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From: TSS ()
Technical Service Center Technical Assistance/Correlation Division (TAC) http://www.fsis.usda.gov/About_FSIS/Technical_Service_Center/index.asp i am trying to refrain in the new year, from having any opinion at all, one of a few of my new years resolutions. just go with the flow i suppose. the wife is estatic about it, her mom and dad have a bet. i even plan to expand this into my ongoing search for answers into TSE. so if i become boring, it's because i have no opinion on anything, however, i suppose it does not hurt to ponder. i only ponder why they have ignored there own science there at USDA for all these years ; pdf 30kb 03-025IFA From: Terry S. Singeltary Sr. [flounder9@verizon.net] Sent: Thursday, September 08, 2005 6:17 PM To: fsis.regulationscomments@fsis.usda.gov 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 ; Docket No, 04-047-l Regulatory Identification No. (RIN) 091O-AF46 NEW BSE SAFEGUARDS (comment submission) > October 1998 > 7.2.1.7 Laboratory Coordination--The Laboratory Coordination Officer > BSE Red Book 2.1-39 > BSE Red Book 2.1-40 > 7.7.3 Rendering snip... > 7.10.11 Prevention--Suspects and animals confirmed to have BSE must not If additional tests do suggest a snip... http://www.fda.gov/bbs/topics/news/2004/NEW01061.html snip... snip... http://www.aphis.usda.gov/lpa/news/2005/07/bsestatement_vs.html "Because of the conflicting results on the IHC and Western blot tests, a sample from this animal will be sent to the OIE-recognized reference laboratory for BSE in Weybridge, England. USDA will also be conducting further testing, which will take several days to complete. http://www.usda.gov/wps/portal/!ut/p/_s.7_0_A/7_0_1OB?contentidonly=true&contentid=2005/06/0206.xml "Today, an official with USDA's National Veterinary Services Laboratory departed for Weybridge, England, hand-carrying samples for further testing. "On June 10 I learned that test was reactive and shared those results at that time. "We now have the test results from the lab in Weybridge, England, as well as the results from additional testing in our own lab, and again I am here today to share those results with you. "The results confirm the presence of BSE in this animal, an animal that was blocked from entering the food supply thanks to the firewalls that are in place. It is critically important to note that this animal was identified as a high risk animal. A sample was taken, and the carcass was incinerated. http://www.usda.gov/wps/portal/!ut/p/_s.7_0_A/7_0_1OB?contentidonly=true&contentid=2005/06/0233.xml 06/09/05 http://www.aphis.usda.gov/lpa/issues/bse/BSE_roundtable_6_9_05.pdf NOW, let us look at another BSE ROUNDTABLE DISCUSSION by USDA et al in the year 2003, please note the BSE science on IHC testing then, and then compare to now, and then ponder those other 9,200 cattle of the infamous June 2004 BSE cover-up program, that did not have rapid testing or WB, just IHC, the lease likely to find BSE/TSE ; We have to be careful that we don't get so set in the way we do things that Dr. Detwiler: That's on the slaughter. But on the clinical cases, aren't Dr. Keller: Tissues are routinely tested, based on which tissue provides an Dr. Detwiler: That's on the slaughter. But on the clinical cases, aren't 2005 The BSE enhanced surveillance program involves the use of a rapid screening test, followed by confirmatory testing for any samples that come back "inconclusive." The weekly summary below captures all rapid tests conducted as part of the enhanced surveillance effort. It should be noted that since the enhanced surveillance program began, USDA has also conducted approximately 9,200 routine IHC tests on samples that did not first undergo rapid testing. http://www.aphis.usda.gov/lpa/issues/bse_testing/test_results.html Office of Inspector General OIG Semiannual Report to Congress FY - 2005 - First Half snip... Strengthen Controls Over Canadian Beef Imports Following the detection of a Canadian cow with bovine spongiform encephalopathy (BSE or “mad cow disease”) in May 2003, we examined the Animal and Plant Health Inspection Service’s (APHIS) oversight of the importation of beef products from Canada. Following requests from four U.S. Senators, we began several reviews in June 2004 to explore whether USDA did not follow appropriate safety measures, beginning sometime in the fall of 2003, in allowing expanded Canadian beef imports into the United States. After the initial halt of imports, in August 2003 the Secretary announced a list of low-risk products that would be allowed from Canada. APHIS also allowed an expansion in the type of Canadian facilities that could produce items for export to the United States. The gradual expansion occurred because agency employees included products similar to those on the published lowrisk list, but APHIS did not communicate this broadly. As a result, from August 2003 to April 2004, APHIS issued permits for products with questionable eligibility. Contrary to publicly stated policy, the agency allowed the import of products from Canadian facilities that produced both eligible and ineligible products, increasing the possibility that higher-risk product could be inadvertently imported. APHIS also issued permits to allow the import of more than 63,000 pounds of beef cheek meat with questionable eligibility because the agency did not establish a clear definition for “boneless beef.” Further, we found that FSIS did not always communicate effectively about the eligibility status of beef cheek meat, specifically to import inspectors. In addition, APHIS issued 1,155 permits for the importation of ruminant (e.g., cow, goat) products from Canada without ensuring that the agency had an appropriate system of internal controls to manage the process for a suddenly overwhelming volume of requests. From May through September 2004, we identified more than 42,000 pounds of product with questionable eligibility. APHIS generally agreed to institute procedures for communicating changes in policy and monitoring the consistency between agency practice and publicly stated policy, as well as to strengthen controls and finalize procedures to issue and monitor permits. FSIS generally agreed to implement controls to communicate the specific eligibility of product when its eligibility status changes and to implement an edit check in its import information system to identify ineligible product. (Audit Report No. 33601-1-Hy, APHIS Oversight of the Importation of Beef Products from Canada) from Japan, Importation of Which Is Prohibited Due to Disease Concerns In January 2005, a Los Angeles restaurant owner was placed on probation for 60 months, to include 800 hours of community service, after he pled guilty to smuggling beef from Japan. Under 9 Code of Federal Regulations (C.F.R.) § 94, beef from Japan is a prohibited product for United States importation due to disease. On two occasions in 2001 and 2002, inspectors in Anchorage, Alaska, intercepted shipments sent from Japan that were manifested as “book,” but upon inspection by USDA and the United States Customs Service, were found to contain approximately 25 kilograms of beef inside a Styrofoam ice chest. Both shipments were addressed to the restaurant owner. Shipping records showed that the restaurant owner had received 13 shipments manifested as “book” from the same sender in Japan in 2001 and 2002. All but one of the shipments were in the same weight range as the two intercepted shipments. The shipper and the restaurant owner were subsequently indicted for various charges including conspiracy and smuggling. An arrest warrant was issued for the shipper, who is still in Japan. http://www.usda.gov/oig/webdocs/SarcFirstHalf05.pdf Working Group Report on the Assessment of the Geographical BSE-Risk (GBR) of CANADA 2004 snip... - 2 - 2. EXTERNAL CHALLENGES 2.1 Import of cattle from BSE-Risk2 countries An overview of the data on live cattle imports is presented in table 1 and is based on data as provided in the country dossier (CD) and corresponding data on relevant exports as available from BSE risk countries that exported to Canada. Only data from risk periods are indicated, i.e. those periods when exports from a BSE risk country already represented an external challenge, according to the SSC opinion on the GBR (SSC July 2000 and updated January 2002). • According to the CD, 231 cattle were imported from UK during the years 1980 to 1990 and no cattle imports from UK were recorded after 1990. • According to Eurostat, altogether 198 cattle have been imported from the UK during the years 1980 to 1990, Additionally 500 were recorded in 1993; this import is 1 For the purpose of the GBR assessment the abbreviation "MBM" refers to rendering products, in particular the commodities Meat and Bone Meal as such; Meat Meal; Bone Meal; and Greaves. With regard to imports it refers to the customs code 230110 "flours, meals and pellets, made from meat or offal, not fit for human 2 BSE-Risk countries are all countries already assessed as GBR III or IV or with at least one confirmed Annex to the EFSA Scientific Report (2004) 2, 1-14 on the Assessment of the Geographical BSE Risk of Canada - 3 - mentioned in Eurostat and the updated UK export statistic as male calves, but not mentioned in the original UK export statistics. According to the CD, detailed investigations were carried out and it is very unlikely that the 500 calves have been imported. Therefore, they were not taken into account. • According to the CD, in 1990 all cattle imported from UK and Ireland since 1982 were placed in a monitoring program. • Following the occurrence of the BSE index case in 1993 (imported from UK in 1987 at the age of 6 months), an attempt was made to trace all other cattle imported from UK between 1982 and 1990. • Of the 231 cattle imported from the UK between 1980 and 1990, 108 animals had been slaughtered and 9 had died. From the remaining, 37 were exported, 76 were sent to incineration and one was buried; these were not entering the rendering system and therefore not taken into account. • According to the CD, 16 cattle were imported from Ireland (according to Eurostat 20), of which 9 were slaughtered, 3 died. The remaining 4 were incinerated and did therefore not enter the rendering system. According to the CD, the 6 animals which were imported in 1990 according to Eurostat, were never imported. • Moreover 22 cattle have been imported from Japan (through USA), of which 4 were exported (excluded from the table) and 14 were destroyed and therefore not entering the rendering system, 4 were slaughtered. • Of 28 imported bovines from Denmark, 1 was destroyed and 1 was exported. Of the 19 buffalos imported in 2000, 1 was incinerated and the others were ordered to be destroyed. • Additionally in total 264 cattle according to the CD (276 according to other sources) were imported from Austria, France, Germany, Hungary, Italy, The Netherlands and Switzerland. • The numbers imported according to the CD and Eurostat are very similar. Some discrepancies in the year of import can be explained by an extended quarantine; therefore it is likely that imports according to Eurostat in 1980 and imports according to the CD in 1981 are referring to the same animals. • Additionally, between 16.000 and 340.000 bovines have annually been imported from US, almost all are steers and heifers. In total, between 1981 and 2003, according to the CD more than 2.3 million, according to other sources 1.5 million cattle have been imported. • According to the CD, feeder/slaughter cattle represent typically more than 90% of the imported cattle from the USA; therefore, only 10% of the imported cattle have been taken into account. snip... Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the Geographical BSE Risk of Canada 2.2 Import of MBM or MBM-containing feedstuffs from BSE-Risk countries An overview of the data on MBM imports is presented in table 2 and is based on data provided in the country dossier (CD) and corresponding data on relevant exports as available from BSE risk countries that exported to Canada. Only data from risk periods are indicated, i.e. those periods when exports from a BSE risk country already represented an external challenge, according to the SSC opinion on the GBR (SSC, July 2000 and updated January 2002). According to the CD, no imports of MBM took place from UK since 1978 (initially because of FMD regulations). • According to Eurostat data, Canada imported 149 tons MBM from the UK in the period of 1993 to 2001. According to up-dated MBM statistics from UK (August 2001) no mammalian MBM was exported to Canada from 1993 – 1996. As it was illegal to export mammalian meat meal, bone meal and MBM from UK since 27/03/1996, exports indicated after that date should only have included nonmammalian MBM. Therefore, these imports were not taken into account. • According to the CD, imports of MBM have taken place from Denmark, Germany, France, Japan and US. • According to Eurostat Canada imported MBM from Denmark, Belgium, France and Ireland. • According to the CD further investigations concluded that all imported MBM from Denmark consisted of pork and poultry origin and was directly imported for aquaculture, the imported MBM from France was feather meal, the imported MBM from Germany was poultry meal for aquaculture and the imported MBM from Belgium was haemoglobin; therefore these imports were not taken into account. • The main imports of MBM were of US origin, according to the CD around 250.000 tons, according to other sources around 310.000 tons between 1988 and 2003. snip... 2.3 Overall assessment of the external challenge The level of the external challenge that has to be met by the BSE/cattle system is estimated according to the guidance given by the SSC in its final opinion on the GBR of July 2000 (as updated in January 2002). Live cattle imports: In total the country imported according to the CD more than 2.3 million, according to other data 1.5 million live cattle from BSE risk countries, of which 231 (CD) respectively 698 (other sources) came from the UK. The numbers shown in table 1 are the raw import figures and are not reflecting the adjusted imports for the assessment of the external challenge. Broken down to 5 year periods the resulting external challenge is as given in table 3. This assessment takes into account the different aspects discussed above that allow to assume that certain imported cattle did not enter the domestic BSE/cattle system, i.e. were not rendered into feed. In the case of Canada, the 500 cattle imported from UK according to Eurostat were not taken into account and it is assumed that all incinerated, buried, exported animals and the animals still alive did not enter the rendering system and were therefore excluded from the external challenge. MBM imports: In total the country imported according to the CD around 300.000 tons, according to other sources nearly 360.000 tons of MBM from BSE risk countries, of which 149 tons came from the UK. The majority consisted of MBM imported from the US. The numbers shown in table 2 are the raw import figures and are not reflecting the adjusted imports for the assessment of the external challenge. Broken down to 5 year periods the resulting external challenge is as given in table 3. This assessment takes into account the different aspects discussed above that allow to assume that certain imported MBM did not enter the domestic BSE/cattle system or did not represent an external challenge for other reasons. As it was illegal to export mammalian meat meal, bone meal and MBM from UK since 27/03/1996, exports indicated after that date should only have included non-mammalian MBM. In the case of Canada all imported MBM from UK, Germany, Belgium, Denmark and France was not taken into account. snip... 3. STABILITY 3.1 Overall appreciation of the ability to avoid recycling of BSE infectivity, should it enter processing Feeding The annual Canadian production of MBM is approximately 575,000 tons of which approx. 40,000 tons are exported each year, mainly to USA. Use of MBM in cattle feed • Before the feed ban, dairy cattle received supplementary feed containing MBM during their productive life (maximum 200-400 g MBM per day). Beef cattle in the western part of the country do not usually receive complementary feed. Beef cattle in the eastern part receive normally no supplement protein but the calves could have access to creep feeds containing MBM, after weaning the ratios may have contained supplemental protein containing MBM (100-400 g per day). • According to the CD, MBM is mainly fed to pigs and poultry and included in pet food. • According to the CD, only a proportion of dairy cattle may have received MBM. Feed bans • Before 1997, there was no legal restriction to include MBM into cattle feed. • An MBM-ban was introduced in August 1997; it is forbidden since to feed mammalian MBM to ruminants except if of pure porcine, equine and non mammalian origin, i.e. in practice a ruminant-to-ruminant ban (RMBM-ban). Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the Geographical BSE Risk of Canada - 9 - Potential for cross-contamination and measures taken against • Cross-contamination in the about 600 feed mills is assumed to be possible as long as cattle and pig feed is produced in the same production lines, and premises. • Cross-contamination during transport is possible, particularly if the same trucks are used for transporting ruminant MBM (RMBM) and non-ruminant MBM (porcine or poultry MBM which still might be included into cattle feed) or for transporting pig/poultry feed and cattle feed. • On-farm cross-contamination is regarded to be possible. • Cross-contamination of cattle feed with RMBM can not be excluded. Hence, as reasonable worst case scenario, it has to be assumed that cattle, in particular dairy cattle, can still be exposed to RMBM and hence to BSE-infectivity, should it enter the feed chain. Control of Feed bans and cross-contamination • With the introduction of the RMBM ban (1997) the feed mills (approximately 600) were checked for compliance with the ban, including good manufacturing practices (GMP) and record keeping, i.e. the separation in production of MBM containing ruminant material (RMBM) from non-ruminant MBM. • The feed mills had previously – since 1983 – been regularly checked in relation to production of medicated feed. • No examinations are performed to assess cross-contamination with RMBM of the protein (e.g. non ruminant MBM) that enters cattle feed. Differentiation would anyway be difficult. Rendering Raw material used for rendering • Ruminant material is rendered together with material from other species, but according to the CD only in the production of MBM prohibited for use in ruminant feeds. • Slaughter by-products, including specified risk material (SRM) and fallen stock are rendered. • The country expert estimated that 20% of the rendering plants, processing 20% of the total amount of raw material, are connected to slaughterhouses. Their raw material is more than 98 % animal waste from these slaughterhouses while less than 2 % is fallen stock. No estimation was given for the remaining 80% of the rendering capacity. • There are 32 rendering plants of which 3 are processing blood exclusively. Rendering processes • The rendering systems (parameters) were specified for 6 plants producing mixed MBM, none of these fulfilled the 133/20/3 standard. Of these, 5 have dedicated facilities to produce products for use in ruminant feed and products not permitted for use in ruminant feed. • The remaining plants process porcine or poultry material exclusively. SRM and fallen stock • There is an SRM ban for human food in place since 2003. Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the Geographical BSE Risk of Canada - 10 - • However, SRM are rendered together with other slaughter waste and fallen stock. However, according to the CD, MBM with SRM is not permitted to be fed to ruminants. Conclusion on the ability to avoid recycling • Between 1980 and 1997 the Canadian system would not have been able to avoid recycling of the BSE-agent to any measurable extent. If the BSE-agent was introduced into the feed chain, it could have reached cattle. • Since 1997 this ability gradually improved with the introduction of the ruminant MBM ban and its implementation. • Since cross-contamination cannot be excluded, and as SRM is still rendered by processes unable to significantly reduce BSE-infectivity, the system is still unable to avoid recycling of BSE-infectivity already present in the system or incoming. 3.2 Overall appreciation of the ability to identify BSE-cases and to eliminate animals at risk of being infected before they are processed Cattle population structure • Cattle population: 12.15 Million in 1988 increasing to 14.6 Million in 2001; • Of the total cattle population, 2.2 million are dairy cattle and 12.4 million are beef. • The cattle population above 24 months of age: approx. 6.0 Million. • Of the approximately 2.2 Million dairy cattle 2 Million are located in the two eastern provinces Ontario and Quebec. • Mixed farming (cattle and mono-gastric species) is usually not practiced; the country expert estimated the proportion of mixed farming to be less than 1%. • Individual regions traditionally have ID systems under provincial authorities. Brand inspectors are present when cattle are assembled. It is estimated by the Canadians that the level of a national, uniform ID for cattle is less than 10%; most of those individual pedigree animals. Mandatory ID for the milk-fed veal sector was implemented in Quebec in 1996, but does not contain information on the herd of origin. An agreement of the relevant industries to develop a national cattle ID and trace back strategy was reached on 1 May 1998 (starting in 2001).Since 2002, a national identification program is existing. Al cattle leaving any farm premises must be uniquely identified by ear tag. BSE surveillance • BSE was made notifiable in 1990. • Every cow over one year of age exhibiting central nervous system signs suggestive of BSE submitted to a laboratory or presented at an abattoir is subjected to a BSE laboratory diagnostic test (histology and over the past years also PrPSc-based laboratory tests). • In addition, cattle submitted for rabies examination and found rabies negative are examined for BSE. Samples are prepared immediately upon arrival to the federal laboratory responsible for the rabies diagnostic for possible later BSE examination, i.e. formalin fixation. • Since the 1940’s, a rabies control program has been in place, where farmers, veterinarians and the general public are well educated about this neurological Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the Geographical BSE Risk of Canada - 11 - disease. In 1990, when BSE was made notifiable, this awareness was extended to suspicions of BSE. • Since 1993 the number of brains examined per year did exceed the number recommended by OIE (300 - 336 for countries with a cattle population over 24 months of age of 5.0 to 7.0 Million) in all years, except in 1995 (table 4). year 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 samples 225 645 426 269 454 759 940 895 1´020 1´581 3´377 3´361 Table 4: Number of bovine brains annually examined for CNS diseases, including BSE. • According to the CD approx. 98% of the examined cattle were older than 24 months and approx. 90% exhibited neurological symptoms. Although the identification system of Canada does not document the birth date or age of the animals, according to the CD, examination of the dentition is used to ascertain the maturity of the animals. • The list of neurological differential diagnoses for the 754 brains examined in 1997 included encephalitis (70 cases), encephalomalacia (19), hemophilus (7), hemorrhage (2), listeriosis (38), meningoencephalitis (36), rabies (22), tumors (2), other conditions (135) and no significant findings (423). • Compensation is paid for suspect BSE cases as well as for animals ordered to be destroyed (90-95% of market value with a maximum of 2,500 Can$ per cow). • Diagnostic criteria developed in the United Kingdom are followed at ADRI, Nepean. According to the very detailed protocol for the collection, fixation and submission of Bovine Spongiform Encephalopathy (BSE) specimens at abattoirs under inspection by the Canadian Food Inspection Agency, the specimen shall be shipped to National Center for Foreign Animal Disease, Winnipeg, Manitoba. • In 2003, around 3000 animals from risk populations have been tested. • According to the CD, it is aimed to test a minimum of 8000 risk animals (animals with clinical signs consistent with BSE, downer cows, animals died on farm animals diseased or euthanized because of serious illness) in 2004 and then continue to progressively increase the level of testing to 30,000. • In May 2003, Canada reported its first case of domestic BSE. A second case was detected in the US on 23 December 2003 and traced back to Canadian origin. Both were born before the feed ban and originated from Western Canada. 3.3 Overall assessment of the stability For the overall assessment of the stability, the impact of the three main stability factors (i.e. feeding, rendering and SRM-removal) and of the additional stability factor, surveillance, has to be estimated. Again, the guidance provided by the SSC in its opinion on the GBR of July 2000 (as updated January 2002) is applied. Feeding Until 1997, it was legally possible to feed ruminant MBM to cattle and a certain fraction of cattle feed (for calves and dairy cattle) is assumed to have contained MBM. Therefore feeding was "Not OK". In August 1997 a ruminant MBM ban was introduced but feeding of non-ruminant MBM to cattle remained legal as well as feeding of ruminant MBM to non-ruminant animals. This makes control of the feed ban very difficult because laboratory differentiation between ruminant and non ruminant MBM is difficult if not impossible. Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the Geographical BSE Risk of Canada Due to the highly specialised production system in Canada, various mammalian MBM streams can be separated. Such a feed ban would therefore be assessed as "reasonably OK", for all regions where this highly specialised system exists. However, several areas in Canada do have mixed farming and mixed feed mills, and in such regions, an RMBM ban would not suffice. Additionally, official controls for cattle feeds to control for the compliance with the ban were not started until the end of 2003. Thus, for the whole country, the assessment of the feeding after 1997 remains "Not OK". Rendering The rendering industry is operating with processes that are not known to reduce infectivity. It is therefore concluded that the rendering was and is "Not OK". SRM-removal SRM and fallen stock were and are rendered for feed. Therefore SRM-removal is assessed as "Not OK" snip... 4.2 Risk that BSE infectivity entered processing A certain risk that BSE-infected cattle entered processing in Canada, and were at least partly rendered for feed, occurred in the early 1990s when cattle imported from UK in the mid 80s could have been slaughtered. This risk continued to exist, and grew significantly in the mid 90’s when domestic cattle, infected by imported MBM, reached processing. Given the low stability of the system, the risk increased over the years with continued imports of cattle and MBM from BSE risk countries. 4.3 Risk that BSE infectivity was recycled and propagated A risk that BSE-infectivity was recycled and propagated exists since a processing risk first appeared; i.e. in the early 90s. Until today this risk persists and increases fast because of the extremely unstable BSE/cattle system in Canada. 5. CONCLUSION ON THE GEOGRAPHICAL BSE-RISK 5.1 The current GBR as function of the past stability and challenge The current geographical BSE-risk (GBR) level is III, i.e. it is confirmed at a lower level that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. This assessment deviates from the previous assessment (SSC opinion, 2000) because at that time several exporting countries were not considered a potential risk. snip... full text; Report Summary The European Food Safety Authority and its Scientific Expert Working Group on the Assessment of the Geographical Bovine Spongiform Encephalopathy (BSE) Risk (GBR) were asked by the European Commission (EC) to provide an up-to-date scientific report on the GBR in the United States of America, i.e. the likelihood of the presence of one or more cattle being infected with BSE, pre-clinically as well as clinically, in USA. This scientific report addresses the GBR of USA as assessed in 2004 based on data covering the period 1980-2003. The BSE agent was probably imported into USA and could have reached domestic cattle in the middle of the eighties. These cattle imported in the mid eighties could have been rendered in the late eighties and therefore led to an internal challenge in the early nineties. It is possible that imported meat and bone meal (MBM) into the USA reached domestic cattle and leads to an internal challenge in the early nineties. A processing risk developed in the late 80s/early 90s when cattle imports from BSE risk countries were slaughtered or died and were processed (partly) into feed, together with some imports of MBM. This risk continued to exist, and grew significantly in the mid 90’s when domestic cattle, infected by imported MBM, reached processing. Given the low stability of the system, the risk increased over the years with continued imports of cattle and MBM from BSE risk countries. EFSA concludes that the current GBR level of USA is III, i.e. it is likely but not confirmed that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. As long as there are no significant changes in rendering or feeding, the stability remains extremely/very unstable. Thus, the probability of cattle to be (pre-clinically or clinically) infected with the BSE-agent persistently increases. SUMMARY Summary of Scientific Report http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/573/sr03_biohaz02_usa_report_summary_en1.pdf REPORT (6 PAGES) snip... EFSA Scientific Report (2004) 3, 1-6 on the Assessment of the Geographical BSE Risk of snip... http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/573/sr03_biohaz02_usa_report_v2_en1.pdf Report http://www.efsa.eu.int http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/565/sr04_biohaz02_mexico_report_v2_en1.pdf Summary Summary of Scientific Report The European Food Safety Authority and its Scientific Expert Working Group on the Assessment of the Geographical Bovine Spongiform Encephalopathy (BSE) Risk (GBR) were asked by the European Commission (EC) to provide an up-to-date scientific report on the GBR in Mexico, i.e. the likelihood of the presence of one or more cattle being infected with BSE, pre-clinically as well as clinically, in Mexico. This scientific report addresses the GBR of Mexico as assessed in 2004 based on data covering the period 1980-2003. The BSE agent was probably imported into Mexico and could have reached domestic cattle. These cattle imported could have been rendered and therefore led to an internal challenge in the mid to late 1990s. It is possible that imported meat and bone meal (MBM) into Mexico reached domestic cattle and leads to an internal challenge around 1993. It is likely that BSE infectivity entered processing at the time of imported ‘at - risk’ MBM (1993) and at the time of slaughter of imported live ‘at - risk’ cattle (mid to late 1990s). The high level of external challenge is maintained throughout the reference period, and the system has not been made stable. Thus it is likely that BSE infectivity was recycled and propagated from approximately 1993. The risk has since grown consistently due to a maintained internal and external challenge and lack of a stable system. EFSA concludes that the current geographical BSE risk (GBR) level is III, i.e. it is likely but not confirmed that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. The GBR is likely to increase due to continued internal and external challenge, coupled with a very unstable system. http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/565_en.html ONE YEAR PREVIOUSLY ; From: Terry S. Singeltary Sr. [flounder@wt.net] Greetings FDA, snip... PLUS, if the USA continues to flagrantly ignore the _documented_ science to date about the known TSEs in the USA (let alone the undocumented TSEs in cattle), it is my opinion, every other Country that is dealing with BSE/TSE should boycott the USA and demand that the SSC reclassify the USA BSE GBR II risk assessment to BSE/TSE GBR III 'IMMEDIATELY'. for the SSC to _flounder_ any longer on this issue, should also be regarded with great suspicion as well. NOT to leave out the OIE and it's terribly flawed system of disease surveillance. the OIE should make a move on CWD in the USA, and make a risk assessment on this as a threat to human health. the OIE should also change the mathematical formula for testing of disease. this (in my opinion and others) is terribly flawed as well. to think that a sample survey of 400 or so cattle in a population of 100 million, to think this will find anything, especially after seeing how many TSE tests it took Italy and other Countries to find 1 case of BSE (1 million rapid TSE test in less than 2 years, to find 102 BSE cases), should be proof enough to make drastic changes of this system. the OIE criteria for BSE Country classification and it's interpretation is very problematic. a text that is suppose to give guidelines, but is not understandable, cannot be considered satisfactory. the OIE told me 2 years ago that they were concerned with CWD, but said any changes might take years. well, two years have come and gone, and no change in relations with CWD as a human health risk. if we wait for politics and science to finally make this connection, we very well may die before any decisions DO all these accolades by Johanns USDA et al sound familiar? lets compare; >>>And I can tell you, right now, with the BSE safeguards in place, American and Canadian beef and beef products are safe for consumption. <<< compared to; >>>Brownie, your doing a heck of a job<<< no comment here, i have vowed a New Year resolution, i have no opinion anymore. ...TSS
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