Follow Ups | Post Followup | Back to Discussion Board | VegSource
See spam or
inappropriate posts?
Please let us know.

From: TSS ()
Subject: The State of BSE Surveillance Efforts in the United States
Date: October 17, 2005 at 8:44 am PST

Current Issue … Select Articles October 15, 2005
Point Of View
The State of BSE Surveillance Efforts in the United States
Questions and Recommendations
Wenonah Hauter
The USDA's testing program for Bovine Spongiform Encephalopathy (BSE) is a key component of our firewall against the spread of the disease. There is no test for BSE that can be done on live animals or in beef; therefore, testing the brains of cattle after they are slaughtered is the point where surveillance for BSE takes place.

In the wake of the announcement of the third case of BSE in the U.S., the adequacy of the USDA's testing program is as importantand unclearas it has ever been.

Questions about the USDA's testing program are not new. In the early days of BSE testing, USDA performed only a few hundred tests per year. By 2002, the testing rate had increased to approximately 20,000 per year.

But when Public Citizen and the Government Accountability Project analyzed USDA's data from 1997 through 2000, we found unexplainable variation in the rate of testing between various parts of the country. The testing rate ranged from 1,004 brains per million cattle slaughtered in New York to 0.5 brains per million cattle in Kansas, and attempts to adjust for the age of the cattle slaughtered or their feed did not account for the massive variations in testing rates between states.

Since the United States' first BSE-positive cow was found in December 2003, the USDA has revamped its testing program. But our list of questions about the design and execution of the program has actually gotten longer.

1. Is the downer-cow ban rule going to be changed? USDA has indicated that it has been testing all downer cows because this is the population of animals that has the greatest likelihood of exhibiting BSE symptoms.

One of the BSE interim regulations that USDA put in place on January 12, 2004, was to prohibit "non-ambulatory, disabled" cattle, or downer cows, from entering the human food supply. In recent months, however, the new Secretary of Agriculture, Mike Johanns, has indicated in at least two congressional hearings that he is considering a relaxation of that ban because industry has been complaining that injured cattle that do not have BSE are being prevented from being slaughtered.

This is a deviation from the "out of abundance of caution" standard that USDA had been using since the December 2003 BSE case.

2. How long will "enhanced" testing last? Last spring, USDA announced the start of an "enhanced" surveillance program. Agency officials always made a point to say that this was intended to provide a one-time snapshot, not establish a permanent level of testing. After surpassing their original goal of 270,000 tests, the accelerated testing rate has continued. As of July, more than 400,000 tests had been performed.

At a recent meeting with consumer groups, Ron DeHaven, the administrator for USDA's Animal and Plant Health Inspection Service, said that they were looking at different funding sources to continue the enhanced surveillance program in light of the most recent case of BSE found in Texas but there is nothing definite.

3. Which animals are being tested? The agency has been quite forthcoming about one aspect of their programthe total number of tests performed. We don't know how the tests are distributedby geography, by age of animal, or by type of facility where animals are selected (dead and downer cattle go to rendering plants while tests on other animals would take place at slaughterhouses).

4. Why are no healthy animals being tested? Contrary to initial descriptions of the intensive testing program, which said that 20,000 healthy animals would be included, recent agency statements indicate that no healthy cattle have been tested. Recently, the Japanese Agriculture Ministry found that had they used the U.S. testing system, nearly half of their 20 cases of BSE would have gone undetected.

5. What happened in November? Last fall, rapid testing on a cow in Texas came up as inconclusive. The agency ordered a confirmatory test at the agency's lab in Ames, Iowa, and announced that they were waiting to have it confirmed. Then they happily announced that the cow was negative. What they failed to mention were the serious lapses in the handling of the brain sample, and that a third "experimental" test had come back positive.

Months later, an investigation by the USDA's Inspector General revealed inconsistencies in the testing program that led to a re-test. And seven months later, the public found out that the second case of BSE in the U.S. had been discovered.

Despite a seven-month delay and circumstances that at worst look like a cover-up and at best seem to indicate gross incompetence, USDA officials actually claimed that this case somehow shows that "the system worked."

6. Why can't private companies do their own testing? Testing is a crucial sticking point in negotiations to re-open the Japanese market to U.S. beef. One company, Creekstone Farms Premium Beef, thought they had come up with a way to give their Japanese customers what they want. In 2004, the company requested that USDA issue them a license for the use of rapid tests. USDA said no, and to date, no private company is doing their own BSE testing.

We still don't have answers to all these questions. But we do know we would recommend a stronger BSE surveillance program:

More testing. The agency should be testing all cattle over 20 months of age at slaughter. All downers and "suspect" (exhibiting signs of nervous system problems or rabies) animals should be tested, even if they don't go to slaughter. This level of commitment to detecting the disease could restore consumer confidenceincluding in major export markets like Japan where consumers are demanding testing of all cattle.

More transparency. The agency should be disclosing more than just the number of tests. Which animals get tested, and where, are all important indications of how well the testing program is going to work.

More consistency. USDA must design a consistent policy that exhausts every testing option available when there is an inconclusive rapid test result to avoid the type of confusion and delay that happened with the second case.

No monopoly on testing. USDA should allow companies to do their own testing, with the requirement that positive results must be reported to the government, and USDA inspectors and veterinarians have access to company testing records.

Contrary to the USDA's attempts to portray the second case of BSE as an indication that "the system worked," it should really serve as a wake-up call.

The USDA has known about the weaknesses in their testing program for years, and failed to take the necessary steps to adequately protect consumers from this disease. It is past time for them to act.

Wenonah Hauter is director of the food safety program at Public Citizen, a Washington, D.C.-based consumer advocacy organization with 150,000 members. Website:

Oct. 4, 2005

New Animal Feed Rules Still Leave Consumers at Risk for Mad Cow Disease

Statement by Wenonah Hauter, Director, Public Citizen’s Food Program

The U.S. Food and Drug Administration’s (FDA) proposed regulations governing animal feed – critical to preventing the spread of bovine spongiform encephalopathy (BSE) – are still too weak to protect consumers.

The proposed rules would ban the use of some cattle tissues in animal feed in an attempt to limit the potential for cross-contamination during feed production or the potential for transmitting BSE through mistakenly feeding cattle food intended for other animals. Specifically, the following would be banned: the brains and spinal cords of cattle over 30 months of age, the brains and spinal cords from cattle that have not been inspected and approved for human consumption, and all tissues from cattle that have not been inspected and approved for human consumption if the brain and spinal cord are not removed. But the FDA would still allow the brain and spinal cord from younger cattle, as well as other nervous system tissues from all cattle to be used in animal feed.

This proposal does not live up to the promise the FDA made to American consumers on Jan. 26, 2004, when the agency announced that it was going to take immediate action to strengthen the firewalls against BSE. At the time, Health and Human Services Secretary Tommy Thompson stated: “Small as the risk may already be, this is the time to make sure the public is protected to the greatest extent possible.”

Almost two years after Thompson’s statement, gaping holes in the animal feed ban still exist. The current “feed ban,” which took effect in 1997, still allows the use of cattle blood, waste from the floors of poultry houses, and processed restaurant and food plate waste to be fed to cattle. The new rules will not address these loopholes and will still allow the use of rendered cattle remains, including some nervous system tissues, in feed for hogs and poultry. Because hog and poultry remains can be put back into cattle feed, the pathways for the disease to spread will still exist.

The rules also fail to meet recommendations made by a team of international animal health experts in February 2004, after their investigation into the U.S. government’s response to the first U.S. case of BSE. The international team recommended a complete ban on the use of mammalian protein in cattle feed as a precaution against cross contamination. The team also called for a ban on the use of bovine specified risk materials (SRMs) in all animal feed. Instead, the proposed rules announced by the agency today address only some of the risk materials, ignoring the tonsils, eyes, small intestines and other tissues that are considered to be SRMs in cattle over 30 months old.

As recently as last month, former FDA Commissioner Lester Crawford publicly stated that the agency was developing a rule that would parallel changes already under way in Canada, including a complete ban on SRMs in animal feed. Yet the proposal released today fails to meet this standard.

Feed regulations that are truly protective of animal and public health must incorporate a ban on all bovine SRMs in all animal feed and end the exemptions for blood, plate waste and poultry litter. Until these changes are made by FDA, consumers will remain at risk.

The FDA’s new rules are available here.

see failed promises or lies, here ;


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

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

Animal Food or Feed; Animal Proteins Prohibited in Ruminant Feed

Comment Number: EC -10

Accepted - Volume 2



Follow Ups:

Post a Followup

E-mail: (optional)


Optional Link URL:
Link Title:
Optional Image URL: