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From: TSS ()
Subject: Re: Mexico SAGARPA Assessment of BSE VS EFSA Scientific Report on the Assessment of the Geographical BSE-Risk (GBR) of Mexico
Date: February 11, 2007 at 10:24 am PST

In Reply to: Mexico SAGARPA Assessment of BSE VS EFSA Scientific Report on the Assessment of the Geographical BSE-Risk (GBR) of Mexico posted by TSS on February 5, 2007 at 1:11 pm:

Dear Ing. Ruiz Garcia,

This is to acknowledge receipt of a the document “Opinion of Analysis of Risk – Occurrence of BSE in Mexico”, same which it differs a lot from what a “Risk Assessment” per se is, but it does illustrate and shows us the great deficiencies of scientific resources as well as economic, as that of organization, infrastructure, professional human resources, communication, statistical and internal controls, among others; it must be stated that it is not privative of Mexico, but to us our main concern is what is not being done, what is being done and how it is done in our Country.

If we compared the previous answer we got to our appeal to the present Opinion, the discrepancies are abysmal (huge) with exception of two and firm statements and those are: “we have strictly followed the norms/recommendations of the OIE and that the BSE risk is minimum or null”, statements made without producing or providing any evidence to support such claims nor how is that you have reached to such conclusions. In abundance I may say that most of the nations that have succumbed to BSE have had a strict adherence to such OIE’s lax norms (recommendations).

A study of such magnitude and relevance, it requires of updated information and just to show you I’ll mention some of your outdated data in the first paragraph of “Introduction” we found three big discrepancies:

· It has been verified scientifically that cattle feeding with flours of contaminated meat and bone ARE the most significant source of dissemination and transmission of this etiologic agent; the Opinion states: “general consensus exists that they are,”

· It has been scientifically verified the maternal transmission; the Opinion says that: “there is no evidence and in case that it does exist”,

· BSE is found (officially recognized) in 34 countries and not only in 26 as it is indicated.

(Such scientific reports were submitted as support to our commentaries before COFEMER on the “Project of Modification to the Official Norm Mexicana NOM-030-ZOO-1995, Specifications and procedures for the import of beef, carcasses, viscera and offal at zoo-sanitary inspection points http://www.apps.cofemer.gob.mx/expediente/filev99/_B00062753.pdf)

Since1995 the scientific researches showed the world that as little as of 1 gram of infected material was enough for a cattle to develop BSE (BSE Inquiry Statement No. 145D http://www.bseinquiry.gov.uk/case outws/s145d.pdf) and today in light of the scientific report “Risk of oral infection with bovine spongiform encephalopathy agent in primates”, (www.thelancet.com http://image.thelancet.com/extras/05let1056web.pdf Published online January 27, 2005 ), it is confirmed and better yet, narrowing it down to establish that only 1 mg (ONE mg) milligram may infect one in fifteen heads of cattle orally fed, that is 7%, while the infected brain of a cattle is sufficient to contaminate up to 700 heads of cattle.

The used heat treatments in inactivating the prion infectivity have demonstrated its inefficiency on doing it as it only reduces its contamination but it does not eliminate them. It has been documented that after exposure to 600º C and completely ashed, the brain samples when reconstituted with saline to their original weights, transmitted the disease, maintaning its infectivity.

The contamination of feed by blood must be considered of high risk and do not underestimate its infectivity in any of its presentations, liquid, dry or as a milk substitute.

The feeding bans on MBM, as well as on the Gallinaza and Pollinaza, in the United States as in Canada and our Country, they have never been observed or respected and the international regulations (OIE) have been played down by creating our own rules –NOMs- have only filled-out (checked-out) questionnaires but the feeding practice continues; the Law and the NOMs are “dead regulations” for their lack of enforcement and null monitoring; the use and abuse of the Clenbuterol in cattle feeding resulting in the poisoning of hundreds of families every year, are a sample of it.

Regarding the import of live cattle, organs and viscera classified as SRM, as well as flours of meat and bone (MBM) coming from countries with BSE as Canada and the United States continue to flow through our borders even though its commercialization is forbidden by the OIE and to mention three examples in imports from U.S.A. during the 2005 we have:
· 466 Bovines – live
· 79.160 kg. Bovine Brains
· 107.632 Tons Flours of Meat and Bone - MBM
(source: USDA, U.S. Dept. of Commerce, US Census Bureau and NRA)

The declaration of “Closed and Sealed Borders” at the appearance of the first case of “mad-cow” in the United States in the period from December 24, 2003 through March 2004, according to information in our hands, borders were never closed or sealed to the import of such products, it was only reduced. Live bovines imports never ceased, it was also reduced.

The idea that eating beef from bovines younger than 30 months of age does not represent any risk, it’s a lie since there are records of animals of 21 months of age that have given positive to BSE test, not to forget the sub-clinical cases, apparently healthy animals that have given positive to the test.

As far as the Cattle Identification National System - SINIIGA – It was set in place as of June 2003, on which SAGARPA projects a fifteen years “investment” of almost $ 43.000 Million Pesos for a system (French-American-Mexican) totally obsolete and no adherence to any international rule or norm (ISO), on which I have submitted my opinion and commentaries before COFEMER and can be consulted in: http://www.apps.to cofemer.gob.MXfilev99/_B00062497.pdf

It is undeniable the great work and merits that SENASICA has obtained in other areas, but that is no reason to have neglected/fail on TSEs, although they are not of fast dissemination or of a spectacular morbidity due to its long “incubation” period and even though its symptomatology may be manifested or not, they are incurables diseases, without treatment and invariably mortal.

In Mexico (1998-2002) there are 44 registered human deaths by CJD- Creutzfeldt-Jakob disease which is caused by eating beef contaminated by BASE (Request of Information No 0001200024304, May 04, 2004). “Incubation” time in humans it varies from 2 to 45 years, depending the route on infection and the genetic conformation of the infected person.

A peculiar data; according to investigations carried out by Dr. Laura Manuelidis, 13% of the people in her project and who had been diagnosed and treated for Alzheimer in U.S.A., in fact they suffered CJD. According to the CONAPO (2004) in Mexico there are 700.000 people who suffer Alzheimer… would you dare to find out?

SAGARPA must assume its responsibility and let go protecting groups without scruples in exchange for the wellbeing of the rest of the population. Such attitudes and ridicules have already been translated in lost of human lives and it will continue costing human lives.

Eng. Ruiz Garcia, as you can see, there is a lot of information out there and everywhere beyond the “official scope” which SAGARPA ignores or tries to hide, which is worse.

I could discuss every topic with you and refute every assertion or excuse SAGARPA makes on such document and whose content lacks of minimum seriousness, reason why I will look for the most appropriate forum to expose SAGARPA
Again, I appreciate your fine attentions and look forward next year in obtaining a complete and unrestricted copy of the Analysis of Risk - Occurrence BSE in Mexico and all its supporting documents.

Respectfully,

Enrique M. Maldonado


e-mailed 01-15-07

cc:
Lic. Alonso Lujambio Irazábal, Comisionado Presidente, IFAI
Lic. Xochitl Castro, Asistente del Comisionado Presidente, IFAI




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