SEARCH VEGSOURCE:

 

 

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




From: TSS ()
Subject: Re: McDonald's Corp. seven scientists and experts and a pharmaceutical supplier Seriologicals Corp. U.S. NOT PROTECTED AGAINST MAD COW DISEASE
Date: January 7, 2006 at 7:11 am PST

In Reply to: Re: McDonald's Corp. seven scientists and experts and a pharmaceutical supplier Seriologicals Corp. U.S. NOT PROTECTED AGAINST MAD COW DISEASE posted by TSS on January 5, 2006 at 2:44 pm:

September 13,2004

USDA, FSTS

Docket Clerk

300 12* Street, SW

Room 102, Cotton Annex

Washington, DC 20250

04-021ANPR

04-021ANPR-70

Richard L. Crawford

Re: Docket No: 04-02 1 ANPR Federal Measures to Mitigate BSE Risks: Considerations

for Further Action

Dear Sir or Madame:

On behalf of McDonald’s Corporation, which operates more than 13,000 restaurants in

the United States, we appreciate the opportunity to submit comments to this very

important Advance Notice of Proposed Rulemaking (ANPRM). 69 Fed. Reg. 42288 (July

14,2004).

In previous comments submitted to FSIS regarding the removal of SRI&, McDonalds

fully supported this rule and its immediate implementation. The removal of SRMs from

human food is the primary firewall to protect the US consumer from being exposed to the

BSE agent. While we applaud the requirement for SRM removal, we feel that it is

equally important for FSIS to insure that each slaughterplant which processes cattle have

systems in place which prevent cross contamination between edible tissue and SRMs.

This should include but not be limited to the use of separate equipment, such as knives,

blades, etc. where appropriate. In addition, it is also important that appropriate and

effective disinfection procedures for equipment used to handle SRMs be developed and

approved for use.

It is our opinion that requiring SRM removal without a procedure to prevent cross

contamination is inadequate as a protective public health measure. The TSE agents

@ions) are sticky and highly resistant to disinfection. If SRMs such as brain and spinal

cord are allowed to contact equipment and other surfaces such as deboning tables which

then are used to handle and process edible tissue this could allow contamination and

negates the intention of the ban. This is true not only in plants slaughtering fed cattle

both under and over 30 months but also in plants slaughtering predominately older cattle.

It is important that measure be taken to prevent cross contamination between carcasses

and SRms in the cull plants. McDonalds requires their suppliers to prevent cross

contamination and audits against certain measurable standards such as requiring spinal

cord to bc removed on the kill floor. We would be willing to share these standards with

FSIS as an example.

FSIS Docket No. 04-02 1 ANPR

dooqhl- =w c1qo -

McDonalds again recommends that dura (the covering around the brain and spinal cord)

be added to the list of SRMs. While skull and vertebral column are included as SRMs,

dura is not. If dura is not removed prior to processing on the fabrication floor, it may

come loose and be incorporated into ground product. Bovine dura was never tested for

infectivity. It was assumed that due to direct contact with spinal cord, it may serve as a

vehicle to transmit disease. In addition, human dura has been the source of human to

human transmission of Creutzfeldt-Jakob Disease (CJD). (personal communication - Dr.

Danny Matthews, UK, VLA) Our ISAC committee recommended that McDonalds add

the removal of dura as a specification in the production of our product.

McDonalds urges the USDA to make the appropriate adjustments in the SRM ban if new

scientific findings and/or the results of the increased surveillance warrant a change.

In regards to imported meat products from other countries, McDonalds suggests that no

SRM exemption be made for countries based on BSE risk. The long incubation period

and limited surveillance in many countries can limit the ability to accurately determine

risk. Also, the risk level of a country could potentially change over night if the trading

patterns of a country changed. It seems logistically impossible to maintain a system

which could continually monitor the world’s trading patterns. In addition, science has

not provided all of the answers in regards to the transmission of BSE. Requiring SRMs

to be removed from imported products for human food is prudent. If the US would wait

until disease is confirmed the exposure would already have occurred.

Thank you for the opportunity to comment on these very important issues.

Richard L. Crawford

Corporat,e Vice President, Government Relations

McDonalds Corporation

1 Kroc Drive

Oak Brook, Illinois 60523

FSIS Docket No. 04-021ANPR

http://www.fda.gov/ohrms/dockets/dailys/04/sep04/092104/04n-0264-c00140-vol22.pdf

2004N-0264 Federal Measures to Mitigate BSE Risks: Considerations for Further Action

C 136 National Cattlemen's Beef Assn (NCBA) Vol #: 22

C 137 Public Citizen Vol #: 22

C 138 Center for Science in the Public Interest (CSPI) Vol #: 22

C 139 Humane Society of the United States (HSUS) Vol #: 22

C 140 McDonald's Corporation Vol #: 22

C 141 North American Natural Casing Assn (NANCA) Vol #: 22

C 142 National Renderers Assn Vol #: 22

C 143 G.A.O.B., Inc. Vol #: 22

C 144 Gelatin Manufacturers of Europe (GME) Vol #: 22

C 145 IBM Business Consulting Services Vol #: 22

C 146 L. Fischer Vol #: 22

C 147 C. Rothenfluch Vol #: 22

C 148 C. Addonizio Vol #: 22

C 149 M. Clifton Vol #: 22


http://www.fda.gov/ohrms/dockets/dailys/04/sep04/092104/092104.htm#04N0264

Dockets Entered on December 22, 2005
2005D-0330, Guidance for Industry and FDA Review Staff on Collection of Platelets
by Automated ... EC 203, McDonald's Restaurants Corporation, Vol #:, 34 ...


http://www.fda.gov/ohrms/dockets/dailys/05/Dec05/122205/122205.htm

03-025IF 03-025IF-631 Linda A. Detwiler [PDF]
Page 1. 03-025IF 03-025IF-631 Linda A. Detwiler Page 2. Page 3. Page 4.
Page 5. Page 6. Page 7. Page 8. Page 9. Page 10. Page 11. Page 12.
www.fsis.usda.gov/OPPDE/Comments/03-025IF/03-025IF-631.pdf - Text Version

03-025IF 03-025IF-634 Linda A. Detwiler [PDF]
Page 1. 03-025IF 03-025IF-634 Linda A. Detwiler Page 2.
Page 3. Page 4. Page 5. Page 6. Page 7. Page 8.
www.fsis.usda.gov/OPPDE/Comments/03-025IF/03-025IF-634.pdf - Text Version
[ More results from www.fsis.usda.gov/OPPDE/Comments/03-025IF/ ]

Page 1 of 17 9/13/2005 [PDF]
... 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 ...
www.fsis.usda.gov/OPPDE/Comments/03-025IFA/03-025IFA-2.pdf - Text Version

03-025IFA 03-025IFA-6 Jason Frost [PDF]
... Zealand Embassy COMMENTS ON FEDERAL REGISTER 9 CFR Parts 309 et al [Docket No. 03-
025IF] Prohibition of the Use of Specified Risk Materials for Human Food and ...
www.fsis.usda.gov/OPPDE/Comments/03-025IFA/03-025IFA-6.pdf - Text Version



http://www.fsis.usda.gov/Search/Search_Results/Index.asp?q=03-025IF&mode=simple&num=10&as_occt=any&restrict=FSIS_DOCKET_COMMENTS



In its opinion of 7-8 December 2000 (EC 2000), the SSC ... [PDF]
Page 1. Linda A. Detwiler, DVM 225 Hwy 35 Red Bank, New Jersey 07701 Phone: 732-741-2290
Cell: 732-580-9391 Fax: 732-741-7751 June 22, 2005 FSIS Docket Clerk US ...
www.fsis.usda.gov/OPPDE/Comments/03-025IF/03-025IF-589.pdf



http://www.fsis.usda.gov/OPPDE/Comments/03-025IF/03-025IF-589.pdf



Page 1 of 17 9/13/2005 [PDF]
... 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 ...
www.fsis.usda.gov/OPPDE/Comments/03-025IFA/03-025IFA-2.pdf



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





03-025IF 03-025IF-618 Richard L. Crawford [PDF]
Page 1. 03-025IF 03-025IF-618 Richard L. Crawford
Page 2. Page 3. Page 4.
www.fsis.usda.gov/OPPDE/Comments/03-025IF/03-025IF-618.pdf -



http://www.fsis.usda.gov/OPPDE/Comments/03-025IF/03-025IF-618.pdf



03-038IF 03-038IF-15 Richard L. Crawford [PDF]
Page 1. 03-038IF 03-038IF-15 Richard L. Crawford
Page 2. Page 3. Page 4.
www.fsis.usda.gov/OPPDE/Comments/03-038IF/03-038IF-15.pdf -



http://www.fsis.usda.gov/OPPDE/Comments/03-038IF/03-038IF-15.pdf



http://www.fsis.usda.gov/OPPDE/Comments/03-025IF/03-025IF-634.pdf





Follow Ups:



Post a Followup

Name:
E-mail: (optional)
Subject:

Comments:

Optional Link URL:
Link Title:
Optional Image URL: