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From: TSS ()
Subject: US May Revise Cattle Import Rule On New Canada BSE Case Gary Weber
Date: July 17, 2006 at 2:47 pm PST

Today 7/17/2006 3:35:00 PM


US May Revise Cattle Import Rule On New Canada BSE Case

WASHINGTON (Dow Jones)--The U.S., now in the later stages of lifting its ban on Canadian cattle that are over 30 months of age, may have to make changes to the proposed rule in response to Canada's most recent mad-cow case, according to U.S. government and industry officials.

Andrea Morgan, a veterinarian and associate deputy administrator at the U.S. Department of Agriculture, said a draft of the U.S. rule on older Canadian cattle has been finished, but may need to be revised.

At the heart of USDA's concern is the age of the latest infected Canadian cow confirmed to be positive for the disease last week. It was just 50 months old, born more than four years after Canada implemented cattle feed restrictions that were supposed to the spread of mad-cow disease, or bovine spongiform encephalopathy.

The USDA sent one of its epidemiologists to Canada over the weekend to follow the country's investigation into its seventh native-born case of BSE. That is something USDA did not do after Canada reported its sixth case earlier this month, but that infected cow was 15 years old - born well before Canada began its feed ban in 1997.

USDA officials are primarily interested to see whether the latest Canadian BSE case represents a widespread problem with the country's feed ban, the domestic restrictions designed to eradicate the cattle disease.

There may be good reason for concern, said U.S.-based National Cattlemen's Beef Association Director of Regulatory Affairs Gary Weber.

The effect on U.S.-Canadian cattle trade, Weber said, may be the cut-off point for cattle birth dates that the USDA writes into its rule to allow in the older animals. Canada, he said, now considers 1999 to be the year that all ranchers there became fully compliant with the feed ban. USDA may be forced to bump that date up, he said.

Chuck Kiker, president of another cattle producer group, R-CALF United Stockgrowers of America, called on the USDA to "indefinitely postpone" its plans to lift its ban on older Canadian cattle. Allowing those cattle across the border, Kiker said in a letter to USDA Secretary Mike Johanns, will only serve in scaring away foreign importers that buy, or are considering buying, beef from the U.S.

Kiker cited a concern voiced recently by South Korea that imported Canadian beef could be mixed in with U.S. origin product.

South Korea and the U.S. remain in prolonged negotiations over resuming beef trade. The country banned U.S. beef in December 2003 after the U.S. discovered its first BSE case in a cow that was later shown to be of Canadian origin.

"With another case of BSE in an animal born after Canada's feed ban ... now is not the time to further weaken our import standards ... " Kiker said in his letter to Johanns, dated July 17.

While Canada's seventh BSE case, the latest is the fourth found in a cow born after the country's feed ban was imposed. Two previous cases were born about three years after Canada began its feed ban and another less than a year.

The Canadian feed ban, similar to the one in the U.S., prohibits the use of bovine material in cattle feed because infected feed is believed to be the primary means of spreading the disease among animals.

The U.S. banned all Canadian beef and cattle in May 2003 after Canada's first domestic case of BSE was found. The USDA eased that ban a few months later on some beef and, in July 2005, began allowing in younger cattle.

The USDA rule allowing in older cattle has taken longer because older cattle are believed to be at higher risk for BSE.

USDA's Morgan said a draft of the proposal has been finished and was in "the clearance process" when Canada reported its latest BSE case last week.

Part of the reason the USDA is eager to allow in the older Canadian cattle is that there are many cow-slaughter operations - plants that specialize in processing older beef and dairy cattle - in the U.S. that need the imports.

In 2003, about 250,000 head of older cows slaughtered in the U.S. came from Canada before the U.S. border was shut, according to data provided by the American Meat Institute Foundation.

Source: Bill Tomson; Dow Jones Newswires; 202-646-0088; bill.tomson@dowjones.com

http://www.cattlenetwork.com/content.asp?contentid=52841

Greetings,

Gary Weber, in my opinion, has no credibility in anything he says. HE is a hypocrite. He is, and has been part of the problem.
His statements are like the 'pot calling the kettle black'.


Weber states;

Weber said, may be the cut-off point for cattle birth dates that the USDA writes into its rule to allow in the older animals. Canada, he said, now considers 1999 to be the year that all ranchers there became fully compliant with the feed ban. USDA may be forced to bump that date up, he said. ...end

HOW THE HELL then would Weber explain a FDA NATIONWIDE MAD COW FEED RECALL OF 10,878.06 TONS IN THE USA IN 2006 JUST LAST MONTH, just another part of the June 2004 Enhanced BSE surveillance program?


MAD COW FEED RECALL USA EQUALS 10,878.06 TONS NATIONWIDE
Sun Jul 16, 2006 09:22
71.248.128.67


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

END OF ENFORCEMENT REPORT FOR July 12, 2006

###

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


NOT counting the latest mad cow feed ban warning letter here;

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

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

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

May 17, 2006

WARNING LETTER NO. 2006-NOL-06

FEDERAL EXPRESS
OVERNIGHT DELIVERY

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

Dear Mr. Shirley:

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

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

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

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

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

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

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

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

Sincerely,

/S

Carol S. Sanchez
Acting District Director
New Orleans District


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

PLUS, the USDA guesstiment of the age of that Alabama mad cow is in question as well;


Alabama mad cow dental records 'dentition' supposedly 10 year + cow ??? or not i.e. 'informed guess'

Alabama BSE Investigation

Final Epidemiology Report

May 2, 2006

SNIP...

Epidemiology Investigation of Index Herd: Farm A

The index case was a deep red, crossbred beef cow estimated to be approximately 10-

years-old based on dentition. On March 16, 2006, USDA personnel exhumed the carcass

of the index case, sent the head to NVSL and transported under seal the remainder of the

carcass to the Alabama State Diagnostic Laboratory (ASDL). The investigators

confirmed the carcass to be that of a red beef cow. The body and facial area did not

contain any white markings. No identification devices were found on the cow, including

any evidence of brands, tattoos, or ear tags. Additionally, on March 29, NVSL examined

the head of the carcass to confirm the lack of a tag and the lack of evidence (holes or

scarring) of previous tags in the ear.

The age of the index cow was estimated by examination of the dentition as 10-years-old

by the accredited veterinarian. Regulatory personnel examined the dentition of the

exhumed carcass and concurred with the estimate. The teeth in the head of the carcass

were short with elongated necks with some incisors missing. This is consistent with the

dentition of other cattle from Alabama with a known age of 10 or more years.

Genetic tests were conducted at NVSL to match the NVSL-generated homogenate of the

obex, the homogenate of obex from the Georgia lab, brain material from the cow head

(collected by NVSL), and ear material from the cow head (also collected by NVSL). On

March 23, the results for these tests indicated they all originated from the same source

and confirmed that that carcass exhumed on March 16 was the index case.

SNIP...

Summary:

Despite a thorough investigation of two farms that were known to contain the index cow,

and 35 other farms that might have supplied the index cow to the farms where the index

case was known to have resided, the investigators were unable to locate the herd of

origin. The index case did not have unique or permanent identification, plus, the size and

color of the cow being traced is very common in the Southern United States. Due to the

unremarkable appearance of solid red cows, it is not easy for owners to remember

individual animals. In the Southern United States, it is common business practice to buy

breeding age cows and keep them for several years while they produce calves. Most

calves produced are sold the year they are born, whereas breeding cows are sold when

there is a lapse in breeding, which can occur multiple times in cows’ lives. For all of

these reasons, USDA was unable to locate the herd of origin.

http://www.aphis.usda.gov/newsroom/hot_issues/bse/content/printable_version/EPI_Final.pdf

> The teeth in the head of the carcass

> were short with elongated necks with some incisors missing. This is consistent with the

> dentition of other cattle from Alabama with a known age of 10 or more years.

WITH the potential for error using dentition, this cow could have been less than 10 years old. ...tss

Audit Report

Animal and Plant Health Inspection Service

Bovine Spongiform Encephalopathy (BSE) Surveillance Program – Phase II

and

Food Safety and Inspection Service

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

Report No. 50601-10-KC January 2006

There is no requirement in the United States for the age of animals to be recorded, therefore, APHIS and FSIS rely on meat establishments to determine the age of cattle slaughtered using documentation or dentition.

snip...

full text 130 pages ;

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

http://www.fsis.usda.gov/ofo/tsc/bse_information.htm

http://www.ianrpubs.unl.edu/epublic/live/nf593/build/nf593.pdf

This added an extra margin of safety because cattle can be reasonably accurately aged by their dentition at 30 months and because BSE is relatively rare under the age of 30 months.

http://www.cdc.gov/ncidod/eid/vol4no3/pattison.htm

SO, what is the threshold of a 'reasonably accurately aged' cow, when we are speaking of a borderline 10 year old cow ??? plus, BSE is not as rare below 30 months as cdc would have you believe. just not testing that many young ones, plus youngest documented to date is 21 months. ...TSS


An evaluation of the accuracy of ageing horses by their dentition: can a computer model be accurate?

Vet Rec. 1995 Aug 5;137(6):139-40


Richardson JD, Cripps PJ, Lane JG.

Department of Clinical Veterinary Science, University of Bristol, Langford.

The prediction of the age of a horse from its dentition has been widely accepted as an accurate technique, but recent reports have questioned this belief. In this study the dental features of 434 thoroughbreds of known age were documented and a multiple regression equation was calculated from the 13 dental features which had the highest correlation with true age. The accuracy of the ages assessed by a computer model were compared with the ages estimated by experienced equine clinicians. There was little difference between the accuracy of the computer model and the human observers, and neither method provided an acceptable level of accuracy for ageing horses from their dentition.

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

http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?db=pubmed&cmd=Retrieve&dopt=abstractplus&list_uids=8540206&query_hl=2&itool=pubmed_docsum

The results show that specific ages cannot be assigned to these dental criteria owing to the wide variation between horses, and that as a result the estimation of age from dentition can never be precise.


http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?db=pubmed&cmd=Retrieve&dopt=abstractplus&list_uids=8533255&query_hl=2&itool=pubmed_docsum

It is suggested that written records of the dental features are made on each occasion when a dental examination is made and that veterinary surgeons advise clients that estimating a horse's age from dental criteria can provide no more than an 'informed guess'.

http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?db=pubmed&cmd=Retrieve&dopt=abstractplus&list_uids=8533248&query_hl=2&itool=pubmed_docsum

WHAT makes this method nothing more than an 'informed guess' for a horse, but an exact science for usda and there mad cows $$$


NOW, what does the cattle industry itself say about the accuracy of detention ;


EMBARGOED UNTIL APRIL 7, 2004

For Immediate Release

Contact: Walt Barnhart 303/850-3360 wbarnhart@beef.org

Nation’s Leading Cattle Organization Uses Fact, Reason

To Protect Cattle Producers in Post-BSE Regulation Frenzy

Other costs, like changing the status of cattle judged older than 30 months in the fed slaughter supply and increased testing levels, are much more difficult to estimate. The 30-month rule is complicated by the fact that dentition as a basis of estimating cattle age is a problematic methodology. NCBA, through its contract with the Cattlemen’s Beef Board, is coordinating checkoff research that would determine the accuracy of dentition and identify other means of accurately assessing animal age.


http://www.beefusa.org/uDocs/Policy%20031404.doc

It is important to remember that, in the Territory as elsewhere, the time of eruption of incisor

teeth is only a broad guide to age in cattle. From one animal to another age at eruption can vary

by several months.

Reference: Charles and Lampkin (1977) (Table 1)

https://transact.nt.gov.au/ebiz/dbird/TechPublications.nsf/419A052DCA5D866169256EFE004F64FC/$file/595.pdf?OpenElement

Subject: GARY WEBER VS TSS ON USA TSEs $$$
Date: June 29, 2002 at 9:02 am PST
Subject: Gary Weber National Cattlemen's Beef Association vs TSS -- Strategic Animal Disease Prevention, Res
Date: Wed, 26 Jun 2002 22:02:06 -0700
From: "Terry S. Singeltary Sr."

Submitted by Category

Public
Anonymous
on 10/09/2001 at 05:27 PM all of above!!!
Strategic Animal Disease Prevention, Res

Gary Weber

National Cattlemen's Beef Association

October 9, 2001

USDA-APHIS
Regulatory Analysis and Development-PPD
Suite 3C03 Unit 118
4700 Riverdale, MD 20737-1238

Re: Animal Disease Risk Assessment, Prevention and Control Act
Docket No. 01-064-1

On behalf of the membership of the National Cattlemen?s Beef Association
(NCBA), I want to express our sincere appreciation to Congress for
passing the Animal Disease Risk Assessment, Prevention and Control Act
of 2001. I also want to thank the United States Department of
Agriculture (USDA), Department of Health and Human Services (HHS),
Departments of Treasury, Commerce, Defense and the Office of the United
States Trade Representative for working to prevent foreign animal
diseases in the United States. The NCBA is the trade association of
America?s cattle farmers and ranchers and the marketing organization for
the largest segment of the nation?s food and fiber industry.

An outbreak of Bovine Spongiform Encephalopathy (BSE) or Foot and Mouth
Disease (FMD) would be extremely damaging to the U.S. cattle industry
and it would have major impacts through out the U.S. economy.

The sale of cattle and calves represents the single largest contributor
to farm and ranch income in the United States, exceeding $35 billion
annually. The retail value of beef sold in the United States exceeds $55
billion and foreign sales exceed $3.5 billion. We are the largest beef
producer in the world. We have the largest beef market and are also the
largest importer of beef in the world. We rank 4th in the size of our
cattle herd, but first in productivity.

An outbreak of BSE or FMD would not only impact cattle producers,
packers, processors and retailers but also severely impact grain
producers. Rural communities who depend on livestock as well as feed
grain demand would suffer as well.

An outbreak of BSE or FMD would reduce consumer purchases of beef and
create a ripple effect in the economy. Each 1- percent drop in consumer
purchases of beef, if sustained for one year, would cause a $350 million
drop in farm and ranch income. In many countries where BSE or FMD have
been found, beef consumption dropped between 30 and 50 percent. If this
were to happen in the United States it would equate to a loss of between
$10.5 and $16.5 billion in farm and ranch income alone. In addition,
virtually all of our over $3.5 billion in international trade would
cease for an indeterminate period of time while we reestablish our
health and trading status.

Consequently, an outbreak of BSE or FMD could easily cost the beef
industry alone between $14 and $ 20 billion in the first year of the
incident.

Fortunately, the U.S. government has had a long history of working to
prevent the introduction of BSE, FMD and other diseases. This long
history has led to the development of numerous firewalls that protect
the domestic beef industry and national economy.

Firewall 1: Intelligence regarding disease status and risk

The first firewall of disease prevention is our knowledge of the disease
status of countries seeking to trade with the United States

The ability to exclude diseases is built upon the assumption of knowing
where the risks are in the world. The International Office of Epizootics
aids in this ?intelligence.? But we also believe our Foreign
Agricultural Service and APHIS professionals stationed overseas need to
be our eyes and ears as it relates to early warning of disease situations.

We believe when a country?s disease status is in doubt, we stop trade
and ask questions later.

Firewall 2: Ports of Entry

We must ensure that only approved products are allowed into the United
States and that Customs and APHIS strategically inspect both passengers
and imported products to ensure this is the case.

At ports of entry, there must be a very close working relationship
between Customs officials and APHIS professionals. Thought should be
given to model scenarios relating to how individuals might try to
circumvent our prohibitions and how to protect against such acts.
Efforts to ?change, modify or void? a products disease risk status
through label changes or trans-shipment must be evaluated. Customs and
APHIS should be able to use the same database to track imported products.

Firewall 3: Animal Health Infrastructure, Education and Disease Surveillance

We must have a clear vision as to what level of animal health
infrastructure is needed in the United States to protect animal
agriculture, respond in the event of a disease outbreak and help the
industry recover. We remain concerned that ?right sizing? and
?reinventing government? may have compromised our infrastructure. We
must evaluate if we have retained an adequate level of infrastructure.

The USDA, State animal health officials, the Cooperative Extension
Service, veterinarians, producers and other professionals should support
continuing education and mock exercises of diseases outbreaks to ensure
our systems will detect a disease outbreak early and quickly stamp it out.

Firewall 4: Enforcement of feed restrictions, food waste treatment and
disposal

The Food and Drug Administration must develop a targeted strategic plan
that ensures enforcement, based on quantifiable risk, of feeds
restricted from ruminant diets. The prevention of the amplification and
spread of BSE depends on preventing the feeding of specific, restricted
feeds. The enforcement program must reflect a heavy focus on entities
manufacturing feeds for ruminants as contrasted with inspecting
dedicated poultry or swine feed manufacturing facilities. The system
must be risk based.

Food waste represents a potential vector for several diseases. To
prevent potential disease introduction, systems must be in place, and
functional at all ports of entry and entities using such by-products to
ensure they eliminate disease risk.

Firewall 5: Disease Surveillance

The USDA should make sure that disease detection systems are ?state of
the art.? The Department must ensure the best available technology is
employed to detect diseases in a timely manner. The scope of
surveillance systems, such as those for BSE, must represent a
statistically valid approach that will provide a known ability to detect
disease if present. For instance, what level of BSE surveillance is
needed to ensure a 95% confidence level that the disease incidence is at
a level of less than 1 per million? This is not to say this is the ideal
target, but systems must be defensibly designed for both domestic and
international markets.

Firewall 6: Research

Our investments in research, technology and education are essential to
stay ahead of the evolving threats of foreign or emerging pathogens. Our
investments in the public and private sector should be based on dialog
and strategically oriented to ensure no voids exist. Efforts must be
made through cooperative research and development agreements to enhance
public and private interaction in order to accelerate the
commercialization of innovations.

Summary

Everyday, consumers in the United States and all around the world
benefit from the strategic investments we have made to ensure we have
the safest and most efficient food production system in the world. We
must not rest on our laurels. We must continue to invest in the
firewalls outlined in this response. To do otherwise will put consumers,
producers, and rural America at untenable risk.

Thank you for this opportunity to share our view on the importance of
the Animal Disease Risk Assessment, Prevention and Control Act of 2001.
We trust that the USDA recognizes the critical role and responsibility
it has to foster a close working relationship across agencies and
departments to ensure we remain free of foreign animal diseases.

We stand ready to help in any and all possible ways to ensure success.

Sincerely,
Gary M. Weber, Ph.D.
Executive Director
Regulatory Affairs

https://199.132.50.48/E-Commen.nsf/8178b1c14b1e9b6b8525624f0062fe9f/eacebde195d8115785256ae00075dde5?OpenDocument

VS

Submitted by Category

Public
Anonymous
on 08/22/2001 at 05:35 PM all of above!!!
The Animal disease Risk Assessment

Terry S. Singeltary Sr.

CJD WATCH

Greetings and To Whom It May Concern,

I would like to respectfully point out a
few points of concern on the past history
of the APHIS/USDA/FDA, in regards to
human/animal TSEs.

snip...

The report will discuss the economic impacts
that would be associated with the potential introduction of
foot-and-mouth disease, bovine spongiform encephalopathy, and related
diseases into the United States; the potential risks posed by those
diseases to public and animal health; and recommendations to protect the
health of animal herds and U.S. citizens from those risks.

snip...

http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2001_register&docid=fr21au01-36

the above paragraph points out my exact concerns.
putting industry and economic concerns,
before public health and letting the industries
involved dictate human health/safety issues,
will only spread these human/animal TSEs.

it is very apparent from the Aug. 4, 1997
partial ruminant-to-ruminant feed, that
these safe-guards and bans are being
blatantly ignored, due to the fact that
the FDA has no regulatory authority, or
any authority to take actions. these feed
bans are still being violated today in 2001,
some 4 years after ban put into place.

some recent feed ban violations;

http://www.fda.gov/foi/warning_letters/g1573d.pdf

here they wonder where CWD comes from,
cleaning SRMs/MRMs from mixers with 140 lbs.
bags of corn, then feeding that corn to deer?

http://www.fda.gov/foi/warning_letters/g1115d.pdf

http://www.fda.gov/foi/warning_letters/g1114d.pdf

these are just a few of many violations,
that are still ongoing today in 2001. But yet
i have been told by Dr. Detwiler herself for
4 years that cattle are not being fed to cattle.

before i move on, i would like to point out
that the statement by the FDA on the Purina
mill in Texas and the 5.5 grams of potentially
tainted feed is grossly misleading.

"FDA has determined that each animal could have consumed, at most and in
total, five-and-one-half grams - approximately a quarter ounce -- of
prohibited material. These animals weigh approximately 600 pounds."

http://www.fda.gov/bbs/topics/news/2001/new00752.html

if we look at these studies, we will find that
the 5.5 grams would be more than sufficient to
infect a cow, if the feed was tainted with TSEs.

please read page 4, 5 and 6 of some 53;

Scientific Steering Committee
ORAL EXPOSURE OF HUMANS TO THE BSE AGENT:
INFECTIVE DOSE AND SPECIES BARRIER

http://europa.eu.int/comm/food/fs/sc/ssc/out79_en.pdf

NOW, we have the refusal by the USDA/APHIS
to do suffient testing on all U.S. cattle,
to find out if any type TSE exist in U.S.
cattle herds. 13,916 cattle tested in some
13 years, from 100 million cattle in any
given year simply is not sufficient, and even
the SSC states that 'passive surveillance'
will NOT detect low level BSE/TSEs in the U.S.
and if we look at dose rate, it would only
take one TSE infected cow to slip through
the many cracks and loopholes that still exist
today, to start a potential epidemic.

If we look at what the E.U. has done,
in comparison to what the U.S. has done,
it is very obvious that the U.S. is trying
to hide something. In 6 months time, the E.U.
has tested some 3.2 million cattle, to our
13,916 in 13 years. Our feeding and rendering
practices have mirrored that of the U.K. for
years. Scrapie has spread across the U.S.,
Outbreaks of T.M.E. (source, feed made from
downer cattle per Richard Marsh), and
C.W.D. spreading in U.S., but, we refuse to test
cattle sufficiently to find TSEs. WHY?

I do not accept Dr. Detwilers lame excuse;

snip...

APHIS believes that it is incorrect to focus on the slaughter cattle
population in regards to BSE surveillance. Cattle less than 20 months
of age make up approximately 88 percent of the slaughter population, and
no where in the world has a case of BSE been diagnosed in cattle less
than 20 months of age. The cattle population APHIS considers as the
target for BSE surveillance would be those most at risk to be exposed to
the disease, not the slaughter population. The surveillance in the
United States is designed to sample those cattle where BSE would most
likely occur (most susceptible) and where the disease would most
likely be detected. The targeted surveillance includes adult cattle
displaying signs of neurologic disease and adult cattle which are
non-ambulatory (down).

snip...

http://www.aphis.usda.gov/oa/bse/bsesurv.html

this is no excuse to not test more cattle,
no matter which age group you target. simply
put, if you don't look, you will not find,
and apparently this is the goal of USDA/APHIS.

look at what happened to Germany. Germany refused
to test for years, said they were BSE Free.
Until they started looking. And if you notice,
when they did start to look, they also found
cattle with BSE, that had no symptoms.
Subclinical cases.

> When asked whether the USDA was evaluating or considering using
> these newer tests in the U.S., Detwiler said they would look at
> them at some point in the future. The reason the USDA isn't looking
> more closely at these tests now is because "there's too much demand
> for them in Europe," and Prionics, for example, is currently "unable
> to send any testing kits to the USDA,"she says. "We can't start any
> evaluation if they can't deliver the European tests to us."

I think in Germany she would have to resign after this lie.
In addition I would be interested to know for what she needs a closer
look at these tests which have been used in practice several hundred
thousand times now and already identified seemingly healthy, but BSE
infected cattle. No, the problem are of course not the tests, but the
availability of BSE positive and negative testing material and the
most serious problem is the US government which simply does not want
to test and find BSE.

> Asked what the USDA thought of the Nature study affirming the
> effectiveness of the three rapid mad cow tests, Detwiler replied
> she wasn't familiar with the study and needed to read it.

Oh god!

> She added that she expected it to take quite some time for the USDA
> to evaluate the rapid tests, that it would likely be a long time
> before they might be approved.

No doubt that this can easily take another
10 to 15 years.

snip...

"In both studies, BSE-affected animals with no overt clinical symptoms
were detected. These results demonstrate the usefulness of the PWB
procedure in surveillance systems serving as a rapid diagnostic tool to
identify animals subclinically infected with BSE."

http://link.springer.de/link/service/journals/00401/bibs/9098005/90980437.htm

BSE Test Results

The number of tests results continues to grow exponentially. There have
now been more than 3.2 million rapid tests carried out between
1 January and 30 June 2001. Over 90% of these tests have been carried
out on healthy animals aged over 30 months. It is reassuring
that the youngest case of BSE in these healthy animals remains at 42
months.

snip...

please note in this statement about Third
Countries, Passive surveillance and Fallen
Animals.

"Passive surveillance was, of course, the only means to detect BSE until
rapid tests became available. It is clear, however, from both the
reports of the FVO and from the long delay in confirming the presence of
BSE that passive surveillance systems were totally inadequate in several
Member States. The Commission will be writing to the Member States in
question with a view to ensuring that the appropriate lessons have been
learned from these past failures."

http://europa.eu.int/comm/dgs/health_consumer/library/speeches/speech112_en.html

when the U.S. has only tested as of July 18,
2001, a total of 13,916 in approx. 12 years
of 'passive' surveillance.

Total Bovine Brain Submissions by State, May 10, 1990 thru July 18, 2001

http://www.aphis.usda.gov/oa/bse/bsesurvey.html#charts

How many more will die. Sporadic CJDs are not
a single strain that falls from sky, it is
potentially multiple strains, that is caused
by different strains of TSEs in the U.S.,
from cows, to mink, to deer, to elk, scrapie
in sheep, and yes, potentially even pigs.
there are other potential routes/sources such
as the surgical arena, nutritional supplements
(nothing more than what they were feeding
to cows), cosmetics, pharmaceuticals etc.
So why the continued refusal to test in
sufficient or compatible numbers as the E.U.?

CJD WATCH data base;


http://www.fortunecity.com/healthclub/cpr/349/index.html

CJD VOICE data base;


http://members.aol.com/larmstr853/cjdvoice/stat798.htm

now, these are far from being all victims,
but at least it is better than the poor
CJD Surviellance in the USA. Only 9 states
make CJD reportable, and out of those 9
states; Texas, Missouri, Utah, Colorado,
New York, Florida, New Jersey, Ohio and
Vermont, i doubt very seriously, by
waiting for death certificates to show
up with CJD written on them, will come
close to reporting all TSE victims in
young and old. we must not forget the
old, by only surveying young TSE victims
(another myth).

Diagnosis and Reporting of Creutzfeldt-Jakob Disease T. S. Singeltary,
Sr; D. E. Kraemer; R. V. Gibbons, R. C. Holman, E. D. Belay, L. B.
Schonberger

http://jama.ama-assn.org/issues/v285n6/ffull/jlt0214-2.html

follow-up from Dr. Tom Pringle
http://www.mad-cow.org/00/feb01_news_mid.html#mmm

Diagnosis of dementia:
Clinicopathologic correlations

Francois Boller, MD, PhD; Oscar L. Lopez, MD; and John Moossy, MD

Article abstract--Based on 54 demented patients consecutively autopsied
at the University of Pittsburgh, we studied the accuracy of clinicians
in predicting the pathologic diagnosis. Thirty-nine patients (72.2%) had
Alzheimer's disease, while 15 (27.7%) had other CNS diseases (four
multi-infarct dementia; three Creutzfeldt-Jakob disease; two thalamic
and subcortical gliosis; three Parkinson's disease; one progressive
supranuclear palsy; one Huntington's disease; and one unclassified). Two
neurologists independently reviewed the clinical records of each patient
without knowledge of the patient's identity or clinical or pathologic
diagnoses; each clinician reached a clinical diagnosis based on criteria
derived from those of the NINCDS/ADRDA. In 34 (63 %) cases both
clinicians were correct, in nine (17%) one was correct, and in 11 (20%)
neither was correct. These results show that in patients with a clinical
diagnosis of dementia, the etiology cannot be accurately predicted
during life.

NEUROLOGY 1989;39:76-79

i posted full text here;

http://www.vegsource.com/talk/lyman/messages/9249.html

Bottom line, to put fire wall up for TSEs
in the USA, it is NOT to only worry of imported
strain, but to worry about home grown strain
also. our borders are FAR from being ceiled,
and to think this is strictly UK disease,
will only spread disease around Globe.

Massive TSE testing in USA cattle, sheep,
deer, elk...

stop ALL feeding of SRMs and MRMs including
intestines (casings) to cattle and all
other animals and including pet foods...

stop all use of pithing at slaughter,
nor the use of "pneumatic stunning"

(note, this must be done for U.S.A. citizens
as well as for export to E.U. citizens. why
set up seperate slaughter houses and renders
only for safeguarding E.U. citizens $$$)

Besides the ruminant-to-ruminant feed ban
that never was enforced, I have found that
many products were imported to the U.S.
from known BSE Countries. Once again,
i was told that this had NOT taken place
since 1997. And again, i find that in fact,
you can still import brains of animals from
known BSE countries for supplements in 2001.
you can still import blood and blood products,
so the borders that USDA/APHIS claim are sealed,
are in fact far from being sealed. i can give
you list of imports if you like.

Also, BSE FREE HERDS??? what the heck is that.
only GOD knows if a herd is BSE free, especially
in the USA. So, my question to the USDA/APHIS,
how can they certify USA herds as BSE Free?
This would be absolutely contrary to the
_OIE principles of veterinary certification_.
A vet cannot certify something he or she does
not know for certain, has not been able to
_verify_. A U.S. vet can certify that a
product derives from bovines born and
reared in the USA, that no case of BSE has
been detected so far in the USA, and that
USA has been classified by the SSC as a
category 2 country (low but not negligable
BSE risk, and very unstable).

Report on the Assessment of the Geographical BSE - Risk of USA (July 2000)

http://europa.eu.int/comm/food/fs/sc/ssc/out137_en.pdf

(please note, i do not see why the USDA/APHIS
is so proud of the above very unstable report)

According to the OIE, "certification should
be based on the highest possible ethical
standards, the most important of which is
that the professional integrity of the
certifying veterinarian must be respected
and safeguarded. It is essential not to
include in the requirements additional
specific matters which cannot be accurately
and honestly signed by a veterinarian.
Certification of freedom from diseases
based on purely clinical freedom and
herd history is of limited value. This is
also true of diseases for which there is
no specific diagnostic test, or the value
of the test as a diagnostic aid is limited.

http://www.oie.int/eng/normes/mcode/A_00008.htm

In fact, a statement such as "BSE-free herd"
is of no value at all. A better statement
might be "comes from a herd that has never
been fed animal proteins", but in that case
the veterinarian should also be the owner
of the herd and really know that he has
never bought any concentrate feeds.

Bottom line, if you snooze, you loose, and
the U.S.A. has been 'asleep at the wheel'
for decades. Their 'band-aid' approach,
needs a tourniquet.

My Mom and many more are dead because of
nothing more than greed and stupidity,
and you can blame BOTH parties for this.

with kindest regards,
I am sincerely,

Terry S. Singeltary Sr.
P.O. Box 42
Bacliff, Texas USA

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

August 7 - October 9, 2001: E-Comments is
currently accepting comments on Docket No.
01-064-1, the Animal Disease Risk Assessment,
Prevention, and Control Act notice of public
meeting and request for comments.

Animal Disease Risk Assessment, Prevention, and Control Act

[Docket No. 01-064-2]
====================================

https://199.132.50.48/E-Commen.nsf/8178b1c14b1e9b6b8525624f0062fe9f/c147d3037a26dfe285256ab000769557?OpenDocument

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

re-Gary Webers 'PORTS OF ENTRY' #2 'FIREWALL' (is burning)...TSS

a few items to ponder below;

> USA FEED MILL FIRMS __N O T__ IN COMPLIANCE [115 TO DATE DOCUMENTED]!
>
> http://www.fda.gov/cvm/efoi/BSEInspectNotCompl031102.xls
>
> http://www.fda.gov/cvm/efoi/InpectionListDescriptionforHP.htm
>
> now, we have covered the ''home grown strains'', excluding
> the cattle/TSE situation, cause they absolutely have not
> the foggiest idea of that, let's look at the potential
> of BSE from imports. now we have all heard of those
> USA 'sealed borders' everyone is so proud of, remembering
> 1/2 to 1 GRAM OF TAINTED MATERIAL IS LETHAL TO A COW.
> let's take a look;
>
> > During the years before the importation of live ruminants and
> ruminant > products was banned (in 1989), 500 cattle and a single
> shipment of 12 > tons of meat and bone meal feed were imported from the
> United Kingdom
>
> this statement is absolutely false;
>
> Subject:
> Re: exports from the U.K. of it's MBM to U.S.???
> From:
> S.J.Pearsall@esg.maff.gsi.gov.uk
> Date:
> Tue, 8 Feb 2000 14:03:16 +0000
> To:
> flounder@wt.net (Receipt Notification Requested) (Non Receipt
> Notification Requested)
>
> Terry
>
> Meat and bonemeal is not specifically classified for overseas trade
> purposes. The nearest equivalent is listed as "flours and meals of meat
> or offals (including tankage), unfit for human consumption; greaves". UK
> exports of this to the US are listed below:
>
> Country
> Tonnes
> 1980
>
> 1981
> 12
>
> 1982
>
> 1983
>
> 1984
> 10
> 1985
> 2
> 1986
>
> 1987
>
> 1988
>
> 1989
> 20
> 1990
>
>
> Data for exports between 1975 and 1979 are not readily available. These
> can be obtained (at a charge) from data retailers appointed by HM
> Customs and Excise: BTSL (Tel: 01372 463121) or Abacus (01245 252222).
>
> Best wishes
> Simon Pearsall
> Overseas trade statistics Stats (C&F)C
>
> Simon
> as discussed
> thanks
> Julie
> ---
> Forwarded message:
> Sent: Fri Feb 04 21:47:01 2000
> Received: Fri Feb 04 21:45:15 2000
>
> any way you add this up, it's 44 TONS...
>
> Paul Brown's and Dr. Detwilers sealed borders, and
> the _non-species_ coding system;
>
> check out Austria cattle pop. of 2.2 million 2001, compare their pop.
> to the USA pop. of 105 MILLION in 2000/2001, and then compare
> testing. what a joke that the USA can say with a straight face,
> USA IS BSE FREE$
>
> What is Austria's production and trade in affected animals and animal
> products?
>
> Austria has almost 2.2 million cattle in 2001 and accounted for 1.6
> percent of world cattle exports in 1999. Stocks of sheep and goats and
> trade in these animals were generally less than 0.1 percent of global
> stocks.
>
> snip...
>
> What are the US imports of affected animals or animal products from

Austria?

>
> Between 1998 and June 2001, US imports from Austria included goat meat,
> animal feeds, and sausage. The sausage and animals feeds were from
> unspecified species.
>
> snip...
>
> Feed - non species specific
>
> 2309909500
>
> Preparations Used in Animal Feedings, NESOI
> KG 0 0 0 1,000
>
> Meat & offal - ruminant
>
> 020450
>
> Goat Fresh, Frozen
> KG 0 656 0 0
>
> Meat & offal - non species specific
>
> 1601006080
>
> Sausage/Smlr Prdct Meat Etc NESOI Food Prep Nt Cnd
> KG 514 0 0 12,154
>
> Source: World Trade Atlas
>
> P.S. be sure you read the list of BSE potential meat
> that was carried on airplanes by passengers;
>
> http://www.aphis.usda.gov/vs/ceah/cei/bse_poland0502.htm


>
> http://www.aphis.usda.gov/vs/ceah/cei/bse_austria1201.htm


>
> or what about the other Countries and their imports;


>
> http://www.aphis.usda.gov/vs/ceah/cei/bse_finland1201.htm


>
> http://www.aphis.usda.gov/vs/ceah/cei/bse_slovenia1101.htm


>
> http://www.aphis.usda.gov/vs/ceah/cei/bse_slovakia1001.htm


>
> http://www.aphis.usda.gov/vs/ceah/cei/bse_japan0901.htm


>
> http://www.aphis.usda.gov/vs/ceah/cei/bse_greece0701.htm


>
> http://www.aphis.usda.gov/vs/ceah/cei/bse_cz0601.htm


>
> http://www.aphis.usda.gov/vs/ceah/cei/bse_germany1200e.htm


>
> http://www.aphis.usda.gov/vs/ceah/cei/bsedenmark.htm


>
> http://www.aphis.usda.gov/vs/ceah/cei/bse_italy0101.htm


>
> or what about these imports, did Mr. Brown forget about these?
>
> BOVINE ANMLS BNLSS EX PRCSSD FROZEN/U.S. IMPORTS FOR
> CONSUMPTION 1997 YEAR TO DATE;
>
> (Custom Value, in Thousands of Dollars)
> (Units of Quantity: Kilograms);
>
> "UNITED KINGDOM"; 37,122 KILOGRAMS, 43 THOUSAND DOLLARS
>
> "NETHERLANDS"; 56,260 KILOGRAMS, 413 THOUSAND DOLLARS
> "CANADA"; 18,141,481 KILOGRAMS, 23,914 MILLION DOLLARS
> LIVERS OF BOVINE ANIMALS, EDIBLE, FROZEN. U.S. IMPORTS FOR CONSUMPTION;
> "NETHERLANDS"; 19,230 KILOGRAMS, 25 THOUSAND DOLLARS
> "CANADA"; 160,632 KILOGRAMS, 147 THOUSAND DOLLARS
> TONGUES OF BOVINE ANIMALS, EDIBLE, FROZEN; U.S. IMPORTS FOR CONSUMPTION;
> "NETHERLANDS"; 1,047 KILOGRAMS, 4 THOUSAND DOLLARS
> "CANADA"; 767,859 KILOGRAMS, 2,028 MILLION
> HI-QULTY BEEF CUTS W/BONE IN PRCSSD F/C U.S. IMPORTS FOR CONSUMPTION;
> "CANADA" 25,332 KILOGRAMS, 37 THOUSAND DOLLARS
> BEEF CUTS W/BONE IN EXCPT PRCDSSD FR/CH U.S. IMPORTS FOR CONSUMPTION;
> "NETHERLANDS" 5,276 KILOGRAMS, 30 THOUSAND DOLLARS
> "CANADA" 117,142 KILOGRAMS, 353 THOUSAND DOLLARS
> MEAT BOVINE ANMLS CUTS W/BONE EX PRROCSSD FR US IMPORTS FOR CONSUMPTION;
> "NETHERLANDS" 51,836 KILOGRAMS, 444 THOUSAND DOLLARS
> "CANADA" 120,955,010 KILOGRAMS, 253,199 MILLION
> CATTLE HIDES, WHOLE, FRESH OR WET-SALT U.S. IMPORTS FOR CONSUMPTION;
> "BELGIUM" 1,270 PIECES, 112 THOUSAND DOLLARS
> "UNITED KINGDOM" 36 PIECES, 3 THOUSAND DOLLARS
> "IRELAND" 12,797 PIECES, 839 THOUSAND DOLLARS
> "ITALY" 50 PIECES, 10 THOUSAND DOLLARS
> "FR GERMANY" 2,500 PIECES, 36 THOUSAND DOLLARS
> "CANADA" 1,405,430 PIECES, 67,320 MILLION DOLLARS
> HIDES/SKINS BOVINE ANMLS NESOI WHOLE FRH/WET-SALTD U.S. IMPORTS FOR
> CONSUMPTION;
> "UNITED KINGDOM" 13 PIECES, 1 THOUSAND DOLLARS
> "ITALY" 4 PIECES, 4 THOUSAND DOLLARS "FR
> GERMANY" 9,455 PIECES, 139 THOUSAND DOLLARS
> "CANADA" 567,816 PIECES, 17,196 MILLION DOLLARS
> CATTLE HIDES, WHOLE, FRESH OR WET-SALTED U.S. IMPORTS FOR CONSUMPTION;
> 1998 YEAR TO DATE;
> "ITALY" 7 PIECES, 2 THOUSAND DOLLARS
> "IRELAND" 1,408 PIECES, 85 THOUSAND DOLLARS
> "FRANCE" 25 PIECES 2 THOUSAND DOLLARS
> "CANADA" 965,355 PIECES, 37,244 MILLION DOLLARS
> HIDES AND SKINS OF BOVINE ANIMALS, WHOLE, NESOI, FRESH OR WET-SALTED
> U.S. IMPORTS FOR CONSUMPTION
> "UNITED KINGDOM" 18 PIECES, 3 THOUSAND DOLLARS
> "SWEDEN" 1 PIECES, 1 THOUSAND DOLLARS
> "ITALY" 2 PIECES, 2 THOUSAND DOLLARS
> "FR GERMANY" 5,565 PIECES, 72 THOUSAND DOLLARS
> "CANADA" 84,327 PIECES, 2,257 MILLION DOLLARS
> SHEEP, LAMB SKINS, NO WOOL, NESOI, PICKLED NOT SPLIT, U.S. IMPORTS FOR
> CONSUMPTION;
> "UNITED KINGDOM" 9,504 PIECES, 88 THOUSAND DOLLARS
> SHEEP, LAMB SKINS, NO WOOL, NESOI, PICKLED, SPLIT U.S. IMPORTS FOR
> CONSUMPTION;
> "UNITED KINGDOM" 149,580 PIECES, 1,212 MILLION DOLLARS
> "NETHERLANDS" 50,400 PIECES, 267 THOUSAND DOLLARS
> "ITALY" 4,175 PIECES, 64 THOUSAND DOLLARS
> "FRANCE" 13,644 PIECES, 57 THOUSAND DOLLARS
> "CANADA" 131,642 PIECES, 241 THOUSAND DOLLARS
> CARCASSES AND HALF-CARCASSES OF SWINE, FROZEN U.S. IMPORTS FOR
> CONSUMPTION;
> "UNITED KINGDOM" 85,003 KILOGRAMS, 201 THOUSAND DOLLARS
> "NETHERLANDS" 24,000 KILOGRAMS, 33 THOUSAND DOLLARS
> "IRELAND" 24,567 KILOGRAMS, 39 THOUSAND DOLLARS
> "FR GERMANY" 23,032 KILOGRAMS, 32 THOUSAND DOLLARS
> "DENMARK" 112,345 KILOGRAMS, 168 THOUSAND DOLLARS
> "CANADA" 17,889 KILOGRAMS, 41 THOUSAND DOLLARS
> HAMS AND CUTS THEROF, BONE IN PROCESSED FRSH/CHLD U.S. IMPORTS FOR
> CONSUMPTION;
> "BELGIUM" 9,406 KILOGRAMS, 34 THOUSAND DOLLARS
> "CANADA" 95,515 KILOGRAMS, 172 THOUSAND DOLLARS
> "ITALY" 6,459 KILOGRAMS, 86 THOUSAND DOLLARS
>
> i could list many many more products of potential BSE/TSE sources
> from many different countries, but not enough room, so you can
> follow this thread and see what i have documented. follow the
> highlighted URLS at bottom of this message;
>
> http://www.vegsource.com/talk/lyman/messages/9910829.html


>
> please remember, this goes far far beyond just eating
> a bad hamburger...
>
> The Earl of Caithness asked her Majesty's Government:
>
> When the ban on the importation of embryos and live cattle from
> North America will be lifted; and [HL3912]
>
> What is the scientific evidence for the imposition of a ban on
> the importation of embryos and live cattle from North America. [HL3913]
>
> Lord Whitty: Her Majesty's Government have not imposed a ban on imports
> of bovine embryos and live cattle from North America.
>
> The European Parliament and European Council introduced legislation in
> May last year laying down rules for the prevention, control and
> eradication of certain transmissible spongiform encephalopathies (TSEs).
> The legislation was introduced in response to the recommendations of the
> Office International des Epizooties (OIE--the international animal health
> organisation) and advice from the Commission's scientific comittees. The
> legislation (and the transitional measures which came into effect in
> October last year) includes requirement that imports into the EU of
> bovine embryos and live cattle must be accompanied by certification
> confirming that the feeding of ruminants with protein derived from
> mammals has been banned and that the ban has been effectively enforced.
> Some exporting countries, such as Canada and the USA, are currently
> unable to meet these new requirements.
>
>

http://www.publications.parliament.uk/pa/ld199697/ldhansrd/pdvn/lds02/text/20425w04.htm#20425w04_sbhd2

TSS

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

suppressed peer review of Harvard study October 31, 2002

http://www.fsis.usda.gov/oa/topics/BSE_Peer_Review.pdf

=========
2006

MAD COW FEED RECALL USA EQUALS 10,878.06 TONS NATIONWIDE
Sun Jul 16, 2006 09:22
71.248.128.67


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

END OF ENFORCEMENT REPORT FOR July 12, 2006

###

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


BSE GBR ASSESSMENTS


http://www.efsa.eu.int/science/tse_assessments/gbr_assessments/catindex_en.html

EFSA Scientific Report on the Assessment of the Geographical BSE-Risk (GBR) of the United States of America (USA)
Last updated: 19 July 2005
Adopted July 2004 (Question N° EFSA-Q-2003-083)

Report
Summary
Summary of the Scientific Report

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

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

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

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



Publication date: 20 August 2004

http://www.efsa.eu.int/science/tse_assessments/gbr_assessments/573_it.html


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


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

Finding 2 Inherent Challenges in Identifying and Testing High-Risk Cattle
Still Remain Our prior report identified a number of inherent problems in
identifying and testing high-risk cattle. We reported that the challenges in
identifying the universe of high-risk cattle, as well as the need to design
procedures to obtain an appropriate representation of samples, was critical
to the success of the BSE surveillance program. The surveillance program was
designed to target nonambulatory cattle, cattle showing signs of CNS disease
(including cattle testing negative for rabies), cattle showing signs not
inconsistent with BSE, and dead cattle. Although APHIS designed procedures
to ensure FSIS condemned cattle were sampled and made a concerted effort for
outreach to obtain targeted samples, industry practices not considered in
the design of the surveillance program reduced assurance that targeted
animals were tested for BSE. In our prior report, we recommended that APHIS
work with public health and State diagnostic laboratories to develop and
test rabies-negative samples for BSE. This target group is important for
determining the prevalence of BSE in the United States because rabies cases
exhibit clinical signs not inconsistent with BSE; a negative rabies test
means the cause of the clinical signs has not been diagnosed. Rabies
Negative Samples APHIS agreed with our recommendation and initiated an
outreach program with the American Association of Veterinary Laboratory
Diagnosticians, as well as State laboratories. APHIS also agreed to do
ongoing monitoring to ensure samples were obtained from this target
population. Although APHIS increased the samples tested from this target
group as compared to prior years, we found that conflicting APHIS
instructions on the ages of cattle to test resulted in inconsistencies in
what samples were submitted for BSE testing. Therefore, some laboratories
did not refer their rabies negative samples to APHIS in order to maximize
the number tested for this critical target population. In addition, APHIS
did not monitor the number of submissions of rabies negative samples for BSE
testing from specific laboratories. According to the Procedure Manual for
BSE Surveillance, dated October 2004, the target population includes:
Central nervous system (CNS) signs and/or rabies negative - sample animals
of any age (emphasis added): a. Diagnostic laboratories –samples submitted
due to evidence of CNS clinical signs.
USDA/OIG-A/50601-10-KC Page 19
USDA/OIG-A/50601-10-KC Page 20
b. Public health laboratories – rabies negative cases. c. Slaughter
facilities – CNS ante mortem condemned at slaughter, sampled by FSIS. d.
On-the-farm – CNS cattle that do not meet the criteria for a foreign animal
disease investigation. For FYs 2002, 2003, and 2004 (through February 2004),
NVSL received 170, 133, and 45 rabies-negative samples, respectively.
Between June 1, 2004, and May 29, 2005, the number of samples received for
testing increased to 226 rabies suspect samples. The collection sites
submitting these samples follow. Collection Site Number of Rabies Suspect
Submissions * Slaughter Plant 0 Renderer 2 On-Farm 11 Public Health Lab 94
Diagnostic Lab 81 3D-4D 8 Other 4 Total 200 * 26 were tested but not counted
by APHIS towards meeting the target goals because the obex was not
submitted. We obtained a copy of a memorandum, dated July 13, 2004, that
APHIS sent to diagnostic and public health laboratories providing them
instructions on submitting samples for cattle showing signs of CNS diseases,
but testing negative for rabies. The letter was sent to about 170 State
veterinary diagnostic and public health laboratories and discussed the need
to submit specimens to NVSL of all adult cattle (emphasis added) that showed
signs of CNS diseases, but tested negative for rabies. This directive did
not specify the age of the cattle. The Procedure Manual for BSE
Surveillance, dated October 2004, specified samples of cattle of any age
should be submitted. We contacted laboratories in six States to determine if
it was standard procedure to submit all negative rabies samples to NVSL. We
found that, because of the lack of specificity in the APHIS letter and
inadequate followup by APHIS, there were inconsistencies in the age of
cattle samples submitted for BSE testing. For those States contacted, the
following samples were submitted versus tested as negative for rabies.
USDA/OIG-A/50601-10-KC Page 21
Rabies Negative Tests Not Sent for BSE Testing Since June 1, 2004 State
Negative Rabies Tests Sent for BSE Testing Not Sent for BSE Testing
Pennsylvania a/ 33 15 18 Kansas b/ 85 69 16 Wisconsin c/ 12 1 11 South
Dakota d/ 7 0 7 Arizona e/ 5 5 0 Mississippi e/ 4 4 0 Total 146 94 52 a/ A
Pennsylvania laboratory official said only rabies negative cattle over 20
months of age were submitted for BSE testing. The laboratory did not submit
18 samples for BSE testing because the animals were less than 20 months of
age. b/ Kansas laboratory officials said early in the expanded surveillance
program, there was confusion as to the cattle ages that should be submitted
for BSE testing. They did not know if cattle should be submitted that were
above 20 months or 30 months of age. Of the 16 animals not submitted for BSE
testing, 14 were under 20 months of age from early in the expanded
surveillance program. The other two animals were not tested due to internal
laboratory issues. The Kansas and Nebraska area office officials contacted
the laboratory and told the officials to submit rabies negative cattle of
any age for BSE testing. The laboratory now submits all rabies negative
cattle for BSE testing. c/ A Wisconsin laboratory official said only rabies
negative cattle samples 30 months of age or older are submitted for BSE
testing. Of the 11 animals not submitted for BSE testing, 8 were less than
30 months of age. Wisconsin laboratory officials were not certain why the
other three samples were not submitted. d/ Laboratory officials from South
Dakota said they did not receive notification from APHIS regarding the
submission of rabies negative cases for BSE testing. The section supervisor
and laboratory director were not aware of any letter sent to the laboratory.
The section supervisor said most bovine rabies tests at the laboratory are
performed on calves. We confirmed the laboratory’s address matched the
address on APHIS’ letter distribution list. However, there was no evidence
that the South Dakota area office contacted the laboratory. The laboratory
was not listed on the documentation from the APHIS regional office detailing
the area office contacts with laboratory personnel. We contacted the South
Dakota area office and were advised that while some contact had been made
with the laboratory, the contact may have involved Brucellosis rather than
BSE. On May 4, 2005, the area office
advised us they recently contacted the laboratory regarding the submission
of rabies negative samples for BSE testing. e/ Arizona and Mississippi
laboratory officials said they submitted all rabies negative samples for BSE
testing regardless of the age of the animal. An NVSL official stated that
APHIS is not concerned with rabies negatives samples from cattle less than
30 months of age. This position, however, is contrary to APHIS’ published
target population. Our prior audit recognized the significant challenge for
APHIS to obtain samples from some high-risk populations because of the
inherent problems with obtaining voluntary compliance and transporting the
carcasses for testing. USDA issued rules to prohibit nonambulatory animals
(downers) from entering the food supply at inspected slaughterhouses. OIG
recommended, and the International Review Subcommittee33 emphasized, that
USDA should take additional steps to assure that facilitated pathways exist
for dead and nonambulatory cattle to allow for the collection of samples and
proper disposal of carcasses. Between June 1, 2004, and May 31, 2005, the
APHIS database documents 27,617 samples were collected showing a reason for
submission of nonambulatory and 325,225 samples were collected with reason
of submission showing “dead.” Downers and Cattle that Died on the Farm APHIS
made extensive outreach efforts to notify producers and private
veterinarians of the need to submit and have tested animals from these
target groups. They also entered into financial arrangements with 123
renderers and other collection sites to reimburse them for costs associated
with storing, transporting, and collecting samples. However, as shown in
exhibit F, APHIS was not always successful in establishing agreements with
non-slaughter collection sites in some States. APHIS stated that agreements
do not necessarily reflect the entire universe of collection sites and that
the presentation in exhibit F was incomplete because there were many
collection sites without a payment involved or without a formal agreement.
We note that over 90 percent of the samples collected were obtained from the
123 collection sites with agreements and; therefore, we believe agreements
offer the best source to increase targeted samples in underrepresented
areas. We found that APHIS did not consider industry practices in the design
of its surveillance effort to provide reasonable assurance that cattle
exhibiting possible clinical signs consistent with BSE were tested.
Slaughter facilities do not always accept all cattle arriving for slaughter
because of their business requirements. We found that, in one State visited,
slaughter facilities pre-screened and rejected cattle (sick/down/dead/others
not meeting business
USDA/OIG-A/50601-10-KC Page 22
33 Report from the Secretary’s Advisory Committee on Foreign Animal and
Poultry Diseases, February 13, 2004.
USDA/OIG-A/50601-10-KC Page 23
standards) before presentation for slaughter in areas immediately adjacent
or contiguous to the official slaughter establishment. These animals were
not inspected and/or observed by either FSIS or APHIS officials located at
the slaughter facilities. FSIS procedures state that they have no authority
to inspect cattle not presented for slaughter. Further, APHIS officials
stated they did not believe that they had the authority to go into these
sorting and/or screening areas and require that the rejected animals be
provided to APHIS for BSE sampling. Neither APHIS nor FSIS had any process
to assure that animals left on transport vehicles and/or rejected for
slaughter arrived at a collection site for BSE testing. FSIS allows
slaughter facilities to designate the area of their establishment where
federal inspection is performed; this is designated as the official
slaughter establishment.34 We observed animals that were down or dead in
pens outside the official premises that were to be picked up by renderers.
Animals that were rejected by plant personnel were transported off the
premises on the same vehicles that brought them to the plant.35 A policy
statement36 regarding BSE sampling of condemned cattle at slaughter plants
provided that effective June 1, 2004, FSIS would collect BSE samples for
testing: 1) from all cattle regardless of age condemned by FSIS upon ante
mortem inspection for CNS impairment, and 2) from all cattle, with the
exception of veal calves, condemned by FSIS upon ante mortem inspection for
any other reason. FSIS Notice 28-04, dated May 20, 2004, informed FSIS
personnel that, “FSIS will be collecting brain samples from cattle at
federally-inspected establishments for the purpose of BSE testing.” The
notice further states that, “Cattle off-loaded from the transport vehicle
onto the premises of the federally-inspected establishment (emphasis added),
whether dead or alive, will be sampled by the FSIS Public Health
Veterinarian (PHV) for BSE after the cattle have been condemned during ante
mortem inspection. In addition, cattle passing ante mortem inspection but
later found dead prior to slaughter will be condemned and be sampled by the
FSIS PHV.” 34 FSIS regulations do not specifically address the designation
of an establishment’s “official” boundaries; however, FSIS Notices 29-04
(dated May 27, 2004) and 40-04 (dated July 29, 2004) make it clear that FSIS
inspection staff are not responsible for sampling dead cattle that are not
part of the “official” premises. 35 APHIS’ area office personnel stated that
it was their understanding that some establishments in the State were not
presenting cattle that died or were down on the transport vehicle to FSIS
for ante mortem inspection. The dead and down cattle were left in the
vehicle, if possible. In rare circumstances, dead cattle may be removed from
the trailer by plant personnel to facilitate the unloading of other animals.
36 A May 20, 2004, Memorandum between the Administrators of APHIS and FSIS.
USDA/OIG-A/50601-10-KC Page 24
APHIS has the responsibility for sampling dead cattle off-loaded onto
plant-owned property that is adjoining to, but not considered part of, the
“official premises.37 FSIS procedures38 provide that “Dead cattle that are
off-loaded to facilitate the off-loading of live animals, but that will be
re-loaded onto the transport vehicle, are not subject to sampling by FSIS.
While performing our review in one State, we reviewed the circumstances at
two slaughter facilities in the State that inspected and rejected unsuitable
cattle before the animals entered the official receiving areas of the
plants. This pre-screening activity was conducted in areas not designated by
the facility as official premises of the establishment and not under the
review or supervision of FSIS inspectors. The plant rejected all
nonambulatory and dead/dying/sick animals delivered to the establishment.
Plant personnel refused to offload any dead or downer animals to facilitate
the offloading of ambulatory animals. Plant personnel said that the driver
was responsible for ensuring nonambulatory animals were humanely euthanized
and disposing of the carcasses of the dead animals. Plant personnel informed
us that they did not want to jeopardize contracts with business partners by
allowing unsuitable animals on their slaughter premises. In the second case,
one family member owned a slaughter facility while another operated a
livestock sale barn adjacent to the slaughter facility. The slaughter
facility was under FSIS’ supervision while the sale barn was not. Cattle
sometimes arrived at the sale barn that were sick/down/dead or would die or
go down while at the sale barn. According to personnel at the sale barn,
these animals were left for the renderer to collect. The healthy ambulatory
animals that remained were marketed to many buyers including the adjacent
slaughter facility. When the slaughter facility was ready to accept the
ambulatory animals for processing, the cattle would be moved from the sale
barn to the slaughter facility where they were subject to FSIS’ inspection.
We requested the slaughter facilities to estimate the number of cattle
rejected on a daily basis (there were no records to confirm the estimates).
We visited a renderer in the area and found that the renderer had a contract
with APHIS to collect samples for BSE testing. In this case, although we
could not obtain assurance that all rejected cattle were sampled, the
renderer processed a significant number of animals, as compared to the
slaughter plants’ estimates of those rejected. Due to the close proximity
(less than 5 miles) of the renderer to the slaughter facilities, and the
premium it paid for dead cattle that were in good condition, there was a
financial incentive for transport drivers to dispose of their dead animals
at this renderer. 37 FSIS Notice 40-04, dated July 29, 2004. 38 FSIS Notice
29-04, dated May 27, 2004.
USDA/OIG-A/50601-10-KC Page 25
In our discussions with APHIS officials in Wisconsin and Iowa, they
confirmed that there were plants in their States that also used
pre-screening practices. On May 27, 2005, we requested APHIS and FSIS to
provide a list of all slaughter facilities that pre-screened cattle for
slaughter in locations away from the area designated as the official
slaughter facility. Along with this request, we asked for information to
demonstrate that either APHIS or FSIS confirmed there was a high likelihood
that high-risk animals were sampled at other collection sites. In response
to our request, the APHIS BSE Program Manager stated that APHIS did not have
information on slaughter plants that pre-screen or screen their animals for
slaughter suitability off their official plant premises. To their knowledge,
every company or producer that submits animals for slaughter pre-sorts or
screens them for suitability at various locations away from the slaughter
facility. For this reason, USDA focused its BSE sample collection efforts at
other types of facilities such as renderers, pet food companies, landfills,
and dead stock haulers. Further, in a letter to OIG on June 14, 2005, the
administrators of APHIS and FSIS noted the following: “…we believe that no
specific actions are necessary or appropriate to obtain reasonable assurance
that animals not presented for slaughter are being tested for BSE. There are
several reasons for our position. First, we do not believe that the practice
is in fact causing us to not test a significant enough number of animals in
our enhanced surveillance program to invalidate the overall results. Second,
OIG has concluded that because of the geographical proximity and business
relationships of the various entities involved in the case investigated,
there is reasonable assurance that a majority of the rejected cattle had
been sampled. Third, it is also important to remember that the goal of the
enhanced surveillance program is to test a sufficient number of animals to
allow us to draw conclusions about the level of BSE (if any) in the American
herd…We believe that the number we may be not testing because of the
“pre-sorting” practice does not rise to a significant level. The number of
animals tested to date has far exceeded expectations, so it is reasonable to
infer that there are few of the animals in question, or that we are testing
them at some other point in the process…APHIS estimated…there were
approximately 446,000 high risk cattle…[and APHIS has]…tested over 375,000
animals in less than 1 year. This indicated that we are missing few animals
in the high-risk population, including those that might be pre-sorted before
entering a slaughter facility’s property.” We obtained 123 APHIS sampling
agreements and contracts with firms and plotted their locations within the
United States (see exhibit F). We also analyzed the samples tested to the
BSE sampling goals allocated to each State under the prior surveillance
program. This analysis showed that there are
USDA/OIG-A/50601-10-KC Page 26
sampling gaps in two large areas of the United States where APHIS did not
have contracts with collection sites. These two areas are shown in the
following chart (Montana, South Dakota, North Dakota and Wyoming – Group 1
and Louisiana, Oklahoma, Arkansas, and Tennessee – Group 2): State Original
Sampling Goal Based on (268,500 sampling goal) Samples collected as of May
31, 2005 Deficit No. of BSE Sampling Agreements/ Contracts39MT 5,076 182
4,894 2 SD 6,938 2,792 4,146 1 ND 3,616 174 3,442 0 WY 2,513 61 2,452 0 AREA
TOTAL 14,934 OK 7,792 2,407 5,385 1 AR 3,672 353 3,319 0 TN 4,938 3,050
1,888 1 LA 2,312 452 1,860 1 AREA TOTAL 12,452 APHIS notes that for the
current surveillance program, it had established regional goals and APHIS
was not trying to meet particular sampling levels in particular States.
However, we believe that it would be advantageous for APHIS to monitor
collection data and increase outreach when large geographical areas such as
the above States do not provide samples in proportion to the numbers and
types of cattle in the population. We also disagree with APHIS/FSIS’
contention that because they have tested over 375,000 of their 446,000
estimate of high risk cattle, few in the high-risk population are being
missed, including those that might be pre-screened before entering a
slaughter facility’s property. In our prior audit, we reported that APHIS
underestimated the high-risk population; we found that this estimate should
have been closer to 1 million animals (see Finding 1). We recognize that BSE
samples are provided on a voluntary basis; however, APHIS should consider
industry practice in any further maintenance surveillance effort. Animals
unsuitable for slaughter exhibiting symptoms not inconsistent with BSE
should be sampled and their clinical signs recorded. However, this cited
industry practice results in rejected animals not being made available to
either APHIS or FSIS veterinarians for their observation and identification
of clinical signs exhibited ante mortem. Although these animals may be
sampled later at other collection sites, the animals are provided post
mortem without information as to relevant clinical signs exhibited ante
mortem. For these reasons, we believe APHIS needs to 39APHIS noted that
sites with agreements do not necessarily reflect the entire universe of
collection sites and at some sites APHIS collects samples with no payment
involved and no agreement in place. OIG agrees that not all collection sites
are reflected in our presentation of the 123 sites with reimbursable
agreements. OIG believes obtaining sampling agreements is one of the primary
methods available to increase sample numbers in areas with sampling gaps.
USDA/OIG-A/50601-10-KC Page 27
observe these animals ante mortem when possible to assure the animals from
the target population are ultimately sampled and the clinical signs
evaluated. Recommendation 3.......

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


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