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From: TSS ()
Karen Eggert (301) 734-7280 STATEMENT BY DR. RON DEHAVEN REGARDING OIE RISK RECOMMENDATION March 9, 2007 “In October 2006, the U.S. Department of Agriculture submitted an application and supporting documents to the World Organization for Animal Health (OIE) to formally request country classification for bovine spongiform encephalopathy (BSE) risk. The OIE undertakes a thorough review process before recommending a risk classification, and then provides an opportunity for all delegate countries to review the recommendations and present comments prior to final adoption of a country’s classification at the OIE’s General Assembly meeting in May. “While we recognize that a final classification decision will not be made by the OIE until May, we feel it is important to be responsive to questions we are now being asked about the risk classification recommended for the United States. The OIE Scientific Commission has endorsed the recommendation from an OIE expert panel that the United States be classified as “controlled risk” for BSE. “The controlled risk classification recognizes that OIE-recommended, science-based mitigation measures are in place to effectively manage any possible risk of BSE in the cattle population. This recommendation provides strong support that U.S. regulatory controls are effective and that U.S cattle and products from cattle of all ages can be safely traded in accordance with international guidelines, due to our interlocking safeguards. “The OIE risk classification process is an essential step in promoting trade and understanding of this disease. We appreciate OIE’s review of our application, as well as its leadership in developing sound, science-based guidelines that will help countries standardize regulations and import requirements. We look forward to the final adoption of this classification, which will be announced at the OIE meeting in May.” # http://www.aphis.usda.gov/newsroom/content/2007/03/OIE_statement3-9-07.shtml BSE/BASE UPDATE USA United States District Court, District of Arizona Proceeding Type: Waiver/Plea U.S. Attorney: Long, Robert -------------------------------------------------------------------------------- if my siphering is correct, that would be about another 2600 potential mad cows that went into the food chain. add that to these ; >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.< REMINDER, CATTLE ON FEED IN TEXAS http://www.fda.gov/bbs/topics/NEWS/2001/NEW00752.html The USDA documents also indicate the agency never was able to identify or test 52 cows that came into the United States in 2001 along with the Washington cow that tested positive in 2003. Of these, 11 were considered to be "high risk" because they were born within a year and on the same premises as the infected cow. These cows may have gone into the food supply and been consumed by people. The concern is humans can contract a fatal brain disease from eating beef products contaminated with the mad cow pathogen. The second case, which was detected last year in a Texas cow and which USDA These two cases (the latest was detected in an Alabama cow) present a "The fact the Texas cow showed up fairly clearly implied the existence of Brown, who is preparing a scientific paper based on the latest two mad cow USDA officials finally retested the cow and confirmed it was infected seven "Everything they did on the Texas cow makes everything USDA did before 2005 PAUL BROWN COMMENT TO ME ON THIS ISSUE Tuesday, September 12, 2006 11:10 AM 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 Report No. 50601-10-KC January 2006 Finding 2 Inherent Challenges in Identifying and Testing High-Risk Cattle Still Remain Greetings list members, IF you remember correctly, i posted this ; Subject: Re: USDA/APHIS JUNE 2004 'ENHANCED' BSE/TSE COVER UP UPDATE snip... > snip...END WELL, someone did call me from Bio-Rad about this, Bio-Rad, TSS phone conversation 12/28/04 Finally spoke with ; at approx. 14:00 hours 12/28/04, I had a very pleasant my question; Does Bio-Rad believe USDA's final determination of False positive, ask if i was a reporter. i said no, i was with CJD Watch again, very nervous, will not answer directly about USDA for fear of "very political" "very loaded question" outside USA and Canada, they use many different confirmatory tech. in -------- Original Message -------- Hi Terry: ............................................snip Let me know your phone Regards Bio-Rad Laboratories 9/13/2005 http://www.fsis.usda.gov/OPPDE/Comments/03-025IFA/03-025IFA-2.pdf https://web01.aphis.usda.gov/BSEcom.nsf/0/b78ba677e2b0c12185256dd300649f9d?OpenDocument&AutoFramed https://web01.aphis.usda.gov/regpublic.nsf/168556f5aa7a82ba85256ed00044eb1f/eff9eff1f7c5cf2b87256ecf000df08d?OpenDocument [Docket No. 05-004-2] RIN 0579-AB93 Issue: Two commenters stated that the underlying assumption of the \2\ Bushmann, A., and Gruschup, M.; Highly Bovine Spongiform Response: APHIS is familiar with the results of the study mentioned \3\ Westaway, D., et al.; (1994) Degeneration of Skeletal Blood Issue: Two commenters expressed concern that there has been a \4\ Pattison, J., et al.; UK Strategy for Research and Response: As stated in our risk analysis, the pathogenesis studies [[Page 73907]] these findings did not indicate that additional mitigation measures \6\ Spongiform Encephalopathy Advisory Committee, Oct. 19, 2000, --------------------------------------------------------------------------- The study on scrapie-infected hamsters noted by the commenter \13\ Stahl, N. and Prusiner, S.B.; (1991) FASEB-J. 5: 2799-807. --------------------------------------------------------------------------- [[Page 73916]] APHIS agrees with the commenter that reports indicate that some of http://www.epa.gov/fedrgstr/EPA-IMPACT/2005/December/Day-14/i24057.htm Docket No. 05-004-1 RIN 0579-AB93 BSE TSS was Received PROPOSED RULES ======================================================================== This section of the FEDERAL REGISTER contains notices to the public of ======================================================================== Animal and Plant Health Inspection Service 9 CFR Part 94 [Docket No. 05-004-1] AGENCY: Animal and Plant Health Inspection Service, USDA. ACTION: Proposed rule. ----------------------------------------------------------------------- SUMMARY: We are proposing to amend the regulations governing the DATES: We will consider all comments that we receive on or before ADDRESSES: You may submit comments by any of the following methods: snip... International guidelines for trade in animal and animal products Chapter 2.3.13 of the Code and supplemented by Appendix 3.8.4 of the http://a257.g.akamaitech.net/7/257/2422/01jan20051800/edocket.access.gpo.gov/2005/pdf/05-16422.pdf Greetings again APHIS ET AL, P.O. Box 42 Bacliff, Texas USA 77518 Please note that it may take between 24 and 72 hours for the EDOCKET staff to process your comment before it is available publicly through EDOCKET. You can use the identifier noted above to find your comment through the Quick or Advanced Search pages when it is available. ........... next 3 urls now dead ; "[Docket No. 05-004-1] RIN 0579-AB93 BSE TSS " was Received BSE; MRR; IMPORTATION OF LIVE BOVINES AND PRODUCTS DERIVED FROM BOVINES [Docket No. APHIS-2006-0041] RIN 0579-AC01 APHIS-2006-0041-0006 Comment from Terry S Singletary Sr 01/09/2007 PUBLIC SUBMISSIONS http://www.regulations.gov/fdmspublic/ContentViewer?objectId=09000064801f3412&disposition=attachment&contentType=crtext http://www.regulations.gov/fdmspublic/ContentViewer?objectId=09000064801f3413&disposition=attachment&contentType=msw8 full text ; Terry S. Singeltary Sr. Belgium/Netherlands Sheep Test Results Background Factsheet Veterinary Services April 2002 APHIS snip. Additional tests will be conducted to determine exactly what TSE the animals have BSE or scrapie. These tests involve the use of bioassays that consist of injecting mice with tissue from the infected animals Page 15 of 98 8/3/2006 and waiting for them to develop disease. This testing may take at least 2 to 3 years to complete. http://www.aphis.usda.gov/lpa/pubs/fsheet_faq_notice/fs_ahvtsheeptr.pdf DECLARATION OF EXTRAORDINARY EMERGENCY BECAUSE OF AN ATYPICAL T.S.E. (PRION DISEASE) OF FOREIGN ORIGIN IN THE UNITED STATES http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2000_register&docid=fr20jy00-31 DECLARATION OF EXTRAORDINARY EMERGENCY BECAUSE OF AN ATYPICAL T.S.E (PRION DISEASE) OF FOREIGN ORIGIN IN THE UNITED STATES [2] http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2000_register&docid=fr20jy00-32 Mr. Singeltary. I hope this finds you well. As you are aware I left the USDA last Linda Detwiler My reply to Dr. Detwiler; --- Original Message --- hello Dr. Detwiler, thanks for your kind reply. > However, we were prioritized after their own needs, hence the delay. not sure i understand that? > You will have to contact USDA for further word. already done that, and there answer was; Dear Mr. Singeltary, The Western blot tests on these animals were completed in April of this Have a nice day, Jim Rogers --- Original Message --- Dear Mr Singeltary Thank you for you enquiry to the SEAC secretariat about mouse bioassays After making a number of enquiries, it appears that Defra were not involved Yours sincerely Tom Barlow Dr Tom Barlow Tel: 0207 904 6267 http://www.fsis.usda.gov/OPPDE/Comments/2006-0011/2006-0011-1.pdf [Docket No. FSIS-2006-0011] FSIS Harvard Risk Assessment of Bovine 9/13/2005 http://www.fsis.usda.gov/OPPDE/Comments/03-025IFA/03-025IFA-2.pdf Suppressed peer review of Harvard study October 31, 2002. http://www.usda.gov/oig/webdocs/50601-10-KC.pdf Subject: Re: OIE WEAKENS BSE GUIDELINES EVEN MORE FOR TRADE PURPOSES, putting humans further 'at risk' globally Under the previous guidelines of the World Organization for Animal Health, known commonly as OIE, the U.S. would have had to wait until 2013 before it could be recognized as a "negligible risk" country. Under the new guidelines, approved Wednesday by unanimous vote, there will be little or no waiting. "For the U.S., this is much better," said Alex Thiermann, an OIE chairman.......snip.........end International Organisations Coordinator U.S. Department of Agriculture USDA, APHIS Dr. Thiermann is serving as International Organisations Coordinator in Paris, France, where he represents APHIS at relevant standard setting organisations dealing with animal health and international trade. This recent appointment in Paris resulted in response to his current leadership position in the standard setting committee of the OIE, as well as his past experience as twice chairman of the World Trade Organisation's Sanitary and Phytosanitary Committee (WTO-SPS). During 1997 to 1999 he was elected Chairman of the World Trade Organisation, Sanitary and Phytosanitary Committee (WTO-SPS). From 1994 he served as the vice-president of the OIE' Code Commission and since 2000 he has served as president of this important standard-setting committee. He served as a member of the U.S. delegations to the negotiation of the WTO, the IPPC, as well as serving as U.S. Coordinator for the Codex Alimentarius. He joined APHIS in 1989 as the Deputy Administrator for International Services. Before joining APHIS, he served as the National Program Leader for animal health research under the USDA's Agriculture Research Service (ARS). A native of Chile, he received his DVM degree from the University of Chile, and a PhD degree from the School of Medicine at Wayne State University in Detroit, Michigan. ............. WASHINGTON (Dow Jones)--The U.S. will now have a much stronger case to make that there is virtually no mad-cow disease risk here thanks to a decision Wednesday by the Paris-based World Organization for Animal Health to relax country standard requirements. Previously, a country had to wait seven years after its discovery of mad-cow disease, or bovine spongiform encephalopathy, before it could be considered in the "negligible risk" category -- the category for countries with the least BSE risk. That has now been changed and countries must wait until 11 years after birth date of the last native-born cow discovered with the disease. The U.S. reported finding its latest BSE case in March, but U.S. Department of Agriculture officials say the infected cow was more than 10 years old when it died. Under the previous guidelines of the World Organization for Animal Health, known commonly as OIE, the U.S. would have had to wait until 2013 before it could be recognized as a "negligible risk" country. Under the new guidelines, approved Wednesday by unanimous vote, there will be little or no waiting. "For the U.S., this is much better," said Alex Thiermann, an OIE chairman. He also called the new age-based guideline more "realistic." Ron DeHaven, head of USDA's Animal and Plant Health Inspection Service, called the new guidelines "a significant change," in a telephone interview with Dow Jones Newswires, prior to the OIE vote. DeHaven who is currently in Paris for the OIE annual meeting, said, "When we found the (BSE) case is not nearly as relevant as when that animal was born." Michael David, head of USDA's National Center for Import and Export, agreed and explained that an infected cow's age can point to when there was a spread of the disease. There are three OIE risk categories: "negligible," "controlled" and "undetermined." The U.S. would prefer to be considered "negligible" because it provides negotiators with a stronger case for countries to reopen borders to U.S. beef. A "negligible" standing also carries with it fewer costly safety restrictions than the other categories. The U.S. has reported finding three cases of BSE in cattle -- one in December 2003, a second in June 2005 and a third in March 2006. However, USDA officials said only the two latest cases count under the new OIE guidelines. The first BSE case, officials said, was in an animal about 6 years old, but that animal was born and infected in Canada before being sent to the U.S. David said that first BSE discovery "was an imported case and it really doesn't matter because we can show that it came from Canada. The two that mattered to us are two native cases and one was born 12 years ago ... and the second one is at least 10 years old." Despite the infected animal's origin, the December 2003 BSE discovery was and still is very important to many beef-importing nations. Most importing countries, including Japan, South Korea and China, shut their borders to U.S. beef in December 2003. Japan has since eased its ban and then reinstated it, but even when the country resumes importing again it will maintain restrictions on U.S. beef that are far stricter than OIE guidelines. The USDA's David said Japan registered an official objection with the OIE on the BSE standard changes approved Wednesday, but the country did not vote against them. China and the U.S. are in negotiations now to resume beef trade, but China's refusal to accept USDA claims that it is a "negligible risk" country complicated talks held in mid-May. USDA officials now have a much stronger argument that U.S. beef products are among the least risky for BSE in the world, but an official OIE confirmation of "negligible" status for the U.S. could be as much as two years away, David said. The process is long and complex, requiring well detailed explanations of such things as a country's BSE surveillance program. -By Bill Tomson; Dow Jones Newswires; 202-646-0088; bill.tomson@dowjones.com ##################### Bovine Spongiform Encephalopathy ##################### C H A P T E R 2 . 3 . 1 3 . BOVINE SPONGIFORM ENCEPHALOPATHY Article 2.3.13.1. The recommendations in this Chapter are intended to manage the human and animal health risks associated with the presence of the bovine spongiform encephalopathy (BSE) agent in cattle (Bos taurus and B. indicus) only. 1) When authorising import or transit of the following commodities and any products made from these commodities and containing no other tissues from cattle, Veterinary Administrations should not require any BSE related conditions, regardless of the BSE risk status of the cattle population of the exporting country, zone or compartment: snip... 2005 OIE Terrestrial Animal Health Code Subject: Re: OIE WEAKENS BSE GUIDELINES EVEN MORE FOR TRADE PURPOSES, putting humans further 'at risk' globally In Reply to: Re: OIE WEAKENS BSE GUIDELINES EVEN MORE FOR TRADE PURPOSES, putting humans further 'at risk' globally posted by TSS on May 25, 2006 at 7:08 am: The 74th Annual General Session of the International Committee of the World Organisation for Animal Health (OIE) was held in Paris from 21 to 26 May 2006 . The General Session notably brings together representatives appointed by the Governments of the 167 OIE Member Countries. Approximately 600 participants representing Member Countries, intergovernmental organisations (FAO, WHO, World Bank, WTO etc.) took part in the event. The Session was honoured by the presence, alongside the President and the Director General, of high-ranked authorities, including numerous Ministers of OIE Member Countries. Member Countries praised the role played by the OIE in the global fight against avian influenza. They particularly saluted the agreement reached with the World Bank and key donors to support developing and in transition countries to invest in programmes aimed at bringing their Veterinary Services in line with OIE standards. The main points dealt with during the Session were as follows: - The session accredited the application of a new Collaborating Centre - the Centre for Disease Control (CDC in Atlanta ) - with the aim of better preventing and controlling animal diseases transmittable to human beings. It also recognized the crucial role played by the OIE network of 170 reference laboratories and collaborating centres in reaching the organization's objectives ; - Member Countries welcomed the new World Animal Health Information System (WAHIS) that will strengthen OIE's actions in terms of transparency on state of animal diseases worldwide; - Consistent with the framework of its usual standard-setting activities, the Committee adopted new and updated international standards aimed at providing better safeguards for the sanitary safety of world trade in terrestrial and aquatic animals and their products as well as guidelines to better implement surveillance of animal diseases and zoonoses on their territory. - Member countries also voted new improvements to chapters about animal welfare and food safety in production phase; - They adopted policy lines on identification and animal traceability; - Special attention was given to updating the chapter on BSE in the Terrestrial Animal Health Code. Adopted texts highlighted global surveillance methods that will allow the OIE to propose willing Member Countries a new procedure for an official recognition of their status on the disease; - The Session approved the lists of countries or zones recognized by the OIE as being free from foot and mouth disease, rinderpest, contagious bovine pleuropneumonia and bovine spongiform encephalopathy; - Member Countries also decided that notification to the OIE of any detection of highly pathogenic avian influenza (HPAI) in wildlife was to be compulsory; - The list of Veterinary Critically Important Antimicrobials (VCIA) defined by OIE was published; - The worldwide zoosanitary situation has been examined in detail ; - Two technical items of biggest interest were presented and debated during the Session and gave rise to Resolutions passed by the International Committee: - Economic and social justification of investment in animal health and zoonoses; - Future approaches needed to ensure veterinary education meets societal demands. The high level of scientific expertise of the speakers and the quality of the debates that followed the presentation of each technical item will have served to promote the global application of concepts that are essential for improved control of animal diseases and zoonoses. The International Committee undertook the election of the new OIE President. Dr Barry O'Neil was elected for a three-year mandate. Members of the Administrative Commission, Regional Commissions and Specialist Commissions were also elected by the General Assembly. http://www.oie.int/eng/press/en_060526.htm Canadian import rule progresses http://www.thecattlemanmagazine.com/newsDesk/news_update_12.04_tscra_Texas_cattle.asp#TSCRA%20urges%20APHIS%20to%20revise%20BSE%20surveillance%20plan Updated :09-Jan-2004 The OIE standards on BSE: a guide for understanding and proper implementation The World Organization for Animal Health (OIE) has become increasingly concerned about reports of international trade disruptions involving the misinterpretation of OIE standards. Recent published information on categorization of countries by the OIE indicates there are some apparent misunderstandings about the nature and purpose of the OIE international standards and guidelines, and their interpretation and implementation by Member countries. The OIE Terrestrial Animal Health Code (the Code) contains standards, guidelines and recommendations to be used by national veterinary authorities to prevent the introduction of infectious agents pathogenic for animals and humans into the importing country during trade of animals and animal products, while avoiding unjustified sanitary barriers. While the Code describes conditions for the classification of countries into one of five BSE risk categories, the OIE itself does not assign countries to all these categories. These are used by importing countries when determining the specific conditions for trade. However, the OIE has been recently requested to examine country submissions, made on a voluntary basis, for determining whether they meet the conditions to be officially classified by an OIE decision as "BSE free" or "BSE provisionally free". For the moment the OIE does not give an opinion on the further 3 categories existing in the Code. So far no country has been given such recognition by the OIE. Furthermore, the OIE has been requested by Member countries to reduce the current number of categories. The Code also draws attention to the obligations under the provisions of the World Trade Organization-Sanitary and Phytosanitary Agreement (WTO-SPS), whereby the importing country cannot be more trade restrictive than necessary to achieve the desired national level of protection, and that its measures must not be different from those applied to products within the domestic market. The OIE chapter on BSE currently describes five levels of exporting country status based on their determined risk level (free, provisionally free, minimal risk, moderate risk and high risk). It then addresses trade conditions for various commodities through an increasing degree of restrictions commensurate with the risks presented. For example, fresh meat may be imported safely from a country of any BSE status but with increasing restrictions so that, for countries presenting a high BSE risk, more severe measures are applied to the cattle and to the meat itself. The experts consider that, if these measures are followed, the meat is safe. For some commodities however, the experts have determined that particular commodities should not be exported even from countries presenting a low BSE risk. For example, meat and bone meal, or any commodity containing such products, which originate from countries with minimal, moderate or high BSE risk should not be traded. It is apparent that some Member Countries are applying trade bans when an exporting country reports the presence of BSE, without consulting the recommendations in the Code or conducting a risk analysis in accordance with its OIE and WTO obligations. While the Code provides increasingly restrictive recommendations which are commensurate with the level of BSE risk in each of the country status categories, it does not recommend any other ban than the above mentioned on trade of animals or specific animal products. Regarding the BSE situation in the European Union and more recently in Japan, Canada and the US, the existence of valid up-to-date standards did not prevent major trade disruptions due to a failure by many countries to apply the international standard when establishing or revising their import policies. This has been particularly evident in the case of commodities for which the Code recommends that no restrictions be applied, regardless of the BSE status of the exporting country. Except for short trade suspensions during investigation period following a new epidemiological event, it is of particular concern to the OIE that many countries apply trade bans when an exporting country reports its first case of BSE, without having conducted a risk analysis as described in the Code. Such situations penalise countries with a good and transparent surveillance system for animal diseases and zoonoses, and which have demonstrated their ability to control the risks identified. This may result in a reluctance to report future cases and an increased likelihood of disease spread internationally. http://www.oie.int/eng/press/en_040109.htm Our third general concern has to do with these rules being less stringent than international standards. We are aware that OIE standards for a minimal risk BSE country do not necessarily require 7 years since the last case. OIE does have certain requirements for regions to qualify as minimal risk regions in countries where BSE was identified less than 7 years ago. However, a reading of the OIE Standards reveals that, when applied to the present case, Canada fails to meet those standards. This is where this proposed rule is more lenient than OIE standards. The OIE standard requires that, in countries where BSE was identified less than 7 years ago, there has been a feed ban in place for 8 years. Canada’s feed ban went into effect in 1997. Therefore, the Canadian feed ban went into effect approximately 6 ½ years ago. The OIE standard for a Minimal Risk BSE country or zone is quoted below: b) the last indigenous case of BSE has been reported less than 7 years ago, and the BSE incidence rate, calculated on the basis of indigenous cases, has been less than one case per million during each of the last four consecutive 12- month periods within the cattle population over 24 months of age in the country or zone (Note: For countries with a population of less than one million adult cattle, the maximum allowed incidence should be expressed in cattle-years.), and: i) the ban on feeding ruminants with meat-and-bone meal and greaves derived from ruminants has been effectively enforced for at least 8 years; http://www.agdepartment.com/Testimony/CommentsBSE1-2-04.pdf rule, what standards should the Agency apply to determine a country's BSE status? As stated above, strong precedents and justification exist for US authorities granting exemptions from BSE-related measures for counties which do not pose a BSE risk. This ability to grant exemptions should not be restricted to FSIS measures as implied by question 35, but should be applied across all relevant US authorities. Various options exist for standards that could be applied to determine a country's BSE status. Some of these are canvassed below. As a matter of principle, a country, other than one that is recognised as posing a BSE risk under current US regulation 9 C.F.R. 5 94.18, should not have new FSIS or FDA measures applied to it until any new determination of BSE status that may be required under other US Statutes is made. As long as they remain BSE free, these countries should be allowed to trade under pre-existing conditions that applied under USDA and FDA rules and regulations, pending the completion of any additional BSE status assessment that is required. Some options for determining a country's BSE status include: Option 1 : An assessment of BSE status of relevant counties is already conducted under current US regulation 9 C.F.R. 5 94.18. FDA and FSIS rules and regulations could recognise equivalence for counties that are recognised as BSE fiee under this rule, using whatever standards are already in place for these assessments. Option 2: The US could formally adopt its own criteria. We suggest that these should be based on those promulgated by the OIE for BSE free and BSE provisionally free countries. Such an approach is consistent with that in the proposed rule, BSE Minimal Risk Regions and Importation ofCommodities. This proposed rule suggests a list of factors that has been determined by APHIS to evaluate the BSE risk from a region and classify a region as a BSE minimal-risk. These factors appear to be largely based on OIE recommendations for this category of country or region. regulations that entered into force in 2003 define SRMs similarly to the FSIS Interim Final Rule and prohibit the sale or importation of food that contains sRMs.' However, the Canadian regulation also states that the prohibition "does not apply in respect of food that originates from a country that is designated as being free from BSE . . . . "2 Under a related provision in Canada's Health of Animals regulations, the government may utilize various criteria to designate countries which the government considers to be free from the diseases that pose certain risks.3 Pursuant to its regulatory authority, the Canadian government issued an announcement in 2003 regarding its revised BSE import policies that sets forth the criteria by which Canada determines whether a country is free.^ US authorities could decide to adopt an assessment system that incorporates the Canadian (or similar) criteria. As stated verbatim in the announcement, these criteria include: Either a. For the preceding seven (7) years, the country of origin must have reported no cases of BSE in indigenous bovines, AND b. no cases of BSE have been attributed to the country of origin from another country through epidemiological investigation, OR c all cases of BSE have been clearly demonstrated to originate directly from the importation of live cattle from a BSE affected country and no cases of BSE have been attributed to the country of origin from another country through epidemiological investigation. AND (all of the following) d. The country of origin must have the animal health legislative authority to regulate BSE and the zoosanitary infrastructure to enforce surveillance, monitoring, eradication and import controls for BSE. e. BSE must have been made a nationally notifiable disease in the country of origin for the preceding seven (7) years. f. The country of origin must have an eradication policy for BSE that includes the investigation of suspect animals and, if confirmed positive, their slaughter and destruction and the depopulation of any bovine animal that epidemiological investigation identifies as potentially having been exposed to the disease agent or common risk factor. Animals to be disposed of must be excluded from both the human and animal food chain. C.R.C., C. 870, s. B.01.047.1. Id. ' C.R.C., C. 296, s.7. Canadian Food Inspection Agency, Canadian Bovine Spongifom Encephalopathy (BSE) Import Policies (June 16,2003), available at http://www.inspection.gc.cdenglish/animdheasapolicy/ie-2OOl-l7-42.shl (last viewed Mar. 19, 2004). http://www.fsis.usda.gov/OPPDE/Comments/04-021ANPR/04-021ANPR-63.pdf Electronic Bulletins IMPORTANT NOTICE - Revised Policy Regarding Gelatin in Natural Health Products www.efsa.eu.int 1 Opinion of the Scientific Panel on Biological Hazards of the European Food Safety Authority on the “Quantitative assessment of the Human BSE risk posed by Bovine Vertebral Column including Dorsal Root Ganglia with respect to residual BSE risk”1 (Question N° EFSA-Q-2003-099) Adopted on 18 May 2006 SUMMARY 1.1. Residual BSE risk due to Bovine Vertebral Column The European Food Safety Authority (EFSA) quantitative risk assessment (QRA) guidance document gives residual Bovine Spongiform Encephalopathy (BSE) risk assessments for byproducts – tallow, gelatine and calcium phosphates – used in human food obtained from cattle fit for human consumption (EFSA QRA report, 2004). The effect of including vertebral column in the batch of raw materials used for the production of the by-products was calculated as part of separate risk assessments for these materials. The Commission Mandate to EFSA asked the Panel to review the “Opinion and report, assessment of the human BSE risk posed by bovine vertebral column including dorsal root ganglia (adopted on 16 May 2002)” in the light of their QRA on residual BSE risk and, if appropriate, revise the 2002 Opinion accordingly. This revision covers the by-products, tallow and gelatine, but does not consider the human risk from consumption of meat on the bone or the inclusion of bovinederived phosphates as food additives, or the effect of changing the age limit for regarding vertebral column as specified risk material. The EFSA Opinions on tallow and gelatine give descriptions of manufacturing processes, the various assumptions relating to their QRA and the background considerations relating to the interpretation of the output values. In this document we simply reproduce the relevant conclusions and recommendations of those opinions relating to the inclusion of vertebral column and the production of these by-products. 1 For citation purposes: Opinion of the Scientific panel on Biological Hazards on “Quantitative assessment of the Human BSE risk posed by Bovine Vertebral Column including Dorsal Root Ganglia with respect to residual BSE risk”, The EFSA Journal (2006), 359, 1-3 Summary of Opinion www.efsa.eu.int 2 Some illustrative data is shown below for the range of median (P50) exposure estimates (units, Cattle oral infectious dose 50%, CoID50/person/week)2. For detailed results see table 1 further in this document. GBR II† GBR III GBR IV Tallow De-Greasing bones * * 10-12 to 10-11 Mixture of tissues * * 10-12 to 10-10 Gelatine Acid & Alkaline * * 10-9 to 10-8 Heat & Pressure * * 10-11 to 10- 10 The logic of interpreting the CoID50 units of exposure in terms of human risk is essentially that assuming a species barrier of 1, and all the other assumptions, an exposure value > 10-8 per time period may result in one or more cases of vCJD per time period. The only scenario in which the P50 values approach the 10-8 level is in the production of gelatine from bovine bones by the acid and alkaline method. Referring back to the gelatine opinion, this is a worst case consumption scenario where all the daily human dose of gelatine is assumed to be bovine bone derived (when it is more likely to be 1-5%). Similarly, for more realistic sourcing scenarios such as a GBR III country with reliable surveillance, even the P97.5 values only approach 10-8 for gelatine produced from bovine bones by the acid and alkaline method (and a worst case consumption input). 1.2. Conclusion of this revision • Inclusion of vertebral column in the raw materials used to produce tallow and gelatine from bones or a mixture of tissues increases the level of human exposure by ~ 3-10 fold. However, the levels of residual BSE risk for these products calculated in the QRA are low and the increased risk factor due to inclusion of vertebral column is unlikely to translate into further cases of vCJD in the population. Therefore, in the case of tallow and gelatine, there appears to be no rationale for imposing an age-limit above which to exclude vertebral column from the batches of raw materials used to produce these by-products. • The human risk from consumption of meat on the bone or the inclusion of bovine-derived phosphates as food additives could be estimated using the QRA model if the appropriate input data for human consumption were available. 1.3. Further recommendations of the BIOHAZ Panel during the adoption of this report at their Plenary Meeting, 17-18th May, 2006 • This is the final Report to be revised in the light of the EFSA BSE QRA guidance document (EFSA QRA report, 2004), and joins a series covering a range of residual BSE risk assessments on the cattle by-products : tallow, gelatin, and calcium phosphates. Each revision considers the separate effects of the QRA on the risk of exposure to human and/or cattle population for each by-product. The Panel recognised the need to evaluate the cumulative effect of each incremental change in exposure to the populations calculated in 2 * in this Table is defined as an exposure level of < 10-13 CoID50 units/person/per week. † GBR: Geographical BSE Risk Summary of Opinion www.efsa.eu.int 3 these revisions, and recommended that this “total” exposure assessment be carried out in the near future. • “Gaps” in these residual risk assessments were inevitable due to the restricted scope of the original EFSA BSE QRA guidance document, and the Panel recommended that these gaps should be addressed by future Panel members using their “self-tasking mandate” option. For example, in the context of this vertebral column document, the QRA model could be used to estimate the human risk from consumption of meat on the bone or the inclusion of bovine-derived phosphates as food additives. • The EFSA BSE QRA guidance document was written almost four years ago, and although some parts have been revised since then to accommodate new research findings, the methodology and nomenclature for defining the geographical BSE risk (GBR) input to the model is no longer appropriate. New methodology, under the auspices of the OIE, is under construction within the EU and EFSA and the Panel recommended that once these classifications had been finalised they should harmonised with those used in the EFSA BSE QRA guidance document. The Panel anticipated that this harmonisation may have a knock-on impact on the QRA calculations, conclusions and recommendations and that, again, future Panel members should review this, and other, inputs of the QRA and address this impact using their “self-tasking mandate” option. OPINION under construction within the EU and EFSA and the Panel recommended that once these classifications had been finalised they should harmonised with those used in the EFSA BSE QRA guidance document. The Panel anticipated that this harmonisation may have a knock-on impact on the QRA calculations, conclusions and recommendations and that, again, future Panel members should review this, and other, inputs of the QRA and address this impact using their “self-tasking mandate” option.<<< WHAT ABOUT RISK FACTORS TO HUMANS FROM ALL OTHER TSEs, WITH RELATIONS TO SRMs ??? see full text ; II. Summary of APHIS’ regulatory standards for Minimal Risk regions In the November 4, 2003, proposed rulemaking (APHIS 2003c), APHIS proposed to define standards for a Minimal Risk region and establish import requirements that imposed additional risk mitigation measures on animals and animal products imported from Minimal Risk regions. The minimal risk standards incorporated the broad elements of the Office International des Epizooties (OIE) guidelines for Minimal Risk regions (OIE 2004a). Below, we provide a discussion of the final standards and a more explicit discussion of how OIE guidelines were incorporated into our considerations in the development of the standards. In the final rule, the APHIS standards for a BSE Minimal Risk region define it as a region that: In developing each of these standards for a BSE Minimal Risk region, APHIS based its standards on the guidelines established by the OIE for determining the BSE status of a region. The OIE guidelines, contained in Chapter 2.3.13 of the Terrestrial Animal Health Code (OIE 2004a) and supplemented by Appendix 3.8.4 of the Code (OIE 2004b), currently provide for five possible BSE classifications for regions. For each classification, the guidelines recommend different export conditions for live animals and products, based on the risk presented by the region. This framework not only recognizes different levels of risk among regions, but also provides for trade in live animals and products under certain conditions even from regions considered high-risk under the OIE guidelines. In the discussion that 2Analysis of Risk - Update for the Final Rule: Bovine Spongiform Encephalopathy; Minimal Risk Regions and Importation of Commodities: Animal and Plant Health Inspection Service, December 2004 follows, we provide a more detailed discussion of the application of each of these standards with relevance to the OIE guidelines. (1) Measures in place A Minimal Risk region must have had in place risk mitigation measures and apply additional measures as appropriate. Such measures are based on risk considerations identified in the OIE Terrestrial Animal Health Code Article 2.3.13.2 and embodied in the Article 2.3.13.5, point 1, requirement that a "risk assessment … has been conducted and it has been demonstrated that appropriate measures have been taken for the relevant period of time to manage any risk identified." OIE measures include (but are not limited to): a broad eradication program and extensive surveillance following the detection of BSE; effective epidemiological investigations with appropriate tracing, control and destruction of risk animals; measures to identify and effectively control pathways for amplification of BSE; continuing risk considerations with corresponding revisions of existing mitigations; processing methodologies; appropriate awareness programs; effective detection and control measures; and veterinary infrastructure sufficient to define and implement these programs. Under APHIS regulations (see (1)(i)-(1)(iii) above), these measures must include: import restrictions, surveillance, and an effective feed ban. (1)(i) Import Restrictions APHIS will evaluate the stringency and effectiveness of import restrictions to prevent the importation of BSE infected animals and BSE contaminated products. Our approach reflects the emphasis in the Terrestrial Animal Health Code on the evaluation of risk from imports and the need to take appropriate steps to address any identified risk. Specifically, the OIE Terrestrial Animal Health Code Article 2.3.13.2 identifies the need to assess the likelihood that a transmissible spongiform encephalopathy (TSE) agent has been introduced via imports and, as mentioned above, Article 2.3.13.5, point 1, emphasizes the need to demonstrate that appropriate measures have been taken. (1)(ii) Surveillance An APHIS evaluation of the surveillance program in place within a region will consider whether a region has in place a level of surveillance and monitoring which meets or exceeds the recommendations of OIE Terrestrial Animal Health Code Appendix 3.8.4 (OIE 2004b). The OIE recommendations specify approaches to determine whether BSE is present in the country, and, if present, to monitor the extent or evolution of the disease spread. Issues addressed include general principles for examination for clinical signs in relation to statistical approaches to sampling. The recommendations specify the minimum number of cattle exhibiting one or more clinical signs of BSE that should be subjected to diagnostic tests according to the total cattle population over 30 months of age and include recommendations for active targeted surveillance. With respect to the number of samples that must be taken over the preceding 7 years based on the national census of cattle over 30 months of age, APHIS will consider a region to have exceeded the OIE recommendations if the region 3Analysis of Risk - Update for the Final Rule: Bovine Spongiform Encephalopathy; Minimal Risk Regions and Importation of Commodities: Animal and Plant Health Inspection Service, December 2004 samples a larger number of animals than those recommended by OIE over the appropriate period of time. APHIS will also assess policies and practices for active targeted surveillance. (1)(iii) Feed Ban APHIS will also consider the effectiveness of a feed ban in place within a region. Determining whether a feed ban has been effectively enforced will involve a review of a number of interrelated factors, including: the existence of a program to gather compliance information and statistics; whether appropriate regulations are in place in the region; the adequacy of enforcement activities (e.g., whether sufficient resources and commitment are dedicated to enforcing compliance); a high level of facility inspections and compliance; accountability of both inspectors and inspected facilities; and adequate recordkeeping. Another indication of an effective feed ban can be derived from epidemiologic investigations of diagnosed cases. Cases of BSE found in animals born after the feed ban was implemented would suggest either that the feed ban was ineffective or that there were noncompliance issues. Because of the variability in the incubation period of BSE, APHIS chose not to follow the specifications of the OIE Terrestrial Animal Health Code (Article 2.3.13.5, point 2) that require a "ban on feeding ruminants with meat-and-bone meal (MBM) and greaves derived from ruminants has been effectively enforced for at least 8 years" [unless the last indigenous case of BSE was reported more than 7 years ago]. Rather, APHIS chose to consider the length of time a feed ban has been in place within the context of the sum total of the control measures in place at the time of the diagnosis of BSE and the actions taken subsequently, recognizing that measures taken with regard to other factors (e.g., inspection practices and level of compliance with the feed ban) may provide more positive evidence than simply the length of the feed ban. APHIS will consider the factors above as well as region-specific factors—as a combined and integrated evaluation tool—to determine the overall effectiveness of control mechanisms and to analyze the residual risk. In determining whether the measures in place are adequate, APHIS will also consider the BSE incidence within a region with reference to the specific incidence criteria set forth in OIE Terrestrial Animal Health Code, Article 2.3.13.5 – i.e., "the BSE incidence rate, calculated on the basis of indigenous cases, has been less than 2 cases per million adult cattle during each of the last 4 consecutive 12-month periods within the cattle population over 24 months of age in the country or zone." In this way, APHIS will examine a combination of factors in a manner that allows us to evaluate an individual country’s specific situation, to acknowledge enhanced risk reduction effects of one or more factors that may compensate for other factors, and thereby, to analyze risk based on the overall effectiveness of actions taken by the country to prevent the entry and spread of BSE. (2) Epidemiological Investigations APHIS will assess the adequacy and results of any epidemiological investigation conducted by authorities of the region to establish that the standard has been met satisfactorily. Consistent with Article 2.3.13.5, point 2.b. iii of the OIE Code, we will assess whether risk 4Analysis of Risk - Update for the Final Rule: Bovine Spongiform Encephalopathy; Minimal Risk Regions and Importation of Commodities: Animal and Plant Health Inspection Service, December 2004 animals have been identified and controlled and whether the risk animals have been destroyed as appropriate. Appropriate destruction means the animals are prevented from entering the ruminant feed chain—either through controls and restrictions on carcass disposal or through traceback efforts. (3) Additional Risk Mitigation Measures During its evaluation, APHIS will determine whether programs such as the ones identified in the OIE guideline are in place and assess their effectiveness. If a region has had a case of BSE within the preceding 7 years or a region has not had a case within the preceding 7 years but has not had an effective feed ban in place for 8 years, the OIE Terrestrial Animal Health Code, Article 2.3.13.5 indicates a region should demonstrate compliance with the measures in points 2 to 5 of Article 2.3.13.2. Points 2 to 5 include an ongoing awareness program for veterinarians, farmers, and workers involved in transportation, marketing, and slaughter of cattle; compulsory notification and investigation of all suspected cases of BSE; a BSE surveillance and monitoring program; and examination in an approved laboratory of brain and other tissues collected within the framework of the surveillance and monitoring system. In addition to consideration of the effectiveness of any of these measures, APHIS will also evaluate factors such as slaughtering and rendering practices, including specified risk materials (SRM) removal; evidence of a broad eradication program; increased surveillance; and additional import restrictions. III. Release assessment A release assessment requires consideration of country of origin factors (e.g., incidence/prevalence, surveillance and control programs), biologic factors (e.g., age of animals, agent predilection sites), and commodity factors (e.g., ease of contamination, effect of processing) (OIE Article 1.3.2.4). We considered a number of specific risk factors in the original release assessment, including: incidence of disease in the region of origin; levels of infectious agent; tissue localization; and feed source and exposure. Below, we provide an expanded discussion of these factors as they relate to our evaluation of Canada as a minimal risk region. III.A. Considerations Related to Country of Origin Factors Country of origin factors encompass a variety of factors such as disease incidence as well as risk mitigation measures. In its previous analyses (APHIS 2003b, 2004a), APHIS observed that the two cases of BSE in Canadian-origin animals, one in May 2003 in Canada and one in the United States in December 2003, satisfied the OIE incidence criterion for a minimal BSE-risk country, currently, less than two cases per million cattle over 24 months of age during each of the preceding 4 consecutive 12-month periods. While we recognize that the number of detected cases does not, by itself, allow for the determination of prevalence, evaluation of existing control measures within a country, including the level of surveillance, provides sufficient information from which to determine the magnitude of the risk. This 5Analysis of Risk - Update for the Final Rule: Bovine Spongiform Encephalopathy; Minimal Risk Regions and Importation of Commodities: Animal and Plant Health Inspection Service, December 2004 section contains more detailed information on several of the factors we considered in making our determination. III.A.1. Canadian import restrictions Canada has implemented effective methods for preventing BSE introduction and subsequent potential for spread within Canada in order to minimize the possibility that infected ruminants or contaminated feedstuffs enter the country. The potential for introduction of the BSE agent into Canada has been limited by import restrictions on MBM and live animals. Canada’s Animal Disease and Protection Regulations (1978) and Health of Animals Regulations (1991) prohibited importation of MBM from countries other than the United States and, later, from Australia and New Zealand. These rules were first initiated in response to foot-and-mouth disease (FMD) and later extended to address BSE issues. The Canadian Food Inspection Agency (CFIA) has extensively reviewed its history of imported commodities. CFIA examined transaction records obtained from Canada Customs and Revenue Agency (CCRA) for imports that occurred between 1990 and 2000. Of 4,000 records, 400 potentially represented prohibited material and required further investigation. No records of hazardous imports were discovered and transactions relating to ruminant feed were found to be either misclassifications or incorrectly identified. Further investigation focused on review of Eurostat data (Eurostat 2004) and the import trade data tables provided by Statistics Canada for the period of 1980-2000. References to potential MBM importations from Denmark, France, Belgium, Germany, and Japan, were reviewed in CCRA records and evaluated for MBM and related high risk material. The conclusion of the investigations was that Canada had not imported MBM for use in livestock feed from any country other than the United States, Australia, and New Zealand (CFIA 2002). In addition, in 2000, Canada conducted a review of products imported from countries of the EU, Scandinavia, and Eastern Europe. The review period covered imports for the years between 1990 and 2000. Original documents with descriptions and volumes held by CFIA veterinary inspectors at ports of entry were investigated. The review concluded that MBM used for livestock feed had only been imported from the United States, Australia, and New Zealand (CFIA 2002). Canada has not imported live cattle from the United Kingdom (UK) since 1990. In 1994, an import ban was imposed on all countries where BSE had been detected in native cattle, and from 1996 live cattle could only be imported from countries that Canada designated as free from BSE following a comprehensive risk assessment (CFIA 2003a). After detection of BSE in an imported animal in 1993, Canada traced and destroyed and incinerated or repatriated all surviving cattle imported from the UK (Kellar and Lees 2003). III.A.2. Surveillance in Canada Canada steadily increased its level of BSE surveillance between 1992 and 2003 (See Figure 1, information provided by CFIA). In calendar year 2003, Canada tested 5,727 cattle. Through 6Analysis of Risk - Update for the Final Rule: Bovine Spongiform Encephalopathy; Minimal Risk Regions and Importation of Commodities: Animal and Plant Health Inspection Service, December 2004 December 1, 2004, a total of more than 15,800 samples had been obtained in 2004 alone, thus exceeding the goal of 8,000. The Canadian surveillance system is ramping up to test 30,000 animals per year in 2005. CFIA officials have stated that this surveillance program is designed to detect one case of BSE in one million adult cattle (CFIA 2004c). http://www.aphis.usda.gov/lpa/issues/bse/risk_assessment/03-080-3_risk_doc.pdf http://www.aphis.usda.gov/lpa/issues/bse/03-080-3_final_rule.pdf Q: What pre-import safeguards does USDA have in place in Canada to ensure that ineligible live animals are not shipped to the United States? A: In order to ensure that only eligible animals are shipped to the United States, USDA has been working very closely with Canadian officials to develop pre-import safeguards. These safeguards include the following: • Each eligible animal must be individually identified by an official Canadian eartag, applied before the animal arrives at the port of entry; • Canadian officials will provide an official health certificate that verifies the following information for each shipment of animals: o Name and address of the importer; o Species, breed, and number of bovine, sheep, or goats to be imported; o Purpose of importation; o Individual identification for each animal, which includes eartag number, and any other identification present on the animal, including registration number (if any); o Description of the bovine, sheep, or goats, including name, age in months, color, and markings (if any); o Region/country of origin; o Address or other means of identifying the premises of origin and any other premises where the bovines, sheep, or goats resided immediately prior to export; o Specific address of slaughter establishment, including FSIS establishment number, for animals going to slaughter; o Physical location of feedlot for animals that are to be moved to a feedlot after importation; o Name and address of exporter; o Port of embarkation in Canada, the mode of transportation, route of travel, and port of entry in the United States; and o Identification numbers of the Canadian seals that have been applied to each vehicle in the shipment. There are additional pre-shipment requirements for shipments of live animals, depending on whether or not the animal is for feeding or for immediate slaughter. Please refer to the importer memos on the APHIS web site www.aphis.usda.gov. http://www.aphis.usda.gov/lpa/issues/bse/CAN-ImportQ&A.pdf Veterinary Services On Jan. 4, 2005, after a careful and thorough science-based risk assessment and a comprehensive rulemaking process, the U.S. Department of Agriculture (USDA) published a final rule amending its regulations to provide for the importation of certain ruminants, ruminant products and byproducts from regions that pose a minimal risk of introducing bovine spongiform encephalopathy (BSE) into the United States. The rule establishes criteria for regions to be recognized as presenting minimal risk of introducing BSE into the United States. This rule ensures the continued protection of the U.S. food and feed supply from BSE, while removing unnecessary prohibitions on the importation of certain commodities from minimal-risk regions. A minimal-risk region could include: By establishing criteria for minimal-risk regions, the United States has taken a leadership role in fostering trade of low-risk products with countries that have a low incidence of BSE and historically strong risk mitigation measures. Such a move is consistent with the World Organization for Animal Health (OIE) recommendations for the trade in animals and animal products from BSE-affected countries. Classification of Canada as Minimal-Risk Region In addition to defining the standards for minimal-risk regions, this rule places Canada in the minimal-risk category and defines the requirements that must be met to allow the import of certain ruminants and ruminant products from Canada. USDA conducted a thorough risk analysis to evaluate the risk of resuming the importation of Canadian ruminants and ruminant products in view of the two BSE cases of Canadian origin. This risk analysis included careful consideration of the risk mitigation measures Canada has in place to detect and prevent BSE within Canadian cattle and also the risk mitigation measures imposed in this final rule. USDA determined that allowing the importation of certain Canadian ruminants and ruminant products under the conditions imposed by the rule will continue to protect against introducing additional cases of BSE into the United States. USDA has determined that Canada meets the requirements for a minimal-risk region. The minimal-risk standards that Canada has met include, among other things: Commodities Eligible for Import from Canada The final rule is effective March 7, 2005. Certain live ruminants and ruminant products and byproducts are eligible for importation from Canada as of that date under specified conditions. The following commodities are allowed to be imported as long as they meet applicable criteria specified in the regulations: USDA is also specifying that there are no import restrictions because of BSE for live cervids or camelids (i.e., llamas, alpacas, guanacos and vicunas) from a BSE-minimal risk region. Additional Requirements for Canadian Imports USDA is confident that the animal and public health measures that Canada has in place to prevent BSE, combined with existing U.S. domestic safeguards and additional safeguards provided in the final rule provide the utmost protections to U.S. consumers and livestock. The final rule provides the following additional requirements for live Canadian feeder cattle designed to ensure they are slaughtered before they reach 30 months of age: The final rule provides the following additional requirements for live Canadian sheep and goats designed to ensure they are slaughtered before they reach 12 months of age: USDA first proposed changes to its regulations regarding establishing minimal-risk regions and conditions for safely importing live ruminants and ruminant products from such regions on November 4, 2003, and the comment period was still under way when the United States announced its first case of BSE on December 23, 2003. To allow additional time for commenters to evaluate the proposal in the context of the first U.S. finding of the disease, USDA reopened the comment period and accepted comments until April 7, 2004. Other countries or regions that meet the minimal-risk conditions will be considered in the future. The designation of any future countries as minimal-risk regions will be accomplished through rulemaking procedures following completion of an appropriate risk assessment. Economic Impact Prior to detection of BSE in Canada in May 2003, the United States and Canada engaged in significant trade in feeder cattle and slaughter cattle. This rule will reestablish mutually beneficial trade in live animals between the two countries. Because the United States has permitted imports from Canada of boneless beef from animals less than 30 months of age since mid-2003, this rule is expected to have little impact on U.S. beef imports. The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, sex, religion, age, disability, political beliefs, sexual orientation, or marital or family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDAís TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326-W, Whitten Building, 1400 Independence Avenue, SW, Washington, DC 20250-9410 or call (202) 720-5964 (voice and TDD). USDA is an equal opportunity provider and employer http://www.aphis.usda.gov/lpa/pubs/fsheet_faq_notice/fs_ahbse_minrisk.html Bush nominates new ag secretary http://www.thecattlemanmagazine.com/newsDesk/news_update_12.04_tscra_Texas_cattle.asp#Bush%20nominates%20new%20ag%20secretary nuff said. IN my opinion the WOAH/OIE is nothing more than a organized bunch of lobbyist for the members Countries in support of there INDUSTRY, bound together as one, with the only purpose of open trade for there precious commodities and futures. Speaking only of BSE, they failed at every corner, and then just said to hell with it, well just trade all strains of TSE globally. ALL IN ALL, it's a terribly failed system of TSE surveillance and attempted erradication of this agent in the USA, a failed policy driven by industry greed and ignorance. ... Terry S. Singeltary Sr.
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