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From: TSS ()
Subject: Technical Service Center IKE Interactive Knowledge Exchange FSIS/SRM/BSE
Date: December 26, 2005 at 10:09 am PST

Technical Service Center
The TSC serves as the Agency's center for technical assistance, advice, and guidance regarding the implementation of national policies, programs, systems, and procedures including implementation of the farm-to-table food safety strategy within a HACCP framework. The TSC also assists in the implementation of this strategy and serves as the feedback mechanism relating to changes and refinements in existing systems and procedures.

TSC Mission Statement
The role of the TSC is to assist decision making by providing all parties with the standards and other technical information needed to understand, implement, apply, and enforce regulatory requirements.

TSC Structure

Technical Assistance/Correlation Division (TAC)
Program Analysis Staff (PAS)

Interactive Knowledge Exchange (IKE)
IKE is a tool available to all Field Operations employees. Through the use of fictional scenarios, IKE allows employees to review FSIS requirements, and hopefully, to correlate with his or her work-group and supervisor regarding the application of those requirements. Also available on the IKE homepage are the following links:
Technical Guidance Documents
Guidance for meat, poultry, egg products, and retail and foodservice establishments in hurricane-affected areas that identifies food safety factors establishments should consider as they resume operations.
IKE Comment Page
IKE Scenario 06-05 is now available.


SRM Guidance Material
FSIS provides assistance to inspection program personnel in performing their verification activities as outlined in the interim final rule issued to amend 9 CFR 310.22(a)(3) of its regulations for the removal, segregation, and disposition of specified risk materials (SRMs).
Photograph 1 - Basic anatomical features to help determine the location of the most distal point of the distal ileum portion of the small intestine. (PDF only)
http://www.fsis.usda.gov/PDF/TSC_SRM_Cecum_Ileum.pdf
Photograph 2 - View of the ileocecal junction. (PDF only)
http://www.fsis.usda.gov/PDF/TSC_SRM_Ileocecal_Junction.pdf
Photograph 3 - View the uncoiling and trimming of the distal ileum proximal to the ileocecal junction. (PDF only)
http://www.fsis.usda.gov/PDF/TSC_SRM_Trimmed_Uncoiled_Ileum.pdf


BSE Guidance Material
Using Dentition to Age Cattle
Despite individual differences, when the age of an animal is not known, examination of the teeth serves as the best and most practical method of age determination.
Information and diagrams on the acceptable removal of tonsils from cattle for purposes of 9 CFR 310.22.
Visual diagrams and information provided in support of FSIS Notice 50-04

http://www.fsis.usda.gov/About_FSIS/Technical_Service_Center/index.asp


http://www.usda.gov/Newsroom/0264.04.html


http://www.usda.gov/Newsroom/0273.04.html


http://www.usda.gov/Newsroom/0289.04.html


Greetings,

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,
i will say nothing. it's going to be a quiet 2006. the betting lines are open at;
1-800-dontgiva ;-)

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 ;


Section
Title
File Format
Updated
Complete Manual The Complete BSE Surveillance Manual pdf 9.3mb 10/01/04 What's New Changes from the previous version html 17kb
10/01/04

Title Page
Contents

pdf 30kb
pdf 32kb
10/01/04
08/24/04
Procedure Manual Procedure Manual for BSE Surveillance pdf 420kb 10/01/04 Appendix A Procedures for investigations and
surveillance of targeted cattle for bovine spongiform encephalopathy (BSE) pdf 1.14mb 08/24/04 Appendix B BSE Surveillance Plan pdf 67kb 08/24/04 Appendix C State-level Surveillance Plan Templates pdf 80kb 08/24/04 Appendix D Sampling Job Aid pdf 1.6mb 08/24/04 Appendix E Taking a Quality Sample pdf 346kb 08/24/04 Appendix F AVIC Directory pdf 27kb 09/09/04 Appendix G Forms pdf 953kb 08/24/04 Appendix H Barcodes pdf 99kb 08/24/04 Appendix I Determining the Age of the Cattle pdf 888kb 08/24/04 Appendix J Background on BSE pdf 31kb 08/24/04 Appendix K FSIS Documents pdf 1.3mb 08/24/04 Appendix L Outreach Materials pdf 357kb 08/24/04 Appendix M Veterinary Services Memorandum NO. 580.4 – Procedures for Investigating a Suspected Foreign Animal Disease/Emerging Disease Incident (FAD/EDI) pdf 2.4mb 08/24/04


http://www.aphis.usda.gov/vs/nvsl/BSE/specimencollectionbse.htm


[Docket No. 03-025IFA] FSIS Prohibition of the Use of Specified Risk Materials for Human Food and Requirement for the Disposition of Non-Ambulatory Disabled Cattle

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


Page 1 of 17

From: Terry S. Singeltary Sr. [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 ;


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

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


USA BSE RED BOOK

> October 1998
>
> BSE Red Book 2.1-36
>

> 7.2.1.7 Laboratory Coordination--The Laboratory Coordination Officer
> will advise the READE(3 Director concerning laboratory capabilities and
> appropriate laboratory examinations to be conducted to provide needed
> results as rapidly as possible. This individual will assist with
> interpretation of results.

> BSE Red Book 2.1-39
>
> 7.6 Depopulation Procedures
>
> Under no
> circumstances may BSE suspects be sent fo slaughhter or rendering.


snip...

> BSE Red Book 2.1-40
>
> 7.7 Disposal
> Under no circumstances may BSE suspects be sent to slaughter or
> rendering. Notify FDA, CVM if you suspect that the carcass of a
> BSE-confirmed animal has moved to rendering or animal feed
> manufacturing. Field personel should arrange for the carcass to be
> transported to and examined by a qualified veterinary pathologist or
> field veterinary medical officer. After the pathologic examination has
> been completed and the necessary diagnostic specimens have been
> obtained, field personnel should arrange for disposal of the carcass.
> Before a method of disposal is selected, there are many factors that
> must be considered, and often other State and Federal agencies must be
> consulted. The environmental and legal impacts of the operation must be
> considered. Upon recommendation of the State or Federal agencies, VS may
> consider other disposal methods.
>
snip...

> 7.7.3 Rendering
> Because BSE is spread by rendered animal protein, BSE-suspect and
> confirmed carcasses must not be rendered, unless the rendered material
> is incinerated. Notify FDA, CVM if you suspect that dead BSE animals or
> carcasses have moved to rendering or animal feed manufacturing.
>

snip...

> 7.10.11 Prevention--Suspects and animals confirmed to have BSE must not
> be rendered. Producers, feed mills, and rendering establishments should
> adhere to U.S. State and local rendering policies and FDA regulations
> concerning the feeding of rendered animal protein to ruminants.


snip...

If additional tests do suggest a
presumptive diagnosis of BSE, an NVSL pathologist will hand carry the
sample to the United Kingdom for confirmation. It is at this critical
point, when NVSL suggests a diagnosis of BSE and is preparing to send
the sample to the United Kingdom, that this BSE Response Plan is
initiated. The Plan begins the preliminary notification from NVSL to
APHIS. Preliminary Notification The director of NVSL is responsible for
immediately notifying the APHIS, Veterinary Services (VS) deputy
administrator when tests suggest a presumptive diagnosis of BSE. Once
NVSL has made a presumptive diagnosis of BSE, APHIS and FSIS field
activities will also be initiated. APHIS will receive notification
(either confirming or not confirming NVSL's diagnosis) from the United
Kingdom anywhere between 24 and 96 hours. (The international animal
health community has recognized the United Kingdom's Central Veterinary
Laboratory {CVL} as the world's reference laboratory for diagnosing BSE.
Other countries, including Belgium, France, Ireland, Luxembourg, the
Netherlands, Portugal, and Switzerland, have all sent samples to this
lab to confirm their first case of BSE).

snip...


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


FOR IMMEDIATE RELEASE
Statement
May 4, 2004
Media Inquiries: 301-827-6242
Consumer Inquiries: 888-INFO-FDA


Statement on Texas Cow With Central Nervous System Symptoms
On Friday, April 30 th , the Food and Drug Administration learned that a cow with central nervous system symptoms had been killed and shipped to a processor for rendering into animal protein for use in animal feed. ...

http://www.fda.gov/bbs/topics/news/2004/NEW01061.html



Statement by Chief Veterinary Medical Officer John Clifford Animal and Plant Health Inspection Service Regarding Non-Definitive BSE Test Results
July 27, 2005

snip...


The veterinarian treated the sample with a preservative, which readies it for testing using the immunohistochemistry (IHC) test —an internationally recognized confirmatory test for BSE. Neither the rapid screening test nor the Western blot confirmatory test can be conducted on a sample that has been preserved.

snip...


I would note that the sample was taken in April, at which time the protocols allowed for a preservative to be used (protocols changed in June 2005). The sample was not submitted to us until last week, because the veterinarian set aside the sample after preserving it and simply forgot to send it in.

http://www.aphis.usda.gov/lpa/news/2005/07/bsestatement_vs.html


"Earlier this week, USDA's Office of the Inspector General (OIG), which has been partnering with the Animal and Plant Health Inspection Service, the Food Safety and Inspection Service, and the Agricultural Research Service by impartially reviewing BSE-related activities and making recommendations for improvement, recommended that all three of these samples be subjected to a second internationally recognized confirmatory test, the OIE-recognized SAF immunoblot test, often referred to as the Western blot test. We received final results a short time ago. Of the three samples, two were negative, but the third came back reactive.

"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



"Each was then followed up with an IHC test. Each confirmatory IHC test was negative. The Inspector General, in reviewing our surveillance system that we have in place, decided to retest with a second confirmatory test which is called the Western Blot. We have received test results showing a positive on one animal for the Western Blot.


http://www.usda.gov/wps/portal/!ut/p/_s.7_0_A/7_0_1OB?contentidonly=true&contentid=2005/06/0207.xml


ONE YEAR LATER, not 24 to 96 hours (this is what i call mad cow market timing)


STATEMENT BY DR. JOHN CLIFFORD REGARDING FURTHER ANALYSIS OF BSE TEST RESULTS IN WEYBRIDGE, ENGLAND
June 16, 2005

"Today, an official with USDA's National Veterinary Services Laboratory departed for Weybridge, England, hand-carrying samples for further testing.


http://www.usda.gov/wps/portal/!ut/p/_s.7_0_A/7_0_1OB?contentidonly=true&contentid=2005/06/0218.xml


"So let me start first with the test results. As you are aware, last November we had an inconclusive report from a rapid screening test. USDA then conducted two IHC confirmatory tests, and both came out negative. A few weeks ago an additional confirmatory test was conducted, and that test is referred to as the Western blot test.

"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
BSE Roundtable Discussion Transcript

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 ;


USDA 2003

We have to be careful that we don't get so set in the way we do things that
we forget to look for different emerging variations of disease. We've gotten
away from collecting the whole brain in our systems. We're using the brain
stem and we're looking in only one area. In Norway, they were doing a
project and looking at cases of Scrapie, and they found this where they did
not find lesions or PRP in the area of the obex. They found it in the
cerebellum and the cerebrum. It's a good lesson for us. Ames had to go
back and change the procedure for looking at Scrapie samples. In the USDA,
we had routinely looked at all the sections of the brain, and then we got
away from it. They've recently gone back.
Dr. Keller: Tissues are routinely tested, based on which tissue provides an
'official' test result as recognized by APHIS
.

Dr. Detwiler: That's on the slaughter. But on the clinical cases, aren't
they still asking for the brain? But even on the slaughter, they're looking
only at the brainstem. We may be missing certain things if we confine
ourselves to one area.


snip.............


Dr. Detwiler: It seems a good idea, but I'm not aware of it.
Another important thing to get across to the public is that the negatives
do not guarantee absence of infectivity. The animal could be early in the
disease and the incubation period. Even sample collection is so important.
If you're not collecting the right area of the brain in sheep, or if
collecting lymphoreticular tissue, and you don't get a good biopsy, you
could miss the area with the PRP in it and come up with a negative test.
There's a new, unusual form of Scrapie that's been detected in Norway. We
have to be careful that we don't get so set in the way we do things that we
forget to look for different emerging variations of disease. We've gotten
away from collecting the whole brain in our systems. We're using the brain
stem and we're looking in only one area. In Norway, they were doing a
project and looking at cases of Scrapie, and they found this where they did
not find lesions or PRP in the area of the obex. They found it in the
cerebellum and the cerebrum. It's a good lesson for us. Ames had to go
back and change the procedure for looking at Scrapie samples. In the USDA,
we had routinely looked at all the sections of the brain, and then we got
away from it. They've recently gone back.

Dr. Keller: Tissues are routinely tested, based on which tissue provides an
'official' test result as recognized by APHIS
.

Dr. Detwiler: That's on the slaughter. But on the clinical cases, aren't
they still asking for the brain? But even on the slaughter, they're looking
only at the brainstem. We may be missing certain things if we confine
ourselves to one area.


snip...


FULL TEXT;


Completely Edited Version
PRION ROUNDTABLE


Accomplished this day, Wednesday, December 11, 2003, Denver, Colorado

2005


National Veterinary Services Laboratory (NVSL) Immunohistochemistry (IHC) Testing Summary

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...


Stopping BSE at the Border—USDA Needs To

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)


snip...


Restaurant Owner Sentenced for Smuggling Beef

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;


http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/scr_annexes/563/sr02_biohaz02_canada_report_annex_en1.pdf


EFSA Scientific Report on the Assessment of the Geographical BSE-Risk (GBR) of the United States of America (USA)
Publication date: 20 August 2004
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.


http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/573_en.html

SUMMARY

Summary of Scientific Report
http://www.efsa.eu.int
1 of 1
Scientific Report of the European Food Safety Authority
on the Assessment of the Geographical BSE-Risk (GBR) of
United States of America (USA)
Question N° EFSA-Q-2003-083
Adopted July 2004
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 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.
Key words: BSE, geographical risk assessment, GBR, USA, third countries

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
Conclusions
The European Food Safety Authority concludes:
1. The BSE agent was probably imported into USA and could have reached domestic
cattle in the middle of the eighties. This 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 meat and bone meal (MBM) imported into the USA
reached domestic cattle and lead to an internal challenge in the early nineties.
2. 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.
3. 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.
4. This assessment deviates from the previous assessment (SSC opinion, 2000) because
at that time several exporting countries were not considered a potential risk.
5. It is also worth noting that the current GBR conclusions are not dependent on the large
exchange of imports between USA and Canada. External challenge due to exports to
the USA from European countries varied from moderate to high. These challenges
indicate that it was likely that BSE infectivity was introduced into the North American
continent.
6. EFSA and its Scientific Expert Working group on GBR are concerned that the
available information was not confirmed by inspection missions as performed by the
Food and Veterinary office (FVO – DG SANCO) in Member States and other third
countries. They recommend including, as far as feasible, BSE-related aspects in
future inspection missions.
Expected development of the GBR
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.
A table summarising the reasons for the current assessment is given in the table below

snip...

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


EFSA Scientific Report on the Assessment of the Geographical BSE-Risk (GBR) of Mexico
Last updated: 08 September 2004
Adopted July 2004 (Question N° EFSA-Q-2003-083)

Report

http://www.efsa.eu.int
3 of 6
Conclusions
The European Food Safety Authority concludes:
1. 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
EFSA Scientific Report (2004) 4, 1-6 on the Assessment of the Geographical BSE Risk of
challenge in the mid to late 1990’s. It is possible that imported MBM into Mexico
reached domestic cattle and leads to an internal challenge around 1993.
2. 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.
3. 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.
4. EFSA and its Scientific Expert Working group on GBR are concerned that the
available information was not confirmed by inspection missions as performed by the
Food and Veterinary office (FVO – DG SANCO) in Member States and other third
countries. They recommend including, as far as feasible, BSE-related aspects in
future inspection missions.

http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/565/sr04_biohaz02_mexico_report_v2_en1.pdf

Summary

Summary of Scientific Report
http://www.efsa.eu.int
1 of 2
Scientific Report of the European Food Safety Authority
on the Assessment of the Geographical BSE-Risk (GBR) of
MEXICO
Question N° EFSA-Q-2003-083
Adopted July 2004
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 BSEagent.
The GBR is likely to increase due to continued internal and external challenge, coupled
with a very unstable system.
Key words: BSE, geographical risk assessment, GBR, Mexico, third countries
Summary of Scientific Report
http://www.efsa.eu.int
2 of 2


http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/565/sr04_biohaz02_mexico_report_summary_en1.pdf


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 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]
Sent: Tuesday, July 29, 2003 1:03 PM
To: fdadockets@oc.fda.gov
Cc: ggraber@cvm.fda.gov; Linda.Grassie@fda.gov; BSE-L
Subject: Docket No. 2003N-0312 Animal Feed Safety System [TSS SUBMISSION
TO DOCKET 2003N-0312]

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
or changes are made. this is not acceptable. we must take the politics and the industry out of any final decisions of the Scientific community. this has been the problem from day one with this environmental man made death sentence. some of you may think i am exaggerating, but you only have to see it once, you only have to watch a loved one die from this one time, and you will never forget, OR forgive...yes, i am still very angry... but the transmission studies DO NOT lie, only the politicians and the industry do... and they are still lying to this day...TSS


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

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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