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From: TSS ()
Subject: Re: Alabama mad cow dental records 'dentition' supposedly 10 year + cow ??? or not i.e. 'informed guess'
Date: July 9, 2006 at 6:26 pm PST

In Reply to: Alabama mad cow dental records 'dentition' supposedly 10 year + cow ??? or not i.e. 'informed guess' posted by TSS on July 9, 2006 at 9:40 am:

no wonder USA is not documenting any young cattle yet with mad cow disease,
hell, its a miracle USDA et al have documented any mad cow at all at this
rate ;

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

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