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From: TSS ()
Date: April 29, 2006 at 2:19 pm PST

Release No. 0149.06
Press Office (202)720-4623

MODERATOR: Good morning from Washington. I'm Larry Quinn speaking to you from the Broadcast Center at the U.S. Department of Agriculture. Welcome to today's news conference with Secretary of Agriculture Mike Johanns to discuss the analysis of the Enhanced BSE Surveillance Program. With the Secretary today is Dr. Ron DeHaven, administrator of USDA's Animal and Plant Health Inspection Service.

The reporters during our question period this morning, we remind you that if you'd like to ask a question please press *1 on your telephone touchpad. That will alert us to call on you.

Now it's my pleasure to introduce Secretary of Agriculture Mike Johanns.

SEC. MIKE JOHANNS: Well, thank you. And good morning. Thank you for joining me today. I want to visit with you about the completion of our draft analysis of the BSE Enhanced Surveillance Program. This analysis includes an estimate of the prevalence of BSE in the United States.

When USDA began the enhanced surveillance in June of 2004, the goal was to test as many as 268,500 animals. Well thanks to the commitment of states and industry to make this a successful effort, we've far surpassed our expectations.

To date we have tested more than 690,000 animals as part of the Enhanced Surveillance Program from the populations at highest risk for the disease. That's over 1,000 cattle per day from 5,700 locations across the country. That would include farms and slaughter plants and renderers.

Today we are making available our draft analysis of the data. This analysis is being subjected to a scientific peer review process to ensure our conclusions are in fact science based.

We hope the peer review will be completed by the end of May. In our analysis we looked at the data collected during and prior to the Enhanced Surveillance Program going back to 1999. So altogether our epidemiologists looked at more than 730,000 samples collected over a seven-year time frame.

The data shows that the prevalence of BSE in the United States is extraordinarily low. Our experts used two different methods to analyze the prevalence of BSE, both of which led to similar findings. They concluded that the most likely number of BSE cases present in the United States is between 4 and 7 animals out of a herd of 42 million cattle. Those would be adult cattle.

USDA experts conclude therefore that the prevalence of BSE in the United States is less than 1 case per 1 million adult cattle.

Science enables us to set a 95 percent confidence level in that estimate. In other words, we have an extraordinarily healthy herd of cattle in our country.

I want to make an important distinction. Our surveillance program is not part of our food safety protection. The surveillance program is designed to gather sufficient data to draw some statistically valid conclusions about the health of our herd.

Food safety is protected by an interlocking set of safeguards. The most important of these is the ban that keeps specified risk materials from the human food supply. Specified risk materials are cattle parts that are mostly likely to carry the disease if it were present.

Further, we have other controls at slaughter such as a ban on nonambulatory cattle being slaughtered for human consumption. The most important animal health safeguard is the 1997 ban on ruminant-to-ruminant feeding. This measure prevents the disease from spreading among cattle and by preventing such spread contributes to increased public health protection.

Countries that have implemented ruminant-to-ruminant feed bans as we did in 1997 have seen the incidence of BSE drop dramatically in their cattle population. The longer a feed ban has been in place, the fewer animals are left that would have been exposed to contaminated feed.

So we're dealing with an incredibly low prevalence of the disease in the United States, and science tells us with the safeguards, the prevalence is likely to decline. On top of that, we have strong safeguards in place that make a very low risk for cattle even lower still for humans.

So to recap, we are putting our analysis through a rigorous scientific peer review process to ensure that the conclusions we have drawn are sound and that they are scientifically credible. The enhanced surveillance program gives us the ability to stand on solid scientific ground in saying the prevalence of BSE in the United States is extraordinarily low. But I would argue that there's little justification for continuing surveillance at this level once our analysis is affirmed by peer review ensuring we have a very, very scientific prevalence estimate.

So I look forward to getting the results of the peer review and as I said we hope the peer review will be completed by the end of May. Then we'll see how science and international standards guide us from here.

The framework for our ongoing BSE testing program will also be based in science. I do expect we will move to a level of testing that is in line with international guidelines for a country like ours that is at minimal risk for the disease.

Now before I take your questions, I just want to say how very proud I am of the work that all of our employees and partners have done these last 23 months and are continuing to do. In my opinion the Enhanced BSE Surveillance Program has been a very significant accomplishment. Consumers both here and abroad should feel better than ever about the meat that they are buying, and U.S. producers should be prouder than ever of the great work that they do.

With that, we will be happy to take questions.

MODERATOR: Thank you, Mr. Secretary. Now we're ready for our questions. And our first question today comes from Libby Quaid of Associated Press. Libby?

REPORTER: Hi. Mr. Secretary, my question is really a two-part question. You said earlier that you wanted to persuade Japan to lift the ban on U.S. beef before doing any scaling back of tests. But it sounds like now you may go ahead and make that decision once the peer review is completed. Could you address that? And also, speaking of trade could you give us an update on the situation with Russia and poultry?

SEC. JOHANNS: On the first question, we continue to work with Japan. And I would describe our discussions as going well. I think the information that I released today will significantly aid the discussions. But I think the information I put out today will be positively received across the country. As you know, we have always said we will base our decisions on ongoing surveillance based on science and international standards, peer review. We would consult with our trading partners out there, and we are in the process of doing all those things.

We are on course. We are going to do everything we can to make sure that our decisions are based upon all those factors I mentioned. And today's announcement takes us a step further down that path.

The second thing I would say relative to your question about poultry -- and I appreciate that question -- I was extremely disappointed by the Russian action. There literally was no prenotification. This kind of action is enormously disruptive in terms of our trade relationship, and we are doing everything we can to minimize that disruption.

I immediately sent a letter to my colleague in Russia indicating my serious concern and urging action so there would not be a trade disruption. I appreciated that Ambassador Portman did the same with his colleague in Russia.

We have also been in contact with the ministries and legislative officials to express our grave concern. We understand that the Russian action is related to a growing frustration with fraudulent importing procedures and relates to their desire to better control the importing process.

We understand that. But we are urging that this be done in a manner that does not disrupt all trade nor penalize U.S. exporters who have followed the established procedures.

Under Secretary J.B. Penn spoke to Ambassador Burns in Moscow this morning. We now understand that product departing seaports before May 8 will be admitted. We also understand that the Russians are moving to implement a new import permit licensing system. We are urging that this be put in place immediately so as not to disrupt trade.

Finally I would mention this is very important to us. Russia is our largest export market for poultry with annual sales well over $600 million, so it's important, significant, and we are going to do everything we can to get this straightened out.

MODERATOR: Peter Shinn of the National Association of Farm Broadcasting will have the next question. Standing by should be Matt Kaye. Peter?

REPORTER: Yes. Thank you, Larry. And thank you, Mr. Secretary, for holding this call. Just a quick two-part question for you, Mr. Secretary. The question is, in terms of timing, as you say you've tested far more animals than you anticipated originally, so why go ahead and get this analysis out of the way and go back to a normal testing level now before all the beef markets are reopened to U.S. beef?

And then perhaps for Dr. Dehaven, what would a normal style BSE surveillance program look like?

SEC. JOHANNS: We did additional testing just simply because we wanted to make sure that we had touched all the bases. As we continued to review we wanted to make sure that we had touched all areas of the country. We wanted to make sure that we had a statistical number that gave us a very valid sample. We also as you know in the last months of this surveillance confirmed the previous USDA decision to test 20,000 animals. I re-read the transcript of my predecessor's statements to a House Subcommittee where Secretary Veneman clearly indicated that 20,000 healthy animals would be tested.

And so we needed to spend some time on getting that done, and that expanded the testing also.

And then of course we've been working with trading partners -- Japan, South Korea and others. But one of the things I pointed out in response to Libby's question is equally true in response to your question. We wanted to make sure that as we went along here we were paying attention to not only the sampling, our trading partners, but also that we were getting expert review. So the question may arise, well you've got your analysis so why not just end it today?

Well, we said we wanted to have experts look at this. We will factor in their advice. We hope that will be available by the end of May. And so that will be another step in the direction in terms of making a decision.

Now I will offer the mike here to Dr. Dehaven, and he can talk about ongoing surveillance because I'm very confident in telling you that I anticipate there will be ongoing surveillance.

DR. DEHAVEN: Thank you, Mr. Secretary. Indeed we are working now to develop what we think would be an appropriate level of maintenance testing as we refer to it, making sure that it is scientifically and statistically valid and also that it is consistent with the OIE requirements. The OIE establishes two kinds of BSE surveillance testing --Type A which would be for determining prevalence and that's what we're talking about today with the enhanced testing we've done. But then the OIE chapter also describes a maintenance level of testing or Type B so that when we finally determine a target number of animals to test for our maintenance surveillance testing program it will certainly be consistent and meet or exceed the OIE requirements for Type B or maintenance type of testing.

That testing program clearly will continue to focus on the same targeted high-risk animals, meaning that we will continue to test those animals that if they have the disease these would be the animals most likely to test positive.

I should point out too that in the Type A testing, the prevalence testing we have done, the OIE requirement is based on a point system based on the various categories of animals that are tested who are satisfying those requirements. A country with a high cattle population such as ours should accumulate over a seven-year period 300,000 points. Based on our calculations of the testing that we have done in the United States over the last seven years, our point total at this point would be somewhere in excess of 2.9 million points, nearly ten times the required level of testing by the current OIE chapter.

We'll make sure again with our maintenance testing that we meet or exceed and based on the current evaluation we estimate that number will be somewhere in the 40,000 animals per year level.

MODERATOR: Matt Kaye of the Burns Bureau will be next followed by Scott Kilman. Matt?

REPORTER: Thank you so much, Larry. And thanks, Mr. Secretary. A few weeks ago Acting Under Secretary Chuck Lambert laid out a schedule based on an agreement with Tokyo to resume beef trade. This include plant safety checklists and verification audits. Where exactly are we in that process? How do you see that unfolding in terms of actually encouraging the Japanese to reach a decision? And will you meet with the Japanese Ag Minister in Geneva next week? And how do you expect that meeting will affect this effort to reopen the market?

SEC. JOHANNS: I'll take your last question first. The answer is yes, I do intend to meet with Minister Nakagawa. It looks today like that meeting will be on Tuesday of next week. Give me some flexibility there because these meetings can move around a little bit depending upon demands of schedule. But at least today it looks like it will be Tuesday of next week when we will meet in Geneva.

In terms of the pathway to reopening the Japanese border to U.S. beef, I can also tell you that we are conducting the audits that we talked about. They have started. I would anticipate that they will take, oh, 10 days to two weeks to complete. We will share that information with Japan, answer any questions that they have about the audit. There will be some decision -- this has been a step-by-step process. I'm confident there will be some decision as to what they want to do in terms of any kind of auditing. And so we continue to work with Japan.

Again, I would say that the information we released today I'm confident will be very positively viewed by not only Japan but other trading partners around the world. When you consider the size of the U.S. herd and you apply the statistical analysis that we have applied and really use a couple different approaches and come to the conclusion that somewhere out there there might be four to seven animals, and then you also realize that we're going to subject this to a rigorous expert review to make sure the conclusions we've reached here at the USDA are valid conclusions -- you can really see the practices we've put in place over time have really made a huge difference here in terms of BSE in the United States.

But I think everything's going along as we'd hoped it would with Japan. I'm certainly as impatient as the next person and want this done now. But I'm confident that we're headed in the right direction there.

MODERATOR: Scott Kilman of Wall Street Journal will be next followed by Christopher Doring. Scott?

REPORTER: Mr. Secretary, a couple quick questions. One is, who are the experts who will be doing the peer review, and how much money has been spent annually on the enhanced surveillance program? And then the broader question is, how concerned are you that the rural backlash against having a national ID system could actually kill that program or really put off that idea?

SEC. JOHANNS: You do have some out there who are raising issues about the ID system. And we certainly are mindful of that. And we want to take into account people's attitudes about that ID system, so I am more than willing to listen to concerns and comments. I will also say this, that for those who are saying gosh, I don't want to go in this direction, for whatever reason, we also get a tremendous amount of support from the industry.

Here's the other thing I will tell you about the ID system that I think is very important to recognize. There will always be some who say, I don't want to do that, it's too big a change, or whatever. But the reality is that the rest of the world is moving in this direction, at least from my perspective.

You've got Australia out there moving in this direction very aggressively. They are a huge competitor to U.S. beef. You've got Canada that's been moving in this direction, and they won't be alone. You also have major purchasers of U.S. beef who are saying we need to move in this direction. I just noticed that in Australia a representative of McDonalds -- which of course is a major purchaser of beef -- made a statement about the need for this animal ID system.

And so I just think it's important to recognize that we can always adopt the attitude, I don't want to change, change is hard, I don't like the way this may affect me. But the reality is, that the day is going to arrive where I think we would be hugely criticized by everyone in the industry -- food safety people, by consumers, by purchasers of beef -- if we did not move in this direction. I think if we got four years out there and all of a sudden it was a situation where it was a crisis or something, people would be saying what have you been doing, why haven't you been moving us there? Our plan does that. So that's very important to me.

In terms of the amount of monies spent, it has been a very significant amount of money. But I will -- Dr. DeHaven may have an estimate he can give you, so I'll let him talk about that. And then I will also let him visit with you about the peer review.

DR. DEHAVEN: Thanks again, Mr. Secretary. In terms of the peer review process, in fact we have just let a contract with a Research Triangle Institute who will then contract with we think approximately three or more peer reviewers who are appropriately credentialed, have the scientific expertise to do the appropriate peer review on this process and ensure that they are nonconflicted.

The Office of Management and Budget puts out guidance on peer review process to include the qualifications of those who would be doing peer review. And so we will be carefully adhering to those procedures.

We would expect that as the Secretary mentioned that peer review process will commence in the very near future and hope to have the report back by the end of May.

In terms of the annual cost for our Enhanced Surveillance Program, we can get for you more exact numbers, but we do know in very rough numbers it's costing approximately $1 million a week to do this testing. And in a week's time historically we've tested typically between 5,000 and 7,000 animals. So it is expensive. And yet I think in reading this report that we're releasing today you'll see the value of the statistics that we've had in terms of appropriately characterizing the extremely low risk of BSE in this country.

MODERATOR: Christopher Doring of Reuters is next. And he'll be followed by Kaori Iida. Christopher?

REPORTER: Yes, thank you. A few of my questions have already been answered here. So if I hear you correctly you guys are still obviously in the process of determining what your future track is for the Enhanced Testing Program. Earlier this year you said early 2006. Do you have an estimated timetable as to when you might have a firm decision on that?

SEC. JOHANNS: Christopher, I'd hate to put a timetable on it. There's so many things tend to come up, and our hope is that we'll get the expert analysis by the end of May. But as you know that can always slip some here and there.

The bottom line for me is, as you know we talked about the need for outside peer review, and we want to make sure they have an opportunity to take a good look at what we're doing and that's just so important. Again I think this is a very important step today. But I would say it's a step. We are going to make sure we have outside experts to take a good look and give us their advice.

REPORTER: But it's safe to say at this point your only budgeted as I recall for I think it's 40,000 tests in the Fiscal '07 budget? Is that correct?

SEC. JOHANNS: Christopher, the thing is, I would say about that. I think that's been the case, certainly been the case in the two budgets that I've been here. We have been accessing funds kind of on a as-we-go basis. And I think everybody is anxious to have us do this in a way that is peer-reviewed and done right. And so that budget really hasn't applied here just simply because we've been accessing additional funding as we needed it to continue the surveillance.

REPORTER: And I guess without giving a specific number obviously -- I mean a lot of consumer groups have come out with this 40,000 estimate saying this is how much we budgeted and potentially here's what the scale-back would be. Is it safe to say it will be more than likely more than that 40,000 a lot of people have been talking about?

SEC. JOHANNS: Just today we won't even put an estimate on it, again because we believe here that these decisions need to be based upon science and international standards. And we're anxious to get folks, outside experts to look at it and make their recommendations. And so when we're all done here, not only will we have a report out but we will be able to tell people, whether it's consumer groups or the industry or trading partners or consumers across the United States that not only did we do the report but we subjected it to very, very rigorous review and here's their conclusions.

MODERATOR: Our next question comes from Kaori Iida from NHK Japan Broadcasting. He'll be followed by Philip Brasher. Kaori?

REPORTER: Yes. Thank you, Mr. Secretary. When you meet with Minister Nakagawa in Geneva next week, will you be discussing your scaling down on the Enhanced Surveillance Program? And also with regard to negotiations with Japan, do you plan to send Dr. Lambert or Dr. Penn to Tokyo once the reaudit is complete?

SEC. JOHANNS: We've always said, Kaori, that we would send whatever team is necessary. And I don't have current plans that it would be Dr. Penn or anyone else here at the USDA. But we can literally dispatch people and technical teams overnight as that is necessary. So we'll be happy to do that.

In terms of discussing with Minister Nakagawa, what I will do is share with him the analysis that we have done. I think he'll be very, very pleased to see it. I'm confident that he will. But then I will explain the process that is still ahead of us to make a decision about what an ongoing surveillance program, not what it would look like but how we're going to get to a decision point on that and how we're going to have experts involved, how we're going to base it on science, how we're going to base it on international standards.

So what I will do is explain the hurdles ahead before we get to a point where we make a final decision on what that would look like.

MODERATOR: Philip Brasher from Des Moines Register has the next question followed by Steve Kaye. Philip?

REPORTER: Yes. Thanks for taking my question. Do you have a breakdown or estimates for different populations of cattle, say slaughter steers versus dairy culls or breeding animals where I assume you'd have a higher risk?

SEC. JOHANNS: I'm not sure we do at least at this moment. What I'd like to do to answer that question is ask the folks here at the USDA to try to put together whatever information I can and get that to you, and we will do that.

MODERATOR: Next question comes from Steve Kaye of Cattle Buyers Weekly, followed by Daniel Enoch from Bloomberg. Steve?

REPORTER: Good morning, Mr. Secretary. As you know, two shipments at least to Hong Kong in recent weeks have resulted in suspension of the plants from which those shipments came because either bone fragments or pieces of cartilage of boneless beef products were found. That raises the issue as you know of zero tolerance versus commercial tolerances. And the industry recent weeks has said that if trade resumes soon to South Korea they're concerned that shipments could be interrupted at any time because of the finding of such bone fragments. And they say it's almost impossible to prevent those getting into boxes of boneless beef or other such products. What's USDA doing to address this issue?

SEC. JOHANNS: We are aware of the issue, very much aware of the issue. Let me offer a couple of thoughts if I might. First thing just relative to the response by Hong Kong, Hong Kong decided to take action that I have to tell you I thought was very thoughtful and measured. Instead of slamming the border shut to all U.S. beef, they worked directly with the plants involved.

That's the kind of response from a trading partner that should not go unmentioned, and needless to say we never like to see even a partial disruption but it was a thoughtful, scientifically based, internationally-standard-based response to the issue.

The second thing I'd like to say is there is this debate about absolute zero tolerance versus commercial tolerance, and we are in discussions with our various trading partners about how best to approach this. Whether you're talking about beef or cars, if the attitude is absolute zero tolerance on everything you could bring worldwide trade to a screeching halt. And that is just reality.

What we want to do is always make sure we're protecting consumers here and abroad, that we've got the right policies and procedures in place. How we do that and the common sense applied to this is very, very important. So we will continue those discussions.

My hope is that we can resolve them in a way that is based upon science, based upon international standards, and also based upon the notion that we need to work with each other and do everything we can to protect the consumer but also recognize that you just can't stop trade. There is some tolerance in about everything we do, and trying to find that magic approach is the key here.

REPORTER: Are there international standards that allow for commercial tolerances, Mr. Secretary?

SEC. JOHANNS: That I'm not as familiar with. Dr. DeHaven, maybe I can ask you. The question was, are there international standards that deal with tolerance?

SEC. JOHANNS: There are not. It really is an issue of the age of the animal and the product. So for example, when we're sending beef from animals under 30 months of age from a country with the very, very slim risk of BSE that's found in the United States, we're not talking about a scientific or risk issue. It's more of a marketing issue than it is a risk issue in terms of BSE.

So no, there's no international standards that would apply to this particular situation as it's not from a scientific standpoint a BSE risk issue.

MODERATOR: Our final question today comes from Daniel Enoch from Bloomberg. Daniel?

DR. DEHAVEN: Let me clarify that 40,000 number. We are going to make sure that the ongoing level of surveillance testing that we do is, one, scientifically based in terms of numbers as well as the animals that we target, and that it will meet and exceed the OIE standards for ongoing --

REPORTER: Right. I understand you said that. But you did put a number of 40,000.

DR. DEHAVEN: With a preliminary look at the OIE chapter and their requirements in our cattle population, certainly that 40,000 would appear to be in the ballpark. But again, we've not arrived at that number. And even when we do arrive at that number we want to make sure that it is scientifically peer-reviewed to again make sure that it meets the scientific requirements and meets or exceeds the OIE standards. So we really haven't arrived at any specific number yet.

REPORTER: Okay. But 40,000 is within the ballpark you're looking at?

SEC. JOHANNS: My analysis of this, my decision-making process as we get information back from the experts, I intend to start every discussion on this with a very simple question: What's the experts' advice on this? That's why we seek their peer review; that's why we continue to take this through the process that we described many months ago.

One of the things we said is, we would have a rigorous peer review, and we intend to do that. And I intend to ask what is their advice to me.

MODERATOR: Thank you. Secretary of Agriculture, Mike Johanns.!ut/p/_s.7_0_A/7_0_1OB/.cmd/ad/.ar/sa.retrievecontent/.c/6_2_1UH/.ce/7_2_5JM/.p/5_2_4TQ/.d/2/_th/J_2_9D/_s.7_0_A/7_0_1OB?PC_7_2_5JM_contentid=2006%2F04%2F0149.xml&PC_7_2_5JM_parentnav=TRANSCRIPTS_SPEECHES&PC_7_2_5JM_navid=TRANSCRIPT#7_2_5JM

O.I.E. BSE GUIDELINES, ha, ha, ha, ... just look at the countries that thought they were bse free for all those years that went by those same OIE guidelines.

The USDA June 2004 Enhanced BSE surveillance program was a sham, and everyone knows it now. I find it sad and embarrassing that the USDA and my country, would continue this masquerade. I find it even more sad that the public accepts it. THE complete program, and the USDA should be dismantled and redone. Those test were meaningless under there flawed BSE protocols. ...TSS


The U.S. Department of Agriculture was quick to assure the public earlier this week that the third case of mad cow disease did not pose a risk to them, but what federal officials have not acknowledged is that this latest case indicates the deadly disease has been circulating in U.S. herds for at least a decade.

The second case, which was detected last year in a Texas cow and which USDA officials were reluctant to verify, was approximately 12 years old.

These two cases (the latest was detected in an Alabama cow) present a picture of the disease having been here for 10 years or so, since it is thought that cows usually contract the disease from contaminated feed they consume as calves. The concern is that humans can contract a fatal, incurable, brain-wasting illness from consuming beef products contaminated with the mad cow pathogen.

"The fact the Texas cow showed up fairly clearly implied the existence of other undetected cases," Dr. Paul Brown, former medical director of the National Institutes of Health's Laboratory for Central Nervous System Studies and an expert on mad cow-like diseases, told United Press International. "The question was, 'How many?' and we still can't answer that."

Brown, who is preparing a scientific paper based on the latest two mad cow cases to estimate the maximum number of infected cows that occurred in the United States, said he has "absolutely no confidence in USDA tests before one year ago" because of the agency's reluctance to retest the Texas cow that initially tested positive.

USDA officials finally retested the cow and confirmed it was infected seven months later, but only at the insistence of the agency's inspector general.

"Everything they did on the Texas cow makes everything USDA did before 2005 suspect," Brown said. ...snip...end

CDC - Bovine Spongiform Encephalopathy and Variant Creutzfeldt ...
Dr. Paul Brown is Senior Research Scientist in the Laboratory of Central Nervous System ... Address for correspondence: Paul Brown, Building 36, Room 4A-05, ...

CDC - Afterthoughts about Bovine Spongiform Encephalopathy and ...
Afterthoughts about Bovine Spongiform Encephalopathy and Variant Creutzfeldt-Jakob Disease. Paul Brown Senior Investigator, National Institutes of Health, ...


PAGE 43;

Section 2. Testing Protocols and Quality Assurance Controls



[GAO-05-101 ] Mad Cow Disease: FDA's Management of the Feed Ban Has Improved, but Oversight Weaknesses Continue to Limit Program Effectiveness
Size: 104986 , Score: 1000 , TEXT , PDF , SUMMARY


[GAO-05-101 ] Mad Cow Disease: FDA's Management of the Feed Ban Has Improved, but Oversight Weaknesses Continue to Limit Program Effectiveness
Size: 104986 , Score: 1000 , TEXT , PDF , SUMMARY

[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

Terry S. Singeltary

Subject: Substances Prohibited from Use in Animal Food or Feed, Proposed Rule, Docket No. 2002N-0273 C-534 VOL 45 (PhRMA) and Entered On February 17, 2006
Date: March 10, 2006 at 5:23 pm PST

Marie A. Vodicka, PhD

Assistant Vice President

Biologics & Blotechnology

Scientlflc & Regulatory Affairs


Division of Dockets Management (HFA-305)

Food and Drug Administration

5630 Fishers Lane, rrn . 1061

Rackville, MD 20862

Re: Substances Prohibited from Use in Animal Food or Feed, Proposed Rule, Docket

No. 2002N-0273

February 14, 2006

Dear Sir or Madam :

The Pharmaceutical Research and Manufacturers of America (PhRMA) is providing

comment to the proposed rules issued. ......


Subject: Docket No: 2002N-0273 (formerly Docket No. 02N-0273) Substances Prohibited From Use in Animal Food and Feed PAUL BROWN
Date: January 20, 2006 at 9:31 am PST

December 20,2005

Division of Dockets Management (HFA-305)

Food and Drug Administration

5630 Fishers Lane

Room 1061

Rockville, MD 20852

Re: Docket No: 2002N-0273 (formerly Docket No. 02N-0273)

Substances Prohibited From Use in Animal Food and Feed

Dear Sir or Madame:

As scientists and Irecognized experts who have worked in the field of TSEs for

decades, we are deeply concerned by the recent discoveries of indigenous BSE infected

cattle in North America and appreciate the opportunity to submit comments to this very.........


Given that BSE can be transmitted to cattle via an

oral route with just .OO1 gram of infected tissue, it may not take much infectivity to

contaminate feed and keep the disease recycling. ........

December 19, 2005

Division of Dockets Management (HFA-305)

Food and Drug Administration

5630 Fishers Lane

Room 1061

Rockville, MD 20852

Re: Docket No: 2002N-0273 (formerly Docket No. 02N-0273)

Substances Prohibited From Use in Animal Food and Feed

Dear Sir or Madame:

The McDonald’s Corporation buys more beef than any other restaurant in the United States. It is

essential for our customers and our company that the beef has the highest level of safety.

Concerning BSE, ...........




Sent: Saturday, June 04, 2005 8:07 AM
Subject: BSE OIE CHAPTER 2.3.13 (The Weakening of a already terribly flawwed BSE/TSE surveillance system)

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

Subject: Re: Summary of Enhanced BSE Surveillance in the United States & BSE Prevalence Estimate for U.S. April 27, 2006
Date: April 28, 2006 at 10:20 am PST

Release No. 0143.06
Ed Loyd (202) 720-4623
Jim Rogers (202) 690-4755;article=2815;title=CJD%20WATCH

Meanwhile, back at the ranch with larry, curly, and mo at USDA ET AL ON BSE ALABAMA STYLE;article=2763;title=CJD%20WATCH


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