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From: TSS ()
Subject: Bovine Spongiform Encephalopathy and Spatial Analysis of the Feed Industry
Date: June 4, 2007 at 10:48 am PST

Volume 13, Number 6–June 2007
Bovine Spongiform Encephalopathy and Spatial Analysis of the Feed Industry
Mathilde Paul,* David Abrial,* Nathalie Jarrige,† Stéphane Rican,‡ Myriam Garrido,* Didier Calavas,† and Christian Ducrot*
*Institut National de la Recherche Agronomique (INRA), Saint Genès Champanelle, France; †Agence Française de Sécurité Sanitaire des Aliments (AFSSA), Lyon, France; and ‡Université Nanterre Paris X, Paris, France

Suggested citation for this article

In France, despite the ban of meat-and-bone meal (MBM) in cattle feed, bovine spongiform encephalopathy (BSE) was detected in hundreds of cattle born after the ban. To study the role of MBM, animal fat, and dicalcium phosphate on the risk for BSE after the feed ban, we conducted a spatial analysis of the feed industry. We used data from 629 BSE cases as well as data on use of each byproduct and market area of the feed factories. We mapped risk for BSE in 951 areas supplied by the same factories and connection with use of byproducts. A disease map of BSE with covariates was built with the hierarchical Bayesian modeling methods, based on Poisson distribution with spatial smoothing. Only use of MBM was spatially linked to risk for BSE, which highlights cross-contamination as the most probable source of infection after the feed ban.


We used spatial analysis to explore the link between use of 3 byproducts (MBM, animal fat, animal DCP) in factories that produced cattle feed and the relative risk for BSE for animals born after the ban of MBM in cattle feed in France. Among 327 factories, questionnaires were incomplete for 72 (22%) for the use of MBM, 79 (24%) for animal fat, and 107 (33%) for animal DCP. Our hypothesis for missing data about animal DCP was that manufacturers did not know the answer because they often bought premix with preincorporated minerals. Therefore, lack of responses should not be biased and should not affect the analysis. We applied the same hypothesis to absence of information bias for the use of animal fat because this byproduct was allowed in cattle feed and manufacturers would have no reason to hide data. For MBM, the hypothesis of a possible information bias (because MBM was banned from cattle feed) was tested in a sensitivity analysis using a worst-case scenario; this scenario did not change the result, so a possible information bias, if any, should not have modified the results. The huge regional differences in the proportion of factories using MBM, animal fat, and animal DCP might have different explanations, including the local supply, which is linked to local production or import availability, and the differential interest in using each of these compounds for feed for different species whose densities vary in this French territory.

The main result of the spatial analysis provides evidence of a significant adjusted spatial link between factory use of MBM for monogastric species and the relative risk for BSE. This result favors the effect of cross-contamination of cattle feed with MBM-containing feed for monogastric species as a source of BSE for cattle born after the ban of MBM. A recent epidemiologic study in France (23) clearly showed that cattle that consumed feed from factories were at risk for BSE after the feed ban; it also showed that mixed farms were at a higher risk for BSE, which indicates that cross-contamination has possibly occurred on farms (by feeding monogastric-species feed to bovines). These findings are in agreement with our results; both studies complement each other and raise the question of effectiveness of the ban that was initially restricted to bovines and belatedly extended to other species to reduce cross-contamination.

Our study did not implicate animal fat as a source of infection. However, we cannot exclude a minor effect, which would be impossible to prove given the power of the study. Animal fat is considered potentially infectious because of the solubility of prions (24,25) and the possible contamination with protein impurities by contact with other infectious materials at the slaughterhouse. Animal fat is incorporated in cattle feed in milk replacer and in proprietary concentrates. Clauss et al. (5) identified milk replacer as a potential risk factor for BSE in Germany, of importance comparable to proprietary concentrates; the case-control study carried out in France (23) also found an effect of consumption of milk replacer, but to a lesser extent. Regardless, distinguishing the specific effect of milk replacer and proprietary concentrate in these studies was difficult.

Concerning animal DCP, our study showed no effect of its use in compound feed for cattle; however, we did not take into account mineral and vitamin compounds fed to cattle, which can incorporate animal DCP as well. Our results agree with those of the case-control study (23), which did not provide evidence that use of mineral and vitamin compounds affect risk for BSE; the authors considered that the implication of animal DCP as a source of BSE, if it existed, should have been marginal. In contrast, a risk analysis by the European Food Safety Agency (, consulted 7 September 2006) highlighted the potential role of animal DCP in cattle infection, which might be the same order of magnitude as the residual risk from cross-contamination with MBM. Our results do not support this assessment; further studies would be useful.

Our spatial study highlighted the role of MBM as a source of BSE after the ban of MBM for cattle, through cross-contamination in feed factories. If we exclude deliberate use of MBM in feed for cattle (banned since 1990), our findings indicate that feed manufacturers did not implement sufficient measures to avoid cross-contamination during feed processing. Different key points were identified by the French Ministry of Agriculture (B. Thiebot and X. Delomez, pers. comm.) as minimizing risk for cross-contamination. Some can be implemented quickly, such as the sequence of processing, namely, banning the processing of feed for monogastric species just before feed for cattle. However, others are more difficult to implement, such as automatic computation of formula, automatic computation of the sequence of production, and automatic incorporation of unsold products in feed. The ultimate way to eliminate cross-contamination is to have a complete partition between the feed-processing chains dedicated to monogastric species and to ruminants, a huge investment for the feed industry with low profit margins. Given the situation in the field, the results of our study indicate that the total ban of MBM for farm animals in November 2000 was essential for controlling the spread of BSE.

In the current context of the decreasing epidemic, economic pressure is increasing to release the ban of MBM in feed for monogastric species. The prerequisite, from an animal and human health perspective, is 100% efficient control of the risk for cross-contamination at the factory level and elsewhere. Releasing any control measure would need comprehensive cooperation with the feed industry to adapt their production units, which cannot be achieved in the short term.



full text ;

> EU research weighs relaxing BSE-related feed rules

even the late great Dr. Gibbs once told me personally that even if the Chicken did not contract a TSE,
IF the chicken had been fed the TSE tainted feed and then slaughtered, the agent survives the digestinal tract
to pass on to other species through feed...TSS

On page 220 of Rhodes' book, Nobel Price winner Dr. Carleton Gajdusek is quoted saying pigs are routinely slaughtered
before the disease would become evident in them. Carleton Gajdusek is one of the foremost researchers of Kuru and other
"Transmissible Spongiform Encephalopathies", TSE, of which Bovine Spongiform Encephalopathy, Scrapie, CJD, and Kuru
are variants.

In the book, Dr. Gajdusek is quoted: "the disease hasn't turned up in pigs only because you don't keep pigs alive for seven or
eight years; they're killed after two or three years at the most. When we kept pigs we'd inoculated in our laboratory for eight
years, they came down with scrapie. [a TSE variant] Probably all the pigs in England are infected. And that means not only
pork, it means your pigskin wallet. It means catgut surgical suture, because that's made of pig tissue. All the chickens fed on meat-and-bone meal; they're probably infected. You put that stuff in a chicken and it goes right through"... And in America,
beef cattle are killed at or before age two, before they are likely to show outward symptoms. (Page 228)




Un document de 1991 indiqué dans la liste BSE-L par Terry S. Singeltary






What Do We Feed to Food-Production Animals? A Review of Animal Feed
Ingredients and Their Potential Impacts on Human Health

Amy R. Sapkota,1,2 Lisa Y. Lefferts,1,3 Shawn McKenzie,1 and Polly Walker1
1Johns Hopkins Center for a Livable Future, Bloomberg School of Public
Health, Baltimore, Maryland, USA; 2Maryland Institute for
Applied Environmental Health, College of Health and Human Performance,
University of Maryland, College Park, Maryland, USA;
3Lisa Y. Lefferts Consulting, Nellysford, Virginia, USA

OBJECTIVE: Animal feeding practices in the United States have changed
considerably over the past
century. As large-scale, concentrated production methods have become the
predominant model for
animal husbandry, animal feeds have been modified to include ingredients
ranging from rendered
animals and animal waste to antibiotics and organoarsenicals. In this
article we review current U.S.
animal feeding practices and etiologic agents that have been detected in
animal feed. Evidence that
current feeding practices may lead to adverse human health impacts is also

DATA SOURCES: We reviewed published veterinary and human-health literature
regarding animal
feeding practices, etiologic agents present in feed, and human health
effects along with proceedings
from animal feed workshops.

DATA EXTRACTION: Data were extracted from peer-reviewed articles and books
identified using
PubMed, Agricola, U.S. Department of Agriculture, Food and Drug
Administration, and Centers
for Disease Control and Prevention databases.

DATA SYNTHESIS: Findings emphasize that current animal feeding practices can
result in the presence
of bacteria, antibiotic-resistant bacteria, prions, arsenicals, and dioxins
in feed and animal-based food
products. Despite a range of potential human health impacts that could
ensue, there are significant
data gaps that prevent comprehensive assessments of human health risks
associated with animal feed.
Limited data are collected at the federal or state level concerning the
amounts of specific ingredients
used in animal feed, and there are insufficient surveillance systems to
monitor etiologic agents “from
farm to fork.”

CONCLUSIONS: Increased funding for integrated veterinary and human health
surveillance systems
and increased collaboration among feed professionals, animal producers, and
veterinary and public
health officials is necessary to effectively address these issues.

KEY WORDS: animal feed, animal waste, concentrated animal feeding
operations, fats, human health
effects, nontherapeutic antibiotics, rendered animals, roxarsone, zoonoses.
Environ Health Perspect
115:663–670 (2007). doi:10.1289/ehp.9760 available via
[Online 8 February 2007]


U.S. Animal Feed Production
The U.S. animal feed industry is the largest
producer of animal feed in the world (Gill
2004). In 2004, over 120 million tons of primary
animal feed, including mixes of feed
grains, mill by-products, animal proteins, and
microingredient formulations (i.e., vitamins,
minerals, and antibiotics) were produced in
the United States (Gill 2004). In the same
year, the United States exported nearly
$4 billion worth of animal feed ingredients
(International Trade Centre 2004).


Rendered animal products. In 2003, the
U.S. rendering industry produced > 8 million
metric tons of rendered animal products,
including meat and bone meal, poultry byproduct
meal, blood meal, and feather meal
(National Renderers Association Inc. 2005b).
Most of these products were incorporated into
animal feed. However, data concerning the
specific amounts of rendered animal protein
that are used in animal feed are difficult to
obtain because the information is neither routinely
collected at the federal or state level nor
reported by the rendering industry. The latest
available data, collected by the USDA in 1984,
estimated that > 4 million metric tons of rendered
animal products were used as animal
feed ingredients (USDA 1988). Oftentimes
these ingredients are listed on animal feed
labels as “animal protein products.” Thus, it is
difficult to discern precisely which animal protein
products are included in a particular animal
feed product (Lefferts et al. 2006).
Animal waste. Another major animal
protein–based feed ingredient is animal
waste, including dried ruminant waste, dried
poultry litter, and dried swine waste (AAFCO
2004; Haapapuro et al. 1997). As with rendered
animal products, there are no national
data on the total amounts of animal waste
included in animal feeds, although some
states have collected limited data concerning
this practice. In 2003, it was estimated that
approximately 1 million tons of poultry litter
were produced annually in Florida, and an
estimated 350,000 tons of this litter were
available for use in feed (Dubberly 2003).
Yet, information concerning the precise
amount of this “available” poultry litter that
was actually incorporated into Florida animal
feed was unavailable.
Recycling animal waste into animal feed
has been practiced for > 40 years as a means of
cutting feed costs. However, the U.S. Food
and Drug Administration (FDA) does not offi-
cially endorse the use of animal waste in feed
and has issued statements voicing the agency’s
concern about the presence of pathogens and
drug residues in animal waste, particularly
poultry litter (FDA 1998). In line with these
concerns, the AAFCO, an organization that
develops guidelines for the safe use of animal
feeds, advises that processed animal waste
should not contain pathogenic microorganisms,
pesticide residues, or drug residues that could
harm animals or eventually be detected in animal-
based food products intended for human
consumption (AAFCO 2004). Nonetheless,
these guidelines are not adequately enforced at
the federal or state level.


Table 1. Animal feed ingredients that are legally used in U.S. animal feeds.
Origin, raw material Examples
Forage Alfalfa meal and hay, Bermuda coastal grass hay, corn plant, and
soybean hay
Grains Barley, corn (organic and genetically modified), oats, rice, sorghum,
and wheat
Plant protein products Canola meal, cottonseed cakes and meals, peanut meal,
safflower meal, and
soybean (organic and genetically modified) feed and meal
Processed grain by-products Distillers products, brewers dried grains, corn
gluten, sorghum germ cake and
meal, peanut skins, and wheat bran
Fruit and fruit by-products Dried citrus pulp, apple pomace, and pectin pulp
Molasses Beet, citrus, starch, and cane molasses
Miscellaneous Almond hulls and ground shells, buckwheat hulls, legumes and
by-products, and other crop by-products
Rendered animal protein from Meat meal, meat meal tankage, meat and bone
meal, poultry meal, animal
the slaughter of food by-product meal, dried animal blood, blood meal,
feather meal, egg-shell
production animals and other meal, hydrolyzed whole poultry, hydrolyzed
hair, bone marrow, and animal
animals digest from dead, dying, diseased, or disabled animals including
deer and elk
Animal waste Dried ruminant waste, dried swine waste, dried poultry litter,
and undried
processed animal waste products
Marine by-products Fish meal, fish residue meal, crab meal, shrimp meal,
fish oil, fish liver and
glandular meal, and fish by-products
Dairy products Dried cow milk, casein, whey products, and dried cheese
Fats and oils Animal fat, vegetable fat or oil, and hydrolyzed fats
Restaurant food waste Edible food waste from restaurants, bakeries, and
Contaminated/adulterated food Food adulterated with rodent, roach, or bird
excreta that has been heat
treated to destroy pathogenic organisms
Antibiotics Tetracyclines, macrolides, fluoroquinolones, and streptogramins
By-products of drug manufacture Spent mycelium and fermentation products
Arsenicals Roxarsone and arsanilic acid
Other metal compounds Copper compounds and metal amino acid complexes
Nonprotein nitrogen Urea, ammonium chloride, and ammonium sulfate
Minerals Bone charcoal, calcium carbonate, chalk rock, iron salts, magnesium
salts, and
oyster shell flour
Vitamins Vitamins A, D, B12, E, niacin, and betaine
Direct-fed organisms Aspergillis niger, Bacillus subtilis, Bifidobacterium
animalis, Enterococcus
faecium, and yeast
Flavors Aloe vera gel concentrate, ginger, capsicum, and fennel
Enzymes Phytase, cellulase, lactase, lipase, pepsin, and catalase
Additives generally regarded Acetic acid, sulfuric acid, aluminum salts,
dextrans, glycerin, beeswax, sorbitol,
as safe (GRAS) and riboflavin
Preservatives Butylated hydroxyanisole (BHA) and sodium bisulfite
Nutraceuticals Herbal and botanical products
Plastics Polyethylene roughage replacement
aData adapted from AAFCO (2004).


Antibiotics. The use of antibiotics in animal
feed is also a public health concern.
Antibiotics are administered at nontherapeutic
levels in feed and water to promote growth
and improve feed efficiency. This practice has
been shown to select for antibiotic resistance
in both commensal and pathogenic bacteria in
a) the animals themselves (Aarestrup et al.
2000; Bager et al. 1997; Gorbach 2001;
Wegener 2003); b) subsequent animal-based
food products (Hayes et al. 2003; White et al.
2001); and c) water, air, and soil samples collected
around large-scale animal feeding operations
(Chapin et al. 2005; Chee-Sanford et al.
2001; Gibbs et al. 2006; Jensen et al. 2002).
Although the use of nontherapeutic levels
of antibiotics in animal feed is approved and
regulated by the FDA (2004), there is no U.S.
data collection system regarding the specific
types and amounts of antibiotics that are used
for this purpose. In response to this significant
data gap, several estimates of nontherapeutic
antibiotic usage have been published based on
USDA livestock production data and FDA
antibiotic usage regulations. For example,
Mellon et al. (2001) estimated that as much as
60–80% of antibiotics produced in the United
States are administered in feed to healthy livestock
at nontherapeutic levels. Many of these
antibiotics are the same compounds that are
administered to humans in clinical settings,
and include tetracyclines, macrolides, streptogramins,
and fluoroquinolones (FDA 2004).
Additional information regarding the types
and amounts of antibiotics used in U.S. livestock
is available in AAFCO (2004), FDA
(2004), and Mellon et al. (2001).
Metals. Metal compounds are also administered
in animal feeds, and the compounds currently
added to both swine and poultry feeds
that are particularly concerning from a public
health perspective are organoarsenicals. The
most commonly used organoarsenical, roxarsone
is administered to feeds at concentrations ranging
from 22.7 g/ton to 45.4 g/ton to promote
growth and improve feed efficiency (Chapman
and Johnson 2002). When used in combination
with ionophores, roxarsone also act as a cococcidiostat
to control intestinal parasites
(Chapman and Johnson 2002). Once roxarsone
is ingested by animals, the parent compound
can be degraded into inorganic arsenite
(AsIII) and inorganic arsenate (AsV) in animal
digestive tracts and animal waste (Arai et al.
2003; Stolz et al. 2007). Both AsIII and AsV are
classified by the U.S. Environmental Protection
Agency (U.S. EPA) as group A human carcinogens
(U.S. EPA 1998). Many other metallic
compounds are also mixed into feeds, including
copper, manganese, magnesium, and zinc compounds,
as well as metal amino acid complexes
(AAFCO 2004).


Table 2. Biological, chemical, and other etiologic agents detected in animal
feed and their potential human health impacts.
Etiologic agent Examples Potential human health impacts References
Bacteria Salmonellaspp., E. coliO157:H7 Bacterial infections a Angulo 2004;
Crump et al. 2002; Davis et al. 2003
Antibiotic-resistant E. faecium, E. coli, C. jejuni Antibiotic-resistant
bacterial infections a Aarestrup et al. 2000; Dargatz et al. 2005;
bacteria b Schwalbe et al. 1999; Sorensen et al. 2001
Prions Causative agent of BSE vCJD c Gizzi et al. 2003; Smith 2003
Arsenicals Roxarsone, AsIII, AsV Increased human exposures to inorganic
arsenic that may Chapman and Johnson 2002; Lasky et al. 2004
contribute to increases in cancer risk a
Mycotoxins Aflatoxins, ochratoxins, fumonisins, Increased human exposures to
mycotoxins that may Bhat and Vasanthi 1999; Hussein and Brasel
trichothecenes contribute to increases in cancer and noncancer risks a 2001
Dioxins and dioxin-like PCDDs, PCDFs, PCBs Increased human exposures to
dioxin-like compounds that Eljarrat et al. 2002; Fries 1995; Huwe and
compounds may contribute to increases in cancer and noncancer risks a Larsen
vCJD, variant Creutzfeldt-Jakob disease.
aInsufficient data are available to fully understand the magnitude of
potential human health impacts associated with contaminated animal feed.
bIncludes antibiotic-resistant bacteria
initially present in animal feed due to contaminated feed ingredients, and
antibiotic-resistant bacteria resulting from the nontherapeutic use of
antibiotics in feed. cDomestically
acquired human cases of vCJD have not been documented in the United States.


In another study, 165 rendered animal
protein products originating from poultry, cattle,
and fish were sampled from a poultry feed
mill and tested for antibiotic-resistant bacteria
(Hofacre et al. 2001). Eighty-five percent of all
feed ingredients sampled contained bacteria
resistant to one or more of the following four
antibiotics: ampicillin, amoxicillin, clavulanic
acid, and cephalothin. Poultry meal and bone
and meat meal (nonpoultry) samples represented
the greatest number of feed ingredient
samples containing bacteria resistant to five or
more antibiotics (Hofacre et al. 2001).

Prions. In addition to bacteria, animal
feeds (in particular, cattle feeds) can be contaminated
with the infectious agent associated
with BSE (Gizzi et al. 2003). BSE, which is
commonly referred to as mad cow disease,
belongs to a group of progressively degenerative
neurologic diseases called transmissible
spongiform encephalopathies (TSEs) (Deslys
and Grassi 2005; Smith 2003). The causative
agent of TSEs is believed to be an infectious
proteinaceous entity called a prion, which is
composed largely of a protease-resistant misfolded
protein (PrPSc). Infectious prions can be
present in animal feed as a result of using rendered
animal products from diseased animals
as feed ingredients. Although prions may be
present in all body tissues of diseased animals,
it is generally acknowledged that prions accumulate
in highest concentrations in central
nervous system tissues (GAO 2002; Smith
2003) that are referred to as specified risk
materials (SRMs). As defined by the USDA
Food Safety Inspection Service (USDA
2005b), SRMs include the skull, brain, eyes,
parts of the vertebral column, spinal cord,
trigeminal ganglia, and dorsal root ganglia of
cattle > 30 months of age, as well as the tonsils
and distal ileum of all cattle. In 1997, the FDA
banned SRMs from use in cattle and other
ruminant feed (GAO 2002). Nonetheless,
SRMs were allowed to be incorporated into
feeds for nonruminants (including poultry),
and subsequent waste products from nonruminants
are still permitted in ruminant feeds
(USDA 2005b).
As of yet, there are no definitive tests for
BSE infectivity in live animals (before symptoms
appear) (Deslys and Grassi 2005; GAO
2002). However, a number of rapid screening
tests based on ELISA or Western blot analyses
have been approved for post-mortem BSE
testing in cattle. Currently, the USDA is conducting
a national BSE testing program; yet,
only high-risk cattle are included in the program
and there are no plans to test animal
feed samples (that could include animal protein
from asymptomatic rendered animals) in
this surveillance effort (USDA 2004). A variety
of tests do exist for the detection of animal
tissues (in general) in animal feed, including
microscopic analyses, polymerase chain reaction,
immunoassay analyses, and near infrared
spectroscopy (Gizzi et al. 2003); nonetheless,
these methods are not robust enough to distinguish
between bovine products that are permitted
in ruminant feeds (i.e., milk and
blood) and bovine products that are prohibited
from ruminant feeds (GAO 2002;
Momcilovic and Rasooly 2000).


Variant Creutzfeldt-Jakob disease.
Beyond bacterial infections, a chronic human
health risk that has been linked to animal
feeding practices is variant Creutzfeldt-Jakob
disease (vCJD), a novel human neurodegenerative
prion disease that is currently
untreatable and fatal (Collinge 1999). vCJD
was first described in 1995 in two teenagers in
the United Kingdom and was believed to be
caused by infection with the causative agent
of BSE or mad cow disease (Smith 2003).
Molecular strain-typing studies and experimental
transmission studies in mice published
in 1996 and 1997 confirmed that vCJD is
caused by the same prion strain that causes
BSE (Collinge 1999).
The primary routes of human exposure to
prions remain debatable; however, the most
likely route is through the ingestion of beef
derived from cattle that were infected when
rendered animal proteins from diseased cattle
were included in their feed. It is hypothesized
that the UK population may have experienced
the highest exposures to BSE from
1989 to 1990, when the incidence of BSE
was still increasing in cattle and specific bans
on high-risk rendered bovine products were
still being implemented (Collinge 1999).
From 1995 to 2002, there were 121 fatalities
out of 129 diagnosed cases in the United
Kingdom (Smith 2003). To date, domestically-
acquired human cases of vCJD have not
been identified in the United States.
However, since BSE was first identified in the
United States in 2003, the Centers for
Disease Control and Prevention (CDC) have
enhanced national surveillance for all types of
CJD in the United States through the analysis
of multiple cause-of-death data derived from
death certificates (CDC 2005). Active CJD
surveillance is also being implemented
through the Emerging Infections Programs
established in four sites across the United
States (CDC 2005).


Food-animal production in the United States
has changed markedly in the past century,
and these changes have paralleled major
changes in animal feed formulations. While
this industrialized system of food-animal production
may result in increased production
efficiencies, some of the changes in animal
feeding practices may result in unintended
adverse health consequences for consumers of
animal-based food products.
Currently, the use of animal feed ingredients,
including rendered animal products, animal
waste, antibiotics, metals, and fats, could
result in higher levels of bacteria, antibioticresistant
bacteria, prions, arsenic, and dioxinlike
compounds in animals and resulting
animal-based food products intended for
human consumption. Subsequent human
health effects among consumers could include
increases in bacterial infections (antibioticresistant
and nonresistant) and increases in the
risk of developing chronic (often fatal) diseases
such as vCJD.
Nevertheless, in spite of the wide range of
potential human health impacts that could
result from animal feeding practices, there are
little data collected at the federal or state level
concerning the amounts of specific ingredients
that are intentionally included in U.S.
animal feed. In addition, almost no biological
or chemical testing is conducted on complete
U.S. animal feeds; insufficient testing is performed
on retail meat products; and human
health effects data are not appropriately
linked to this information. These surveillance
inadequacies make it difficult to conduct rigorous
epidemiologic studies and risk assessments
that could identify the extent to which
specific human health risks are ultimately
associated with animal feeding practices. For
example, as noted above, there are insufficient
data to determine whether other human foodborne
bacterial illnesses besides those caused
by S. enterica serotype Agona are associated
with animal feeding practices. Likewise, there
are insufficient data to determine the percentage
of antibiotic-resistant human bacterial
infections that are attributed to the nontherapeutic
use of antibiotics in animal feed.
Moreover, little research has been conducted
to determine whether the use of organoarsenicals
in animal feed, which can lead to
elevated levels of arsenic in meat products
(Lasky et al. 2004), contributes to increases in
cancer risk.
In order to address these research gaps,
the following principal actions are necessary
within the United States: a) implementation
of a nationwide reporting system of the specific
amounts and types of feed ingredients of
concern to public health that are incorporated
into animal feed, including antibiotics, arsenicals,
rendered animal products, fats, and animal
waste; b) funding and development of
robust surveillance systems that monitor biological,
chemical, and other etiologic agents
throughout the animal-based food-production
chain “from farm to fork” to human
health outcomes; and c) increased communication
and collaboration among feed professionals,
food-animal producers, and veterinary
and public health officials.


Sapkota et al.
668 VOLUME 115 | NUMBER 5 | May 2007 • Environmental Health Perspectives



To minimise the risk of farmers' claims for compensation from feed

To minimise the potential damage to compound feed markets through adverse publicity.

To maximise freedom of action for feed compounders, notably by
maintaining the availability of meat and bone meal as a raw
material in animal feeds, and ensuring time is available to make any
changes which may be required.




MAFF remains under pressure in Brussels and is not skilled at
handling potentially explosive issues.

5. Tests _may_ show that ruminant feeds have been sold which
contain illegal traces of ruminant protein. More likely, a few positive
test results will turn up but proof that a particular feed mill knowingly
supplied it to a particular farm will be difficult if not impossible.

6. The threat remains real and it will be some years before feed
compounders are free of it. The longer we can avoid any direct
linkage between feed milling _practices_ and actual BSE cases,
the more likely it is that serious damage can be avoided. ...

SEE full text ;

CVM Update
May 18, 2007

May 2007 Update on Feed Enforcement Activities to Limit the Spread of BSE

To help prevent the establishment and amplification of Bovine Spongiform
Encephalopathy (BSE) through feed in the United States, the Food and Drug
Administration (FDA) implemented a final rule that prohibits the use of most
mammalian protein in feeds for ruminant animals. This rule, Title 21 Part
589.2000 of the Code of Federal Regulations, here called the Ruminant Feed
Ban, became effective on August 4, 1997.

The following is an update on FDA enforcement activities regarding the
ruminant feed ban. FDA's Center for Veterinary Medicine (CVM) has assembled
data from the inspections that have been conducted AND whose final
inspection report has been recorded in the FDA's inspection database as of
May 12, 2007. As of May 12, 2007, FDA had received over 53,000 inspection
reports. The majority of these inspections (around 68%) were conducted by
State feed safety officials, with the remainder conducted by FDA officials.
Inspections conducted by FDA or State investigators are classified to
reflect the compliance status at the time of the inspection based upon the
objectionable conditions documented. These inspection conclusions are
reported as Official Action Indicated (OAI), Voluntary Action Indicated
(VAI), or No Action Indicated (NAI).

An OAI inspection classification occurs when significant objectionable
conditions or practices were found and regulatory sanctions are warranted in
order to address the establishment's lack of compliance with the regulation.
An example of an OAI inspection classification would be findings of
manufacturing procedures insufficient to ensure that ruminant feed is not
contaminated with prohibited material. Inspections classified with OAI
violations will be promptly re-inspected following the regulatory sanctions
to determine whether adequate corrective actions have been implemented.

A VAI inspection classification occurs when objectionable conditions or
practices were found that do not meet the threshold of regulatory
significance, but do warrant advisory actions to inform the establishment of
findings that should be voluntarily corrected. Inspections classified with
VAI violations are more technical violations of the Ruminant Feed Ban. These
include provisions such as minor recordkeeping lapses and conditions
involving non-ruminant feeds.

An NAI inspection classification occurs when no objectionable conditions or
practices were found during the inspection or the significance of the
documented objectionable conditions found does not justify further actions.

The results to date are reported here both by “segment of industry” and “in
total”. NOTE – A single firm can operate as more than one firm type. As a
result, the categories of the different industry segments are not mutually


These firms are the first to handle and process (i.e., render) animal
proteins and to send these processed materials to feed mills and/or protein
blenders for use as a feed ingredient.

Number of active firms whose initial inspection has been reported to FDA –

Number of active firms handling materials prohibited from use in ruminant
feed – 161 (60 % of those active firms inspected)

Of the 161 active firms handling prohibited materials, their most recent
inspection revealed that:

0 firms (0.0 %) were classified as OAI

4 firms (2.5 %) were classified as VAI


FDA licenses these feed mills to produce medicated feed products. The
license is required to manufacture and distribute feed using certain potent
drug products, usually those requiring some pre-slaughter withdrawal time.
This licensing has nothing to do with handling prohibited materials under
the feed ban regulation. A medicated feed license from FDA is not required
to handle materials prohibited under the Ruminant Feed Ban.

Number of active firms whose initial inspection has been reported to FDA –

Number of active firms handling materials prohibited from use in ruminant
feed – 444 (41 % of those active firms inspected)

Of the 444 active firms handling prohibited materials, their most recent
inspection revealed that:

0 firms (0.0 %) were classified as OAI

5 firms (1.1 %) were classified as VAI


These feed mills are not licensed by the FDA to produce medicated feeds.

Number of active firms whose initial inspection has been reported to FDA –

Number of active firms handling materials prohibited from use in ruminant
feed – 2,391 (46 % of those active firms inspected)

Of the 2,391 active firms handling prohibited materials, their most recent
inspection revealed that:

3 firms (0.1 %) were classified as OAI

56 firms (2.3 %) were classified as VAI


These firms blend rendered animal protein for the purpose of producing
quality feed ingredients that will be used by feed mills.

Number of active firms whose initial inspection has been reported to FDA –

Number of active firms handling materials prohibited from use in ruminant
feed – 183 (47% of those active firms inspected)

Of the 183 active firms handling prohibited materials, their most recent
inspection revealed that:

1 firm (0.5 %) was classified as OAI

7 firms (3.8 %) were classified as VAI


This category includes only those firms that actually use prohibited
material to manufacture, process, or blend animal feed or feed ingredients.

Total number of active renderers, feed mills, and protein blenders whose
initial inspection has been reported to FDA – 6,604

Number of active renderers, feed mills, and protein blenders processing with
prohibited materials – 497 (7.5 %)

Of the 497 active renderers, feed mills, and protein blenders processing
with prohibited materials, their most recent inspection revealed that:

2 firms (0.4 %) were classified as OAI

24 firms (4.8 %) were classified as VAI


Examples of such firms include ruminant feeders, on-farm mixers, pet food
manufacturers, animal feed salvagers, distributors, retailers, and animal
feed transporters.

Number of active firms whose initial inspection has been reported to FDA –

Number of active firms handling materials prohibited from use in ruminant
feed – 5,415 (31% of those active firms inspected)

Of the 5,415 active firms handling prohibited materials, their most recent
inspection revealed that:

2 firms (0.04 %) were classified as OAI

186 firms (3.4%) were classified as VAI


Note that a single firm can be reported under more than one firm category;
therefore, the summation of the individual OAI/VAI firm categories will be
more than the actual total number of OAI/VAI firms, as presented below.

Number of active firms whose initial inspection has been reported to FDA –

Number of active firms handling materials prohibited from use in ruminant
feed – 6,146 (31 % of those active firms inspected)

Of the 6,146 active firms handling prohibited materials, their most recent
inspection revealed that:

3 firms (0.05 %) were classified as OAI

200 firms (3.3 %) were classified as VAI


Issued by:
FDA, Center for Veterinary Medicine,
Communications Staff, HFV-12
7519 Standish Place, Rockville, MD 20855
Telephone: (240) 276-9300 FAX: (240) 276-9115
Internet Web Site:


Date: March 21, 2007 at 2:27 pm PST
Bulk cattle feed made with recalled Darling’s 85% Blood Meal, Flash Dried,
Recall # V-024-2007
Cattle feed delivered between 01/12/2007 and 01/26/2007
Pfeiffer, Arno, Inc, Greenbush, WI. by conversation on February 5, 2007.
Firm initiated recall is ongoing.
Blood meal used to make cattle feed was recalled because it was
cross-contaminated with prohibited bovine meat and bone meal that had been
manufactured on common equipment and labeling did not bear cautionary BSE
42,090 lbs.

Custom dairy premix products: MNM ALL PURPOSE Pellet, HILLSIDE/CDL
Prot-Buffer Meal, LEE, M.-CLOSE UP PX Pellet, HIGH DESERT/ GHC LACT Meal,
A-BYPASS ML W/SMARTA, Recall # V-025-2007
The firm does not utilize a code - only shipping documentation with
commodity and weights identified.
Rangen, Inc, Buhl, ID, by letters on February 13 and 14, 2007. Firm
initiated recall is complete.
Products manufactured from bulk feed containing blood meal that was cross
contaminated with prohibited meat and bone meal and the labeling did not
bear cautionary BSE statement.
9,997,976 lbs.
ID and NV


> May 2007 Update on Feed Enforcement Activities to Limit the Spread of BSE

what about BASE ???


18 January 2007 - Draft minutes of the SEAC 95 meeting (426 KB) held on 7
December 2006 are now available.


64. A member noted that at the recent Neuroprion meeting, a study was
presented showing that in transgenic mice BSE passaged in sheep may be more
virulent and infectious to a wider range of species than bovine derived BSE.

Other work presented suggested that BSE and bovine amyloidotic spongiform
encephalopathy (BASE) MAY BE RELATED. A mutation had been identified in the


3:30 Transmission of the Italian Atypical BSE (BASE) in Humanized Mouse

Models Qingzhong Kong, Ph.D., Assistant Professor, Pathology, Case Western

Bovine Amyloid Spongiform Encephalopathy (BASE) is an atypical BSE strain
discovered recently in Italy, and similar or different atypical BSE cases
were also reported in other countries. The infectivity and phenotypes of
these atypical BSE strains in humans are unknown. In collaboration with
Pierluigi Gambetti, as well as Maria Caramelli and her co-workers, we have
inoculated transgenic mice expressing human prion protein with brain
homogenates from BASE or BSE infected cattle. Our data shows that about half
of the BASE-inoculated mice became infected with an average incubation time
of about 19 months; in contrast, none of the BSE-inoculated mice appear to
be infected after more than 2 years.

***These results indicate that BASE is transmissible to humans and suggest
that BASE is more virulent than
classical BSE in humans.***

6:30 Close of Day One

1997 TO 2006. SPORADIC CJD CASES TRIPLED, with phenotype
of 'UNKNOWN' strain growing. ...

There is a growing number of human CJD cases, and they were presented last
week in San Francisco by Luigi Gambatti(?) from his CJD surveillance

He estimates that it may be up to 14 or 15 persons which display selectively
SPRPSC and practically no detected RPRPSC proteins.

Subject: OIE BSE RECOMMENDATION FOR USA, bought and paid for by your local
cattle dealers i.e. USDA
Date: May 14, 2007 at 9:00 am PST


(Adopted by the International Committee of the OIE on 23 May 2006)

11. Information published by the OIE is derived from appropriate
declarations made by the official Veterinary Services of Member Countries.
The OIE is not responsible for inaccurate publication of country disease
status based on
inaccurate information or changes in epidemiological status or other
significant events that were not
promptly reported to then Central Bureau............

Terry S. Singeltary Sr.
P.O. Box 42
Bacliff, Texas USA 77518

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