At least one case has even been identified in an animal less than one year of age. This phenomenon is consistent with what researchers have discovered about BSE in laboratory animals. As the disease is transferred down several generations, the incubation period becomes shorter.

No one has given an acceptable explanation as to how cattle are being exposed to BSE prions in countries where the feeding of meat and bone meal has been outlawed for over 15 years!!! The unfortunate victims of BSE are coming into contact with the prions somewhere. Knowing the fact that prions are indestructible, knowing the fact that prions may seed down the environment, knowing there is no method of satisfactory disinfection for BSE prions, and knowing there is no treatment for animals that contract BSE, why would the USDA consider allowing such a horrendous disease to enter the United States of America? The real answer will surprise you:

1) The USDA subscribes to the idea that BSE can arise in a particular population of cattle spontaneously. In other words, the USDA believes BSE may, in fact, already infect cattle in the United States through the process of spontaneous generation of the abnormal prions that cause BSE. I have heard with my own ears this theory espoused by a USDA veterinarian at the January 2003 annual Kansas Cattlemen's Association convention at Dodge City, Kansas. This USDA veterinarian even expressed his view that the US may have exported BSE to Canada in the early 1990's with the exportation of US meat and bone meal to the Canadian feed industry.
2) The USDA has determined that the US beef cattle industry is part of a North American system. Beef cattle in Canada, the United States, and Mexico are all part of one big integrated system. Chandler Keys, a National Cattlemen's Association spokesman has stated this concept in this manner, and I quote, "It's a good lesson for all of us," said Keys. "We've got to strive to work together. We're a North American system." The last time I looked, no Canadian has offered to pay my income taxes, property taxes, or veterinary inspection fees. When I called the Canadian Embassy and asked about exporting cattle from Missouri to Alberta, I was told Canada would not accept cattle from Missouri because of the possibility of Missouri cattle being infected with Blue Tongue and Anaplasmosis. So much for a North American cattle industry.
3) The USDA is convinced that by boning out meat and removing certain Specified Risk Materials (brain, spinal chord, lymph nodes, ileum, etc), the risk of spreading BSE prions is minimal. This may well be an acceptable method to reduce spread of BSE prions associated with raw meat, but what about live cattle? Live cattle harboring BSE prions, like live deer and elk that harbor Chronic Wasting Disease prions, shed BSE prions into their environment and may take months or years to actually die of this dread disease. Italy, England, Ireland, and Spain all have discovered many new cases of BSE in live cattle during this past year. They have had control measures in place since the late 1980's and early 1990's. Japan continues to discover new cases of BSE in younger and younger animals. We cannot afford to have consumer confidence in beef potentially undermined by continually finding new, and unexplained, cases of BSE in the United States.

As a practicing veterinarian who has taken an oath to protect the health of humans and the animals that feed, clothe, and provide emotional comfort for humans, I am disturbed that the agency charged with protecting the United States cattle industry seems to have their judgment swayed by free trade issues. In the past, both Canada and the United States have maintained the hard line of no trade in beef with any country that has identified a case of Mad Cow Disease, even to the point of prohibiting importation of embryo's or semen from a country with a known natural case of BSE. This hard line of defense has kept BSE out of the United States. I cannot understand why this line of defense, which has served the United States so well, should be relaxed before a live animal test has been developed to identify BSE positive cattle. Relaxing such standards may result in the same circumstances that Europe and Japan find themselves in currently. I have just attended a day-long seminar on Epizootic Diseases conducted by the USDA and the Missouri Department of Agriculture and the Missouri Department of Health. Mad Cow Disease has been identified as a political disease. Where countries with Foot and Mouth Disease virus cases are prevented to trade with the United States, countries with Mad Cow Disease (BSE) will be allowed to trade with the United States. Canada is not the only BSE positive country that wants to trade with the United States. When this Pandora's Box is opened, the United States will be required to receive beef and live animals from any BSE positive country that has satisfied the new OIE qualifications. Basically, any country that can prove it has developed a satisfactory BSE control program will be allowed to export beef into the United States.

I know that I am not the only perplexed practicing veterinarian in the United States. Our education and training have not prepared us to understand a political disease. Canada has been forbidden to trade beef with most of her former trading partners except Mexico. There is no doubt that Canada has suffered immensely because of BSE. Because the USDA APHIS failed to announce that the positive cow in December 2003 was a Canadian cow, all of the US trading partners have forbidden beef trade. By not announcing that fact immediately, our trading partners consolidated their resistance to trade with the United States. That trade has not resumed, and opening the border to a know BSE infected country will not improve those severed trade relationships. Thus, the desire by the USDA to reclassify OIE guidelines, and reclassify Canada as a Moderate to Minimal Risk BSE country. Go figure!!!


TSS


[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

03-025IFA
03-025IFA-2
Terry S. Singeltary


Page 1 of 17

From: Terry S. Singeltary Sr. [[email protected]]

Sent: Thursday, September 08, 2005 6:17 PM

To: [email protected].

Subject: [Docket No. 03-025IFA] FSIS Prohibition of the Use of Specified Risk Materials for Human Food and Requirements

for the Disposition of Non-Ambulatory Disabled Cattle

Greetings FSIS,

I would kindly like to submit the following to [Docket No. 03-025IFA] FSIS Prohibition of the Use of Specified Risk Materials for Human Food and

Requirements for the Disposition of Non-Ambulatory Disabled Cattle

THE BSE/TSE SUB CLINICAL Non-Ambulatory Disabled Cattle

Broken bones and such may be the first signs of a sub clinical BSE/TSE Non-Ambulatory Disabled Cattle ;

snip...FULL TEXT ;


http://www.fsis.usda.gov/OPPDE/Comments/03-025IFA/03-025IFA-2.pdf


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



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

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

OLD TSS SUBMISSIONS;



Docket No, 04-047-l Regulatory Identification No. (RIN) 091O-AF46 NEW BSE SAFEGUARDS (comment submission)

https://web01.aphis.usda.gov/regpublic.nsf/0/eff9eff1f7c5cf2b87256ecf000df08d?OpenDocument


Docket No. 03-080-1 -- USDA ISSUES PROPOSED RULE TO ALLOW LIVE ANIMAL
IMPORTS FROM CANADA


https://web01.aphis.usda.gov/BSEcom.nsf/0/b78ba677e2b0c12185256dd300649f9d?OpenDocument&AutoFramed


Docket No. 2003N-0312 Animal Feed Safety System [TSS SUBMISSION]

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

Docket Management Docket: 02N-0273 - Substances Prohibited From Use in

Animal Food or Feed; Animal Proteins Prohibited in Ruminant Feed

Comment Number: EC -10

Accepted - Volume 2


http://www.fda.gov/ohrms/dockets/dailys/03/Jan03/012403/8004be07.html



PART 2


http://www.fda.gov/ohrms/dockets/dailys/03/Jan03/012403/8004be09.html



PDF]Freas, William TSS SUBMISSION

File Format: PDF/Adobe Acrobat -

Page 1. J Freas, William From: Sent: To: Subject: Terry S. Singeltary

Sr. [[email protected]] Monday, January 08,200l 3:03 PM freas ...



http://www.fda.gov/ohrms/dockets/ac/01/slides/3681s2_09.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



Docket Management Docket: 96N-0417 - Current Good Manufacturing Practice
in Manufacturing, Packing, or Holding Dietary Ingredients a
Comment Number: EC -2
Accepted - Volume 7

http://www.fda.gov/ohrms/dockets/dailys/03/Mar03/031403/96N-0417-EC-2.htm


[PDF] Appendices to PL107-9 Inter-agency Working Group Final Report 1-1
File Format: PDF/Adobe Acrobat - View as HTML
Agent, Weapons of Mass Destruction Operations Unit Federal Bureau of
those who provided comments in response to Docket No. ...
Meager 8/18/01 Terry S. Singeltary Sr ...


http://www.aphis.usda.gov/lpa/pubs/pubs/PL107-9_Appen.pdf

Docket No. 2003N-0312 Animal Feed Safety System [TSS SUBMISSION
TO DOCKET 2003N-0312]

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

# Docket No: 02-088-1 RE-Agricultural Bioterrorism Protection Act of
2002; [TSS SUBMISSION ON POTENTIAL FOR BSE/TSE & FMD 'SUITCASE BOMBS'] -
TSS 1/27/03 (0)

Docket Management

Docket: 02N-0276 - Bioterrorism Preparedness; Registration of Food Facilities, Section 305
Comment Number: EC-254 [TSS SUBMISSION]

http://www.fda.gov/ohrms/dockets/dockets/02n0276/02N-0276-EC-254.htm


Dockets Entered On October 2, 2003 Table of Contents, Docket #,
Title, 1978N-0301,

OTC External Analgesic Drug Products, ... EMC 7, Terry S. Singeltary Sr.
Vol #: 1, ...

http://www.fda.gov/ohrms/dockets/dailys/03/oct03/100203/100203.htm


Daily Dockets Entered on 02/05/03

DOCKETS ENTERED on 2/5/03. ... EMC 4 Terry S. Singeltary Sr. Vol#: 2.
... Vol#: 1.

03N-0009 Federal Preemption of State & Local Medical Device Requireme. ...


http://www.fda.gov/ohrms/dockets/dailys/03/Feb03/020503/020503.htm


Docket Management

Docket: 02N-0370 - Neurological Devices; Classification of Human Dura Mater

Comment Number: EC -1

Accepted - Volume 1


http://www.fda.gov/ohrms/dockets/dailys/03/Jan03/012403/8004be11.html


http://www.fda.gov/ohrms/dockets/dailys/03/Jan03/012403/8004bdfe.html


http://www.fda.gov/ohrms/dockets/dailys/03/Jan03/012403/8004bdfc.html


Daily Dockets - 04/10/03

... 00D-1662 Use of Xenotransplantation Products in Humans.
EMC 98 Terry S. Singeltary Sr. Vol#: 3. 01F ...
http://www.fda.gov/ohrms/dockets/dailys/03/Apr03/041003/041003.htm - 05-20-2003
- Cached


2003D-0186
Guidance for Industry: Use of Material From Deer and Elk In Animal Feed




EMC 1
Terry S. Singeltary Sr.
Vol #:
1

http://www.fda.gov/ohrms/dockets/dailys/03/Jun03/060903/060903.htm


2003D-0186
Guidance for Industry: Use of Material From Deer and Elk In Animal Feed


EMC 7
Terry S. Singeltary Sr.
Vol #:
1

2003D-0186
Guidance for Industry: Use of Material From Deer and Elk In Animal Feed


EMC 7
Terry S. Singeltary Sr.
Vol #:
1


http://www.fda.gov/ohrms/dockets/dailys/03/oct03/100203/100203.htm

01N-0423 Substances Prohibited from use in animal food/Feed Ruminant

APE 5 National Renderers Association, Inc. Vol#: 2

APE 6 Animal Protein Producers Industry Vol#: 2

APE 7 Darling International Inc. Vol#: 2

EMC 1 Terry S. Singeltary Sr. Vol#: 3

http://www.fda.gov/ohrms/dockets/dailys/01/Oct01/101501/101501.htm

Send Post-Publication Peer Review to journal:


Re: RE-Monitoring the occurrence of emerging forms of Creutzfeldt-Jakob

disease in the United States


Email Terry S. Singeltary:


[email protected]



I lost my mother to hvCJD (Heidenhain Variant CJD). I would like to

comment on the CDC's attempts to monitor the occurrence of emerging

forms of CJD. Asante, Collinge et al [1] have reported 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. However, CJD and all human TSEs are not reportable

nationally. CJD and all human TSEs must be made reportable in every

state and internationally. I hope that the CDC does not continue to

expect us to still believe that the 85%+ of all CJD cases which are

sporadic are all spontaneous, without route/source. We have many TSEs in

the USA in both animal and man. CWD in deer/elk is spreading rapidly and

CWD does transmit to mink, ferret, cattle, and squirrel monkey by

intracerebral inoculation. With the known incubation periods in other

TSEs, oral transmission studies of CWD may take much longer. Every

victim/family of CJD/TSEs should be asked about route and source of this

agent. To prolong this will only spread the agent and needlessly expose

others. In light of the findings of Asante and Collinge et al, there

should be drastic measures to safeguard the medical and surgical arena

from sporadic CJDs and all human TSEs. I only ponder how many sporadic

CJDs in the USA are type 2 PrPSc?


http://www.neurology.org/cgi/eletters/60/2/176#535

 

[Sandhusker]

Very good post, Flounder.

 

[Anonymous]

Does none of the NCBA members have an opinion on this USDA dropping all the rules & the safeguards that were instituted to protect the US cattle herd and consumers :???: .....

Or are we all waiting for the Packers to tell the NCBA leadership what their opinion should be ?

Darn sure has created a stir in this part of the country- NCBA closer to being ruled an endangered species!!!!!

 

[Econ101]

What do the packers care? They will sell more chicken and pork at higher prices. NCBA is selling out this industry to the packers. Will not let anyone else but USDA test for BSE. So much for transparency and safety.

 

[Sandhusker]

Haven't heard a word from the USDA crew, either.

What's up, SH?

 

[Silver]

Canada is not the only BSE positive country that wants to trade with the United States. When this Pandora's Box is opened, the United States will be required to receive beef and live animals from any BSE positive country that has satisfied the new OIE qualifications. Basically, any country that can prove it has developed a satisfactory BSE control program will be allowed to export beef into the United States.

hm. And at the same time the US expects other countries (Canada included) to take their beef. In fact the US somehow managed to FORCE Japan to take it's beef. hmmmmmmm......

 

[frenchie]

Canada is not the only BSE positive country that wants to trade with the United States. When this Pandora's Box is opened, the United States will be required to receive beef and live animals from any BSE positive country that has satisfied the new OIE qualifications. Basically, any country that can prove it has developed a satisfactory BSE control program will be allowed to export beef into the United States.

hm. And at the same time the US expects other countries (Canada included) to take their beef. In fact the US somehow managed to FORCE Japan to take it's beef. hmmmmmmm......

I quess they forget, the U.S is B.S.E positive too :lol:

 

[Sandhusker]

Come on Silver and Frenchie, this is a story about the USDA again reversing their own policies and subjecting us to product that can't even be sold in the country where it is produced! The USDA has us taking untested beef from a country that is virtually finding a case a month, and that is your post?

 

[Silver]

Come on Silver and Frenchie, this is a story about the USDA again reversing their own policies and subjecting us to product that can't even be sold in the country where it is produced! The USDA has us taking untested beef from a country that is virtually finding a case a month, and that is your post?

:roll: Oh, and here I thought it was a post whining about how it isn't fair thats what's sauce for the goose is sauce for the gander. About how some people percieve US beef as somehow safer than everyone elses. Oh, and about how the evil USDA is just out for the allmighty dollar. (I hadn't realized they are a 'for profit' organization')

 

[Sandhusker]

Come on Silver and Frenchie, this is a story about the USDA again reversing their own policies and subjecting us to product that can't even be sold in the country where it is produced! The USDA has us taking untested beef from a country that is virtually finding a case a month, and that is your post?

:roll: Oh, and here I thought it was a post whining about how it isn't fair thats what's sauce for the goose is sauce for the gander. About how some people percieve US beef as somehow safer than everyone elses. Oh, and about how the evil USDA is just out for the allmighty dollar. (I hadn't realized they are a 'for profit' organization')

So why the plan to take Japanese beef, for health?

 

[Silver]

Come on Silver and Frenchie, this is a story about the USDA again reversing their own policies and subjecting us to product that can't even be sold in the country where it is produced! The USDA has us taking untested beef from a country that is virtually finding a case a month, and that is your post?

:roll: Oh, and here I thought it was a post whining about how it isn't fair thats what's sauce for the goose is sauce for the gander. About how some people percieve US beef as somehow safer than everyone elses. Oh, and about how the evil USDA is just out for the allmighty dollar. (I hadn't realized they are a 'for profit' organization')

So why the plan to take Japanese beef, for health?

Well, if health is the REAL issue (which I doubt), Japanese beef is arguably far safer than US or Canadian beef. They actually know their incidence of BSE.

 

[frenchie]

:roll: Oh, and here I thought it was a post whining about how it isn't fair thats what's sauce for the goose is sauce for the gander. About how some people percieve US beef as somehow safer than everyone elses. Oh, and about how the evil USDA is just out for the allmighty dollar. (I hadn't realized they are a 'for profit' organization')

So why the plan to take Japanese beef, for health?

Well, if health is the REAL issue (which I doubt), Japanese beef is arguably far safer than US or Canadian beef. They actually know their incidence of BSE.

I quess thats what happens if you actually look for it