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From: TSS ()
Subject: Renderers say industry not prepared for FDA feed ban rule
Date: February 22, 2009 at 1:22 pm PST

-------------------- BSE-L@LISTS.AEGEE.ORG --------------------


Two recent articles caught my eye ;

Renderers say industry not prepared for FDA feed ban rule

Food Chemical News

February 2, 2009

and

BSE, rendering relate to human safety

Emma Struve 02/17/2009

To enhance protection of the human food supply, the Food and Drug Administration (FDA) will institute a new rule April 27, 2009. This rule prohibits brain and spinal corn material from cattle over 30 months of age from entering the animal food supply.

Ultimately, the goal is to further decrease the likelihood that cattle may become infected with Bovine Spongiform Encephalopathy (BSE) thereby reducing the risk that infected animals will enter the human food chain.

An additional consequence stemming from implementation of the rule is that livestock producers will have a more difficult time disposing of carcasses.

Crawford County Supervisor John Lawler said of the disposal issue, "We've got a problem here, we all know about this, with these cattle."

At this point policy makers and livestock producers are examining available information to formulate a plan for how to adopt changes necessary to comply with the rule.

What is Bovine Spongiform

Encephalopathy (BSE)?

BSE is an infectious disease of cattle that causes physical deterioration of the brain and spinal tissues resulting in a "wasting" appearance of the animal, according to the USDA Animal and Plant Health Inspection Service (APHIS) overview of BSE.

Through research, scientists have found that the most common manner of infection is when a healthy animal consumes feed that contains protein rendered from an infected ruminant animal.

A BSE related human prion disease called variant Creutzfeldt-Jakob disease (vCJD) became scientifically known in 1996. Those afflicted with vCJD are assumed to have acquired the disease by consuming food containing protein from BSE infected cattle.

Some current regulations concerning BSE materials in the United States

In 1997 the FDA prohibited the use of mammalian protein in feeds given to ruminants (cattle, sheep, and goats).

The Food and Drug Administration (FDA) along with the Food Safety and Inspection Service (FSIS) instituted rules that removed from the human food supply risk materials where prions (infective proteins) might be found.

Since 1990 APHIS has conducted BSE surveillance and about 800,000 animals in the United States have been tested since the program started. Three cases of BSE have been identified.

What is the new regulation?

On April 25, 2008 the FDA published a rule to prohibit the use of some materials of cattle origin in animal food. The rule will take effect April 27, 2009 and can be found in its entirety at

www.fda.gov/OHRMS/DOCKETS/98fr/08-1180.htm.

Who is affected by the new regulation?

Companies that render deceased cattle over 30 months of age will be required to modify their procedures in order to assure and prove the brain and spinal cord material of these animals did not enter the final product, typically meat and bone meal.

David Kirstein, representative for Darling International, a rendering company that serves Iowa livestock producers, stated that the company is not yet sure how to handle the issue.

"Darling has a lot of facilities across the United States...different plants with different capabilities," Kirstein continued.

Simply removing the material after collecting the whole animal is "not an easy task" for renderers. Customers of Darling can expect to be contacted in writing with changes planned for the very near future.

Livestock producers, especially those with beef producing cow herds or dairies, may have to find an alternative carcass disposal method if renderers cannot handle the banned materials.

Are there viable alternative methods of disposal?

Dr. David Schmitt, Iowa Department of Agriculture (IDA) and Land Stewardship State Veterinarian suggested four alternative carcass disposal methods: incineration, burial, landfill, and composting.

"Biosecurity is very important," Schmitt insisted. He stressed the need for proper disposal and people to be responsible.

What are the applicable local regulations regarding disposal?

Incineration, Schmitt said, can only be done by approved enclosed facilities. Open burning is prohibited.

Burial sites for livestock carcasses must be located specified distances from water sources and, in well drained soil, no deeper than six feet with at least 30 inches of cover, and with a maximum density of seven carcasses per acre. A full listing of rules is provided by the DNR at

www.iowadnr.gov/afo/disposal.html.

The rules for burials were designed to protect public and private water sources from the potentially harmful materials released during decomposition, explained Schmitt.

To accept carcasses is at the discretion of each individual landfill. Marry Wittry, director of the Carroll County Solid Waste Management Commission, said that the Carroll landfill board of directors that makes the final policy determinations has not "taken a position on whether or not they will accept cows."

Dr. Thomas Glanville, Iowa State University professor in the Department of Agricultural and Biosystems Engineering, conducted a three-year composting study and found that carcasses, except large bones, were decomposed in less than a year. An in-depth discussion of Glanville's research is available at www3.abe.iastate.edu/cattlecomposting/index.asp.

There is no permit required to compost livestock on the farm that owned them, although a solid waste disposal permit is required, and may be obtained through the DNR, to start a communal compost pile or business.

Additional assistance is available from local USDA's Natural Resources Conservation Service (NRCS) offices in planning to construct an animal mortality composting facility and determining its suitable site and size. Financial assistance may also be available through the Environmental Quality Incentives Program (EQIP).

http://www.dbrnews.com/site/news.cfm?newsid=20263994&BRD=2703&PAG=461&dept_id=555123&rfi=6

BOO-HOO-HOO pity them $$$ all they way too the bank.

they have flouted TSE regulations for too long.

Déjà-vu, the renderers have been fighting BSE/TSE regulations from day one $$$

http://www.google.com/search?hl=en&q=renderers+say+industry+not+prepared+for+fda+feed+ban+rule&btnG=Search

Renderers say industry not prepared for FDA feed ban rule ???

you got to be kidding me ???

i am reminded of this ;

STRICTLY PRIVATE AND CONFIDENTIAL 25, AUGUST 1995

snip...

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

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.

snip...

THE FUTURE

4..........

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 ;

http://www.bseinquiry.gov.uk/files/yb/1995/08/24002001.pdf

THIS is what happens when you have the industry run the government. ...

seems the 'homegrown BSE' might just turn out to be a more infections BSE/TSE i.e. atypical h-BSE, they don't tell you that though do they ???

Atypical BSE North America Update February 2009

Greetings,

Considering that Mad Cow disease of all documented phenotypes, either the c-BSE, or the atypical h-BSE and or the l-BSE, ALL of which have been documented in North America, how many more, who knows, but they seem to be throwing all there marbles in the pot now by calling the h-type BSE 'familial'. what happens if we come up with another strain ? kinda like the sporadic FFI, that's not familial, what's that all about ? considering the many different strains of the typical scrapie 20+, and then the atypical Nor-98 Scrapie, which the USA has documented 6 cases the last i heard, and the thought of more than one strain of CWD in deer and elk, where will the next year, 4 years, 8 years, and beyond take us in the world of human and animal Transmissible Spongiform Encephalopathy and 'sound science' in the USA ? WILL the New Administration see the enfamous enhanced bse surveillance program of 2004 for what it was, a fraud, and have a 'redo' ? WE can hope i suppose. ...TSS

Both of the BSE cases ascertained in the US native-born cattle were atypical cases (H-type), which contributed to the initial ambiguity of the diagnosis. 174, 185 In Canada, there have been 2 atypical BSE cases in addition to the 14 cases of the classic UK strain of BSE2: one was the H-type, and the other was of the L-type.198

snip...end

source :

Enhanced Abstract Journal of the American Veterinary Medical Association January 1, 2009, Vol. 234, No. 1, Pages 59-72

Bovine spongiform encephalopathy

Jane L. Harman, DVM, PhD; Christopher J. Silva, PhD

http://avmajournals.avma.org/doi/ref/10.2460/javma.234.1.59

Thursday, December 04, 2008 2:37 PM

"we have found that H-BSE can infect humans."

personal communication with Professor Kong. ...TSS

Wednesday, February 11, 2009 Atypical BSE North America Update February 2009

http://bse-atypical.blogspot.com/2009/02/atypical-bse-north-america-update.html

see history ;

SCHOOL LUNCH PROGRAM FROM DOWNER CATTLE UPDATE

http://downercattle.blogspot.com/

Sunday, November 16, 2008 Resistance of Bovine Spongiform Encephalopathy (BSE) Prions to Inactivation

http://bse-atypical.blogspot.com/2008/11/resistance-of-bovine-spongiform.html

back at the ranch with larry, curly, and mo from USDA on BSE Epidemiology Update March 23, 2006 As of today, 13 locations and 32 movements of cattle have been examined with 27 of those being substantially completed. Additional investigations of locations and herds will continue. In addition, state and federal officials have confirmed that a black bull calf was born in 2005 to the index animal (the red cow). The calf was taken by the owner to a local stockyard in July 2005 where the calf died. The calf was appropriately disposed of in a local landfill and did not enter the human or animal food chain.

http://www.aphis.usda.gov/newsroom/hot_issues/bse/bse_al_epi-update.shtml

The calf was appropriately disposed of in a local landfill and did not enter the human or animal food chain.

well, back at the ranch with larry, curly and mo heading up the USDA et al, what would you expect, nothing less than shoot, shovel and shut the hell up. no mad cow in USA, feed ban working, no civil war in Iraq either.

but what has past history shown us, evidently it has shown the USDA et al nothing ;

Disposal of meat and bone meal (MBM) derived from specified risk material (SRM) and over thirty month scheme carcasses by landfill The Committee was asked to consider a quantitative risk assessment of the disposal of meat and bone meal derived from specified risk material and over thirty month scheme carcasses by landfill, prepared in response to a request from the Committee at its June 1999 meeting.

The Committee was asked whether, in the light of the results of the risk assessment, it held to its earlier published (June 1999) view that landfill was an acceptable outlet for MBM of any origin, although it retained a preference for incineration. The Committee reiterated that it had a strong preference for incineration as the favoured route for the disposal of MBM and were uneasy about the use of landfill for the disposal of this material. If there were cases where incineration was not practical the Committee felt it would be preferable for any material going to landfill to be pressure-cooked first or possibly stored above ground prior to incineration.

http://www.seac.gov.uk/summaries/summ_0700.htm

Disposal of BSE suspect carcases It is the Department's policy to dispose of BSE suspects by incineration wherever feasible. No BSE suspect carcases have been landfilled since 1991.

http://www.defra.gov.uk/animalh/bse/publichealth/notification.html#disp

OPINION ON

THE USE OF BURIAL FOR DEALING WITH ANIMAL

CARCASSES AND OTHER ANIMAL MATERIALS THAT

MIGHT CONTAIN BSE/TSE

ADOPTED BY THE

SCIENTIFIC STEERING COMMITTEE

MEETING OF 16-17 JANUARY 2003

The details of the SSC's evaluation are provided in the attached report. The SSC

concludes as follows:

(1) The term "burial" includes a diversity of disposal conditions. Although burial is

widely used for disposal of waste the degradation process essential for BSE/TSE

infectivity reduction is very difficult to control. The extent to which such an

infectivity reduction can occur as a consequence of burial is poorly characterised.

It would appear to be a slow process in various circumstances.

(2) A number of concerns have been identified including potential for groundwater

contamination, dispersal/transmission by birds/animals/insects, accidental

uncovering by man.

(3) In the absence of any new data the SSC confirms its previous opinion that animal

material which could possibly be contaminated with BSE/TSEs, burial poses a

risk except under highly controlled conditions (e.g., controlled landfill).

SNIP...

4. CONCLUSION

In the absence of new evidence the opinion of the SSC "Opinion on Fallen Stock"

(SSC 25th June 1999) must be endorsed strongly that land burial of all animals and

material derived from them for which there is a possibility that they could

incorporate BSE/TSEs poses a significant risk. Only in exceptional circumstances

where there could be a considerable delay in implementing a safe means of disposal

should burial of such materials be considered. Guidelines should be made available

to aid on burial site selection.

4 PAGES;

http://europa.eu.int/comm/food/fs/sc/ssc/out309_en.pdf

During the 2001 outbreak of FMD in the UK, the

Department of Health prepared a rapid qualitative

assessment of the potential risks to human health

associated with various methods of carcass disposal

(UK Department of Health, 2001c). The most

relevant hazards to human health resulting from

burial were identified as bacteria pathogenic to

humans, water-borne protozoa, and BSE. The main

potential route identified was contaminated water

supplies, and the report generally concluded that an

engineered licensed landfill would always be

preferable to unlined burial. In general terms, the

findings of the qualitative assessment relative to

biological agents are summarized in Table 13.

TABLE 13. Potential health hazards and associated pathways of exposure resulting from landfill or burial of

animal carcasses (adapted from UK Department of Health, 2001c).

PLEASE SEE TABLE AT;

http://www.k-state.edu/projects/fss/research/books/carcassdispfiles/PDF%20Fi les/CH%201%20-%20Burial.pdf

PART 2

Rendering and fixed-facility incineration were

preferred, but the necessary resources were not

immediately available and UK officials soon learned

that the capacity would only cover a portion of the

disposal needs. Disposal in commercial landfills was

seen as the next best environmental solution, but

legal, commercial, and local community problems

limited landfill use. With these limitations in mind,

pyre burning was the actual initial method used but

was subsequently discontinued following increasing

public, scientific, and political concerns. Mass burial

and on-farm burial were last on the preferred

method list due to the complicating matter of bovine

spongiform encephalopathy (BSE) and the risk posed

to groundwater (Hickman & Hughes, 2002).

http://www.k-state.edu/projects/fss/research/books/carcassdispfiles/PDF%20Fi les/Introduction%20to%20Part%202%20-%20Cross-Cutting%20&%20Policy%20Issues.p df

Carcase disposal:

A Major Problem of the

2001 FMD Outbreak

Gordon Hickman and Neil Hughes, Disposal Cell,

FMD Joint Co-ordination Centre, Page Street

snip...

http://www.defra.gov.uk/animalh/svj/fmd/pages27-40.pdf

3. Prof. A. Robertson gave a brief account of BSE. The US approach was to accord it a _very low profile indeed_. Dr. A Thiermann showed the picture in the ''Independent'' with cattle being incinerated and thought this was a fanatical incident to be _avoided_ in the US _at all costs_...

snip...

http://www.bseinquiry.gov.uk/files/mb/m11b/tab01.pdf

PAUL BROWN SCRAPIE SOIL TEST

http://www.bseinquiry.gov.uk/files/sc/seac07/tab03.pdf

Some unofficial information from a source on the inside looking out -

Confidential!!!!

As early as 1992-3 there had been long studies conducted on small pastures containing scrapie infected sheep at the sheep research station associated with the Neuropathogenesis Unit in Edinburgh, Scotland. Whether these are documented...I don't know. But personal recounts both heard and recorded in a daily journal indicate that leaving the pastures free and replacing the topsoil completely at least 2 feet of thickness each year for SEVEN years....and then when very clean (proven scrapie free) sheep were placed on these small pastures.... the new sheep also broke out with scrapie and passed it to offspring. I am not sure that TSE contaminated ground could ever be free of the agent!! A very frightening revelation!!!

----------

You can take that with however many grains of salt you wish, and we can debate these issues all day long, but the bottom line, this is not rocket-science, all one has to do is some experiments and case studies. But for the life of me, I don't know what they are waiting on?

Kind regards,

Terry S. Singeltary Sr. Bacliff, Texas USA

More here:

http://www.bseinquiry.gov.uk/files/ws/s018.pdf

INCINERATION TEMPS

Requirements include:

a. after burning to the range of 800 to 1000*C to eliminate smell;

well heck, this is just typical public relations fear factor control. do you actually think they would spend the extra costs for fuel, for such extreme heat, just to eliminate smell, when they spread manure all over your veg's. i think not. what they really meant were any _TSE agents_.

b. Gas scrubbing to eliminate smoke -- though steam may be omitted;

c. Stacks to be fitted with grit arreaters;

snip...

1.2 Visual Imact

It is considered that the requirement for any carcase incinerator disign would be to ensure that the operations relating to the reception, storage and decepitation of diseased carcasses must not be publicly visible and that any part of a carcase could not be removed or interfered with by animals or birds.

full text;

http://www.bseinquiry.gov.uk/files/yb/1989/04/03006001.pdf

http://europa.eu.int/comm/food/fs/sc/ssc/out311_en.pdf

TSS

----- Original Message ----- From: "Terry S. Singeltary Sr." To: Sent: Thursday, March 23, 2006 4:39 PM Subject: BSE UPDATE ALABAMA March 23, 2006

RENDERED PRODUCTS IN PET FOOD Greg Aldrich, Ph.D. President, Pet Food and Ingredient Technology, Inc. Summary Globally, in 2005, pet food and products were a $53 billion industry-and the market is growing. In the United States, dog and cat food sales alone account for $14.5 billion with exports of nearly $1 billion. The global total for pet food and supplies for all pet animals is now approaching $40 billion annually. These rising sales are driven, in part, by increasing ownership of pets with more than 140 million dogs and cats and an estimated 200 million specialty pets, such as fish, pocket pets, and exotic animals. It is also moved by the trend that more people consider their pets as members of the family as demonstrated by everything from birthday and holiday celebrations, family photos, health insurance, burial plots, and preparation of special meals. Pet foods are now more than ever considered packaged goods that are co-mingled with other family food items. The top five pet food companies, over 65 percent of the market, are owned by household names like Mars, Nestle, Proctor & Gamble, Colgate-Palmolive, and Del Monte. Traditional retail outlets such as grocery and farm/feed stores have lost some market share to big-box mass market stores, warehouse clubs, and pet specialty stores, but grocery stores remain the largest outlet. Pet food choices have become almost limitless with options for different price points, life-stage, shapes and sizes, package type, ingredient preferences, breed, size, and disease condition. Pet foods are also becoming more "humanized" and tracking human food trends. Nutrition research is showing that companion animals have some unique dietary requirements, e.g., arginine in the dog and cat, the aminosulfone taurine, and pre-formed vitamin A for the cat. Emerging nutritional benefits from omega-3 fatty acids, carotenoids, dietary fiber, mineral balance, and how meat proteins and fats are connected to optimal nutrition are actively under investigation. Rendered protein meals such as meat and bone meal, poultry by-product meal, and fish meal are almost universally used in pet foods. Generally, they provide high quality protein with a good balance of amino acids. Nutrient availability and (or) dietary utilization can be hampered by excessive heat treatment, dilution of essential amino acids with connective tissue, high levels of ash, and oxidation. Rendered fats and oils like tallow, lard, poultry fat, and fish oil provide a supplementary source of energy, flavor, texture, and nutrients in pet foods. Balancing for essential and conditionally essential fatty acids has become a key driver for selection of specific fats in the diet. Application and oxidation issues are the most common challenges faced in their use. Much of the information for pet food ingredients has been gleaned from livestock and human nutrition research. There is a fundamental need to develop these databases specifically for pets in order to address their unique nutritional idiosyncrasies and to support this growing and Essential Rendering-Pet Nutrition-Aldrich 160 continually segmenting industry. Raw, fresh, human edible, and alternative protein sources are competing to supply the protein and fat needs in pet foods. Opportunities for various rendered

snip...

Market, Volume, and Trends

No easily obtainable figures are available to provide specifics on the amount of rendered products used in pet foods. However, through some estimates and assumptions it may be possible to determine a reasonable volume. If one were to assume the average cost per pound for all pet food sold was $0.60/lb, then based Essential Rendering-Pet Nutrition-Aldrich 167 on total sales of pet food ($14.5 billion in 2005), the total tons produced each year would be in the neighborhood of 12 million. If rendered ingredients were 20 percent of these 12 million tons across all products (protein meals, fats, other), then the pet food industry would consume around 2.4 million tons per year. This represents roughly 25 percent of the total U.S. production of rendered materials during the same period (Swisher, 2005). This indicates substantial reliance and connectedness between the pet food industry and the rendering industry. This dependence for the pet food industry is for a vital supply of animal-based proteins and fats to meet the demands of their customers; for the rendering industry, it is an important outlet for their products with a tremendous value-added upside. Increasing the understanding of opportunities and limitations between the two industries will provide increased value to both, with the pet owner and their pets as the ultimate winners. Protein Meals Pet food companies write very specific purchasing requirements for their ingredients, including rendered products. AAFCO definitions are the "starting place" for these specifications. Meat and Bone Meal and Meat Meal: Meat and bone meal has been a staple protein in pet foods and is still used by a great many today. However, its popularity has declined in recent years due to several issues. Probably the biggest issue is that meat and bone meal is no longer considered "label friendly." What this means, specifically, is that the nomenclature is too generic for today's discerning consumer. Consumers have been taught to distrust something simply called "meat." A strictly beef or strictly pork meat and bone meal would likely be more acceptable to consumers, but these were not commonly available until recently. These meals are now often available for a higher price and are widely used in pet food. Adding to the challenges are its association with livestock feed rather than human food, recurring issues with bovine spongiform encephalopathy (BSE), inspections and record keeping for all ruminant meats, and concerns with disease outbreaks such as foot and mouth disease. These issues continue to place downward pressure on the popularity of meat and bone meal. Nutritionally, meat and bone meal remains a good source of animal-based protein with a fairly consistent protein level of 50 percent (Parsons et al., 1997; Pearl, 2004). This is an adequate level for traditional pet food diets with protein levels between 18 percent and 26 percent. Like many other animal-based proteins, methionine, cystine, and the total sulfur amino acids are likely the first to become limiting. Fat composition ranges from 10 percent to as high as 25 percent, depending upon supplier. The fatty acid profile can vary some and resembles the composition of the animal from which the meal originates, e.g., beef fatty acids are proportionally more saturated than pork fatty acids. Incidentally, one will often find measurable quantities of omega-3 fatty acids in meat and bone meal of ruminant origin. Due to the more saturated nature of the fatty acids in meat and bone meal it is inherently more resistant to oxidation than many of the other rendered meat meals. The higher level of ash (around 25 percent) in meat and bone meal can be a Essential Rendering-Pet Nutrition-Aldrich 168 challenge to formulate with versus some other protein meals. The AAFCO specifications indirectly restrict ash by setting limits on calcium and phosphorus levels and their ratio. Typical levels of calcium and phosphorus in meat and bone meal are 7.5 percent and 5.0 percent, respectively, and they are readily available. However, this level of minerals beco es problematic when formulating higher protein (greater than 30 percent) and low ash foods like those for cats. Increasing levels of ash in meat and bone meal have not been shown to lower protein digestibility (Johnson et al., 1998; Shirley and Parsons, 2001). However, this may not be directly due to the effect of ash on digestibility (Johnson and Parsons, 1997), but rather due to the amount and quality of connective tissue present. Low quality collagen affects protein quality where a lower proportion of essential amino acids and a higher proportion of nonessential amino acids such as hydroxyproline (Eastoe and Long, 1960) may be to blame for lower digestibility. The requirement (AAFCO) for pepsin indigestible residue of less than 12 percent partially serves to control this. Processing systems and excessive temperatures have also been shown to negatively affect the amino acid digestibility of meat and bone meal (Wang and Parsons, 1998; Batterham et al., 1986). But on the whole, the digestibility of meat and bone meal for companion animals is comparable to that of lamb meal and poultry by-product meal (Johnson et al., 1998). In dog and cat diets, meat and bone meal has not been reported to negatively affect the intestinal flora, stool consistency, or stool volume. However, beef is often blamed for food hypersensitivities so meat and bone meal is one of the first ingredients removed in an "elimination" diet regimen. Regardless of this special circumstance, the palatability, acceptability, and utilization of meat and bone meal-containing diets by both dogs and cats are quite good. Lamb Meal: Lamb meal has been a popular ingredient in dog and cat diets for the better part of the last 15 years. Initially it was considered a novel ingredient in diets for animals with food-related allergies (hypersensitivity). Lamb meal and rice diets were some of the fastest growing products offered in the pet food aisle- to the point that lamb meal supply was outstripped by the demand. "Lamb meal analogs" made of other protein meals were rumored to have entered the market, but tight controls due to BSE and scrapie issues and new DNA typing technology (Krcmar and Rencova, 2003) have all but made this an issue of the past. Some domestic lamb meal is available; however, much of the lamb meal used in pet foods is derived from the lamb meat industry in Australia and New Zealand. Most of this lamb meal is rendered in a "low temperature" rendering process. Theoretically, the quality of the meal may be better because heat damage to the proteins is minimized. However, data to support or refute this hypothesis are lacking. Lamb meal is a species-specific category of meat meal, but, very little data are available in the public domain on the ingredient itself. Analytically, lamb meal mirrors the nutrient composition of meat (and bone) meal. Likewise, the protein quality of lamb meal is reported to be roughly comparable to meat and bone meal and about 75 percent of chicken by-product meal (Johnson and Parsons, 1997; Johnson et al., 1998). In the study by Johnson et al. (1998), ileal digestibility of the essential amino acids lysine and threonine and the nonessential sulfur amino acid Essential Rendering-Pet Nutrition-Aldrich 169 cystine were quite low in the lamb meal-containing diets. This may be due to contamination of the lamb meal with high levels of wool. Wool is high in sulfur amino acids like cystine, but its nutritional availability is low. This poor availability of cystine, a taurine precursor, may explain the taurine-associated dilated cardiomyopathy in certain breeds of dogs fed an otherwise nutritionally complete diet based on lamb meal and rice (Fascetti et al., 2003). Effects of lamb meal in dog or cat diets on palatability, shelf-life, or appearance are lacking in the literature. Anecdotally, lamb meal is not considered to be the most palatable of the meat meals due to the "mutton-fat" aroma. Cats prefer other meat meals over lamb meal. Concerns about rancidity and short shelflife of lamb meal products may result from the long journey thati takes from "down under" and (or) prooxidants inherent to rendered lamb. In addition, high levels of lamb meal in a product can lead to a gray color. If the meal contains appreciable levels of contamination from wool, complaints about "hairs" may be heard from customers, especially in baked products like biscuits and treats. Poultry (By-product) Protein Meals: Poultry protein meals are a popular, high quality protein source used in pet food. The pet food industry consumes an estimated 23 percent of the rendered poultry proteins produced each year (Pearl, 2003). However, the ability to make one homogenous statement about this ingredient ends there. Due to some inconsistent rules regarding ingredient nomenclature, an evolving pet food customer base, and pressures within the poultry industry, a series of names and classifications of poultry protein meals has emerged. To start, the rendered poultry proteins are defined by AAFCO differently than the meat meals. This has created some controversy in the pet food industry and resulted in a whole layer of confusion and misdirection for the consumer. By definition, poultry by-product meal (Section 9.10) differs from poultry meal (Section 9.71) only by the inclusion of "heads, feet, and entrails" (AAFCO, 2006). Further, they can be labeled specific to their "kind" and many renderers have accommodated. Thus, there are numerous products available in the market under this umbrella: poultry by-product meal, chicken by-product meal, chicken meal, turkey by-product meal, and turkey meal. No duck or goose meal is known to have been developed as of this writing. Adding to this confusion, there are several different grades of rendered poultry products available. "Feed grade" poultry by-product meal is seldom used in pet food because it contains a higher level of ash and lower protein content. Standard pet food grade poultry by-product meal contains less than 14 percent ash and low-ash poultry meal and (or) poultry by-product meal contains less than 11 percent ash. The latter is available in limited quantities at a premium price and typically reserved for low-ash cat formulas. One further split has been the request by certain customers for poultry protein meals that are preserved against oxidation by natural compounds (natural antioxidant systems) rather than the traditional synthetic antioxidants. Among these various names, grades, and inferences regarding quality or lack thereof, there is very little in the way of direct comparisons between "meal" and "by-product meal" available in the literature. Of studies that are available, the results are mixed. For example, Bednar et al. (2000) reported that protein Essential Rendering-Pet Nutrition-Aldrich 170 digestibility was better for poultry meal than for poultry by-product meal. However, protein quality of pet food grade chicken meal did not differ from chicken by-product meal in a chick assay (Aldrich and Daristotle, 1998). From this report, data on individual chicken pieces indicated that the protein quality of feet, bone, and cartilage was poorer than other parts utilized in rendered poultry by-product meal. This appears to be independent of ash level (Johnson et al., 1998; Johnson and Parsons, 1997; Yamka et al., 2003) and would indicate that regardless of whether or not the "by-product" qualifier was present or not, the amount of cartilage and connective tissue had a bigger impact on the quality of the protein. Adding to this, the more extensively the protein meal is processed in rendering, the further the quality can be eroded (Wang, 1997). To make matters worse, there is substantial variation in the nutrient composition of poultry protein meals (Locatelli and Hoehler, 2003). Controlling this variation becomes something that the pet food company must actively manage to assure a consistent finished product. Most manage this by establishing strong relationships with select suppliers. In general, poultry protein meals are well utilized by dogs and cats and make up the biggest share of proteins in many of the premium pet foods. The fatty aci profile complements dog and cat nutrient requirements very well. Additionally, they contain an enriched level of the essential linoleic acid. Palatability of poultry protein meals is very good in both dogs and cats and in many instances serves as the standard by which other ingredients are measured. Turkey (By-product) Protein Meals: Turkey protein meal-containing pet foods are becoming more popular, thus the ingredient warrants a separate description. However, nutritional information on rendered turkey is not easily obtained nor is the ingredient constantly available. Most of the turkey to be rendered is lumped in with chicken then processed and labeled as poultry (byproduct) meal. There are only a few companies that produce or trade turkey protein meals. Turkey protein meals are a slightly darker golden brown color with a "richer" aroma when compared to chicken protein meals. The nutrient composition of turkey protein meal is usually considered to be somewhat better than meat and bone meal, which has allowed some pet food companies to use turkey protein meal as a modest upgrade to meat and bone meal as a leading protein source. The nutrient profile of turkey meal is slightly less favorable than that of pet food grade chicken protein meal. For example, turkey protein meal ranges from 62 to 65 percent protein and ash level ranges from 18 to 25 percent, whereas, pet food grade chicken protein meal typically exceeds 65 percent protein with less than 17 percent ash. This may be due to the more efficient removal of meat and other soft materials for the human edible and (or) hot dog markets, i.e. 78 percent of turkey ends up in the grocery meat case versus 72 percent of chicken. Thus, the raw material finding its way to rendering is, in general, lower in protein and fat and higher in bone (i.e., ash). The amino acid and fatty acid profile of turkey meal is very similar to that of chicken meal. Contrary to conventional wisdom, the tryptophan level in turkey meal is not greater than that found in chicken meal so it may not have a sleep inducing or calming effect as is so often rumored. No direct feeding tests of turkey meal to dogs or cats are available Essential Rendering-Pet Nutrition-Aldrich 171 in the literature. However, in vitro digestibility and amino acid profiles are similar enough to chicken by-product meal to suggest that turkey meal nutritional utilization would be similar. Palatability, acceptability, utilization, and stool quality of turkey protein meal-containing diets is very good when fed to either cats or dogs. However, the ingredient does not appear to have any unique nutritional features from that of chicken or poultry protein meals aside from its name in marketing campaigns. Fish Meal: Fish meal is an increasingly common ingredient in pet foods. While there are a few exclusionary diets in which fish meal is the feature protein ingredient, by and large, fish meal is added only secondarily as a protein source. Fish meal, relative to most other protein meals, has a high level of protein with a correspondingly high protein digestibility. Typical fish meals contain upwards of 19 percent ash which can be problematic for cat, puppy, large breed, or therapeutic diets. Besides being a source of high quality protein, fish meal also contains about eight to 12 percent fat which is rich in omega-3 fatty acids including eicosapentaenoic acid (EPA; 20:5n3) and docosahexanoic acid (DHA; 22:6n3). Thus, in most diets its primary purpose is to serve as a vehicle to deliver fatty acids. There are indications that these longer chain omega-3s may be needed. While the more direct method for the inclusion of these fatty acids would be through fish oils, the use of fish meal serves an additional purpose. Stabilizing the more highly unsaturated oils, like fish oil, can be quite difficult, especially when surface applied to pet foods. However, for reasons not fully understood, the volatile omega-3 fatty acids found in fish meal seem to be easier to stabilize in a pet food application than those in the surface applied oil. This isdou ly true for those companies attempting to utilize marine oils simultaneous to claiming to be naturally preserved. For insurance and to comply with maritime laws, antioxidant preservatives may be used when the situation warrants. The predominant fish meals available and used by the pet food industry in the United States are Gulf and Atlantic menhaden meals, capelin and herring meals from the North Atlantic, and mackerel meal from Chile. Freshwater fish meals, such as catfish from the Mississippi delta region, are also found in some pet foods. There can be substantial compositional differences in the fatty acid profile, stability, and ash levels among the many fish species (Palstinen et al., 1985; Pike and Miller, 2000). Further, the different fish meals are not necessarily interchangeable as they can dramatically affect palatability. The cat seems to be more sensitive than the dog to changes in the origin of the meal. There are very little data in the literature on the nutrient utilization of fish meal by dogs and cats. This is one case where utilizing nutrient availability data from aquaculture and swine is probably appropriate and applicable. Results from these species would suggest that fish meal is a very high quality protein source for cats and dogs with few negatives aside from compositional considerations like ash and stability. Fats and Oils In the diet, fat provides a concentrated source of energy, essential fatty acids, a route for fat soluble vitamin absorption, texture, aroma, and flavor. Fat, in Essential Rendering-Pet Nutrition-Aldrich 172 and of itself, will increase the palatability of a diet up to a certain point in cats, and without limit in dogs. Addition of fat to the diet to meet label guarantees will often reach 10 percent of the formula. While energy and essential fatty acids are a concern nutritionally, maintaining food stability is a primary issue. Dietary oxidized fat has been associated with lower metabolizable energy values (Pesti, 2002), slower puppy growth, suppressed immunity, and lower dietary and serum linoleic acid concentrations (Turek et al., 2003). Choosing the right fat source and method to retain freshness are important. Tallow: Tallow was one of the original fats applied to early commercial pet foods and there are several companies that still use it today. Most of the animal fat sold as tallow comes from federally inspected animals and facilities and has regulated quality and composition, something many other fats and oils cannot claim. Although other animal fats can be found in tallow, it is, practically speaking, derived from beef because it is a dominant meat in North America and Europe. Because of the saturated nature of the fatty acids (i.e., saturated fats are solid at higher temperatures) in fat from beef animals, it most often meets the definition of tallow-a titer of 40, or a melting point of 40ºC. For many, the "harder" fats like tallow carry a poor nutritional connotation due to the negative association of saturated fats with transport lipoproteins, cholesterol, and coronary heart disease. This is really a human nutritional issue as coronary heart disease is not a prevalent health concern for dogs or cats. Dogs and cats are considered to be "HDL species" meaning they have a preponderance of the "good" HDL in their circulation. The fatty acids in beef tallow are about 50 percent saturated, with a small amount of linoleic acid (LA; 3.0 percent) and linolenic acid (ALA; 0.6 percent) and none of the longer chain omega-3 fatty acids (EPA or DHA). Mutton tallow has a similar level of saturation (47 percent), but with a slightly higher level of LA (5.5 percent) and ALA (2.3 percent). Since beef tallow is considered a "saturated" fat and is a common fat source encountered by dogs and cats, it often serves as the baseline or "control" treatment in fatty acid research. Tallow digestibility is high (i.e., apparent fat digestibility of 97 percent or better) and comparable to other fat sources like chicken fat and lard. Among the different fat sources, beef tallow is well known for be ng one of the more palatable. Mutton or lamb tallow is not quite as palatable, possibly due to the aroma. Animal fat from tallow has even been shown to benefit "olfactory acuity scores" (Altom et al., 2003), which may translate to beneficial effects during hunting. Tallow is also considered to be more shelf-stable than less saturated fats and requires less antioxidant addition to achieve shelf-life goals. Tallow also contains a small level of conjugated linoleic acid that is now showing promise as a potent natural element in the fight against cancer. Tallow is a good "platform" to provide energy and flavor, but a balanced diet may require a complementary oil enriched with linoleic acid and (or) omega-3 fatty acids. Lard/Choice White Grease: Lard and choice white grease are also common animal fats used in pet foods. They are derived primarily from pork and are most often labeled generically as animal fat. Like tallow, most of the lard used in pet food comes from federally inspected facilities and a portion of the available supply Essential Rendering-Pet Nutrition-Aldrich 173 is human edible. Thus, pet food companies may partially compete in the human edible market for this ingredient. Due to its abundance, the cost is not typically beyond that of other fat sources. The proportion of essential fatty acids such as linoleic acid can range between 3 percent and 16 percent (Firestone, 1999). To some degree, this can be influenced by the diets the pigs were fed prior to slaughter. Lard is relatively easy to stabilize due to a preponderance of palmitic and oleic acids. Lard and choice white grease are semi-solid to viscous liquid at room temperature. It can solidify during colder weather so transportation and handling can be an issue. Further, it must be coated on foods when they are hot in order to get adequate penetration. Digestibility of lard is high and comparable to other fats. Palatability is good in both cats and dogs. Poultry Fat: Poultry and, more specifically chicken fat, has become a very popular fat source in pet foods. Poultry fat use in pet foods is probably more than 10 percent to 20 percent of the 888 million pounds of poultry fat that was produced in 2003 (U.S. Census Bureau). There are several different sources by which poultry fat is obtained: rendered, rendered-refined, and low-temperature blanched. They differ with regard to quality, consistency, and cost, and they may differ ever so slightly in minor nutrients (e.g., carotenoids), palatability, and stability. Stabilizing chicken fat in bulk storage is not a big challenge; however, when added to pet food, stability can become an issue. The potency of preservative application must consider the food and its handling and packaging. Further, the condition of the fat at the time preservatives are added is critical, i.e., the lower the moisture content, peroxide value, free fatty acid level, and impurities, the better. The trade-off is cost, availability, flavor, and aroma. Chicken fat is a good source of the essential linoleic acid (19.5 percent; USDA-ARS, 2006) and about double that of lard. Chicken fat fits very well in dog and cat diets because it is well accepted by both, having a flavor that is preferred over many other fats. Chicken fat is comparable to other fat sources such as tallow or pork fat in digestibility and overall contribution of metabolizable energy to the diet. Fish Oil: The majority of omega-3 fatty acid research in dogs and cats was conducted with the longer chain omega-3s from fish oil (e.g., EPA and DHA). These oils are derived primarily from pelagic fish like menhaden, anchovy, herring, and mackerel. This family of fish is typically found in the lower-latitude temperate to sub-tropical coastlines. They are known to have a strong oily taste and aroma not appreciated by most people; but while this doesn't appear to be a big problem for dogs, some cats may show a preference for one fish oil over another. Most fish oils are added to the surface of the pet food post-extrusion and drying. The application of fish oil to meet the desired omega-3 fatty acid level is typically less than one to two percent of the formula. This small amount can be challenging to accurately meter without properly designed equipment. Surface application can also lead to palatability concerns. Essential Rendering-Pet Nutrition-Aldrich 174 The fatty acid profile of the different fish oils can vary substantially. Most of the fish oil used in the pet food industry is cold pressed and (or) refined. While the more processed oils add to the cost, the trade-off is improved handling, animal acceptability, and shelf life. Stabilizing bulk fish oil against oxidation requires very little to no preservative; the same goes for oil in canned pet foods. However, application onto the surface of a dry extruded kibble can become an oxidation issue. The most effective antioxidant preservative is ethoxyquin; however, natural antioxidant systems based on tocopherols can be effective. Once ingested, the utilization of fish oil is similar to other fat sources. The omega-3 fatty acids appear in the circulation within hours of ingestion and pass along their benefits for weeks. Other Rendered Ingredients There have been numerous attempts to bring spent hen meal into pet food. However, no "label friendly" name has been developed. Until a suitable approach can be found, it is unlikely that a rendered spent hen meal will be used. Feather meal, while rich in desirable amino acids like methionine and cystine, is seldom, if ever, found in pet foods. This is likely due to issues with labeling and translation to the pet owner. Further, digestibility and utilization of the sulfur amino acids is not adequate to justify its use. Recent research would indicate that while blood meal is a good protein source, from a protein quality perspective, there are issues with its palatability in dogs (Dust et al., 2005). This may limit its use for anything other than a very specialized application like enteral or parenteral prescription diets. Joint cartilage and bone typically represent materials that are not desirable due to the high degree of connective tissue and low level of essential amino acids. However, there are a couple of applications in the pet food industry that may benefit from these fractions. Specifically, there has been an effort to introduce more "natural" sources of chondroprotectives like glucosamine and chondroitin sulfate into the diet. These have been traditionally sourced from China as extracts from bovine trachea (chondroitin sulfate) and crustacean shells (glucosamine). Naturally occurring and measurable levels can be found in bone cartilage and has been marketed by at least one company. Additionally, there is a move, albeit small, to develop foods which rely upon more holistic ingredients-for this purpose steamed bone meal provides calcium, phosphorus, and a host of other trace minerals. There are likely more opportunities to extract specific nutrients from rendered materials. The dependence will be upon the creativity of the product developers and the economic incentives these opportunities present. Essential Rendering-Pet Nutrition-Aldrich 175 References

http://nationalrenderers.org/assets/essential_rendering_book.pdf

Defense opens case Cattlemen vs. Oprah Winfrey

By CHIP CHANDLER Globe-News Staff Writer

snip...

Van Smith, a reporter with City Paper in Baltimore, testified about an article he wrote on rendering plants. Smith said he saw sheep taken to a plant despite a voluntary ban on using processed sheep in protein-enhanced feed, backing up a statement Lyman made on Winfrey's show.

Under cross-examination, Smith said he was not sure whether the sheep were used for feed or other animal-derived products.

snip...

Van Smith, a reporter with City Paper in Baltimore, testified about an article he wrote on rendering plants. Smith said he saw sheep taken to a plant despite a voluntary ban on using processed sheep in protein-enhanced feed, backing up a statement Lyman made on Winfrey's show.

Under cross-examination, Smith said he was not sure whether the sheep were used for feed or other animal-derived products.

http://www.amarillonet.com/

Web posted Wednesday, February 18, 1998 2:02 p.m. CT

Graphic pictures greet Winfrey jury

By KAY LEDBETTER Globe-News Farm and Ranch Editor

Pictures of sheep heads, euthanized pets and roadkill greeted jurors this morning as they returned to the continuation of the cattlemen vs. Oprah Winfrey lawsuit.

The lawsuit continues today in U.S. District Mary Lou Robinson's court, but in a much diminished state.

snip...

Defense lawyer Charles Babcock called Van Smith, a City Paper reporter from Baltimore who had written an article on rendering plants in September 1995.

Smith and Babcock went through more than 50 pictures taken as the reporter toured the Valley Proteins plant in Baltimore and followed a rendering truck to the local animal shelter, a sausage plant and a slaughterhouse.

The pictures showed offal being emptied from the slaughterhouses. They showed animal shelter workers in the euthanasia room; barrels of dead animals in a refrigerated room at the animal shelter; waste meat from the sausage plant; and dead sheep from the slaughterhouse.

http://www.amarillonet.com/

Web posted Friday, January 23, 1998 5:49 a.m. CT

TSS

Witness testifies some ill cattle sent to rendering plant

By CHIP CHANDLER Globe-News Staff Writer

snip...

Mike Engler -- son of Paul Engler, the original plaintiff and owner of Cactus Feeders Inc. -- agreed that more than 10 cows with some sort of central nervous system disorder were sent to Hereford By-Products.

The younger Engler, who has a doctorate in biochemistry from Johns Hopkins University, was the only witness jurors heard Thursday in the Oprah Winfrey defamation trial. His testimony will resume this morning.

According to a U.S. Department of Agriculture report from which Winfrey attorney Charles Babcock quoted, encephalitis caused by unknown reasons could be a warning sign for bovine spongiform encephalopathy, or mad cow disease.

Encephalitis was indicated on the death certificates -- or ``dead slips'' -- of three Cactus Feeders cows discussed in court. The slips then were stamped, ``Picked up by your local used cattle dealer'' before the carcasses were taken to the rendering plant.

snip...

http://www.amarillonet.com/

Subject: Re: MATERIAL FROM CWD-POSITIVE ANIMALS SHOULD NOT BE USED FOR ANIMAL FEED Date: Sat, 16 Nov 2002 18:12:02 -0600 From: "Terry S. Singeltary Sr." Reply-To: Bovine Spongiform Encephalopathy To: BSE-L@uni-karlsruhe.de References: <3DD28050.5010607@wt.net>

######## Bovine Spongiform Encephalopathy #########

Saturday, Nov 16, 2002

Nation Posted on Fri, Nov. 15, 2002

Renderers Reviewing Ban on At-Risk Deer in Feed

BY JULIE INGWERSEN Reuters

CHICAGO - The rendering industry is seeking more details about a new U.S. Food and Drug Administration policy aimed at keeping byproducts from diseased deer out of animal feed, an industry official said on Friday.

The FDA said in a statement this week that it was banning animal feed makers from using ingredients derived from deer and elk that are at high risk for chronic wasting disease, or CWD. Feeds that incorporate these materials "should be recalled or otherwise removed from the marketplace," the statement said.

"We're still trying to get some questions answered ... how they plan to implement it, or how they would enforce it, or what they mean by 'recall,'" Tom Cook, president of the National Renderers Association, told Reuters.

He said deer represent a very small percentage of the roughly 50 billion pounds of raw material that renderers process every year, mostly from livestock animals.

Under federal rules imposed in 1997 to prevent mad cow disease, deer and elk byproducts were already banned from feed rations for cattle, sheep and other ruminant, or grazing, animals. The new rule would ban byproducts from CWD-positive and high-risk deer and elk from all types of animal feed.

Researchers have attributed the spread of mad cow disease in Europe in the 1980s to livestock feed made from the ground-up remains of infected cattle.

While all rendered deer was banned from ruminant feed under the 1997 rules, the material was still allowed in dog, cat and other pet foods. Under the new rule, healthy deer are still allowed in pet food.

But the renderers are mad at what they term FDA's vagueness about exactly what constitutes an "at-risk" deer.

The FDA said the feed ban covered deer and elk that test positive for CWD, and also high-risk animals such as captive deer and elk from CWD-positive herds and wild deer and elk from known areas of CWD infestation, including parts of Colorado, Wyoming and Wisconsin.

Mike Langenhorst, president of Anamax Corp., a rendering company in Green Bay, Wisconsin, said Wisconsin renderers process about 3 million to 4 million pounds of deer matter a year. That represents less than 1 percent of the 1 billion pounds of raw material processed in the state.

Most of the deer material arrives within two weeks of the traditional hunting season in late November, he said.

Langenhorst said the new policy was announced suddenly and caught the industry off-guard. "There are procedures that they should have gone through to do this. This process just came down as a decree," he said.

Mad cow, formally known as bovine spongiform encephalopathy, or BSE, is a brain-destroying illness that has killed thousands of cattle across Europe. More than 100 people in Europe have died from a related human form of the disease believed to have been transmitted through the meat of infected cattle.

CWD is another variation of the disease, affecting deer, elk and similar animals classified as cervids. Mad cow disease has never been found in U.S. cattle, but CWD has been present in North American deer and elk for decades.

Unlike mad cow disease, CWD has never been shown to have infected cattle or humans.

"However," the FDA statement said, "there is little scientific evidence to show whether CWD is or is not a hazard to humans or non-cervid animals such as cattle and pigs. Therefore, FDA believes it is prudent that CWD-positive deer and elk not be used in animal feed."

http://www.macon.com/mld/macon/news/nation/4529790.htm

SECTION ONE EXECUTIVE SUMMARY The U.S. Food and Drug Administration (FDA) is considering regulatory options to reduce the risk of an outbreak of transmissible spongiform encephalopathies (TSE) in the United States. Many TSEs are believed to be transmissible through feed. Examples of TSEs in animals include bovine spongiform encephalopathy (BSE) in cattle, scrapie in sheep and goats, chronic wasting disease in mule deer and elk, and transmissible mink encephalopathy in mink. FDA is considering the following five regulatory options:

snip...

http://www.fda.gov/cvm/index/bse/bse1.pdf

SECTION TWO INTRODUCTION AND PROFILE OF THE MEAT ANIMAL PRODUCING, SLAUGHTERING, AND RENDERING INDUSTRIES

snip...

Table 2-5 End Use Markets for Animal Protein End Use Market Percent of Total Pet Food 36 Poultry 36 Swine 15 Cattle 10 Miscellaneous 3 Total 100 Source: APPI/NRA, 1996. Renderers do not generally designate their MBM for consumption by specific species. Most renderers sell to general feed manufacturers that supply different mixes to a variety of species. An average ewe produces a dressed weight (i.e., the meat products prepared for shipment to wholesale meat outlets) of 58 lb and approximately 40 lb of offal (Meyer, 1993; AMI, 1993). Lambs yield an average dressed weight of 64 lb and approximately 30 lb of offal (Meyer, 1993; AMI, 1993). Mature goats yield as much meat as adult sheep; however, many immature goats are also slaughtered for meat. No federal statistics are published on average goat weights. Based on the mix of slaughtering practices, however, it is estimated that the average slaughtered goat yields approximately one-half the meat of an adult sheep. Renderers also process animals not sent to slaughtering, including diseased, dying, disabled, or dead animals (i.e., "4-D" animals). The renderers' operation provides a valuable service to farmers, who may have no means of disposing of such animals. The addition of "fallen" animals to the rendering feedstock increases the protein content of the meat and bone meal (MBM) produced (i.e., the meaty carcass of the animal is processed along with the offal). Most renderers, especially those located in urban areas, collect and process meat scraps and fat and grease from supermarkets, restaurants, and butcher shops.

The large majority of rendering processes are continuous processes, although a few batch processes still operate. Continuous processes account for approximately 75 percent of all offal operations and 81 percent of adult sheep offal operations (APHIS, 1993). Large continuous rendering systems can process 20,000 to 40,000 lb of raw materials per hour. During rendering, raw material is fed into grinding machines and then passed to a steam-jacketed cylinder for cooking. Cooking removes moisture and releases fat. After the moisture is removed, the solid material is cooked with the fat. Finally, the fat is separated from the protein mass. Cooking temperatures range from 240 to 290 degrees Fahrenheit, and cooking times vary from 20 minutes to 3 hours. Renderers need to be located reasonably close to one or more slaughterhouses to minimize the cost of transporting large volumes of offal. A majority of plants are within 50 miles of their sources of cattle, adult sheep, or other species offal. Further, over 90 percent of plants are within 150 miles of offal sources. Rendering plants are also likely to be reasonably close to end use markets. Slightly more than one-third of all rendered products are transported less than 50 miles to end-use markets, and nearly 65 percent are within 150 miles of their markets. Nevertheless, certain products, particularly MBM, are transported hundreds of miles in some cases. Consumer health concerns in recent years regarding dietary fats and cholesterol have produced a shift in meat demand from red meat to poultry and a decline in demand for certain rendering end products, specifically edible tallow and lard. These changes have weakened business conditions, leading to substantial consolidation and contraction within both industries. For example, the number of large slaughter plants for cattle (processing over 50,000 head per week) declined by 34 percent, and the number of large hog slaughter plants (processing over 100,000 head per week) declined by 40 percent from 1982 to 1991 (AMI, 1992). Additionally, in some areas the number of small slaughterhouses has declined. Even though many of these small plants handled numerous species, they were adversely affected by the decline in animal production levels. Declines in slaughter levels also have tended to drive up the prices that slaughterers charge for processing (or decreased their prices for live animals), since the firms must attempt to cover their fixed costs over a smaller volume of processing. Similarly, the total number of rendering facilities dropped from more than 800 in the early 1970s to the current number of less than 300 (Pietraszek, 1991).

snip...(about 17 pages)

http://www.fda.gov/cvm/index/bse/bse2.pdf

'ANIMAL PROTEIN' SEARCH 9/9/02 ==============================

Darling International, Inc. 5/07/02 Seattle District Office Animal Proteins Prohibited in Ruminant Feed/Misbranded [PDF] [HTML] All American Feed & Tractor 4/01/02 Seattle District Office Animal Proteins Prohibited in Ruminant Feed/Adulterated [PDF] [HTML] Tyson Foods 2/12/02 Seattle District Office Animal Proteins Prohibited in Ruminant Feed/Misbranded [PDF] [HTML] The Feed Bucket 12/11/01 Atlanta District Office Animal Proteins Prohibited in Ruminant Feed/Adulterated/Misbranded [PDF] [HTML] Finlayson Ag Center 11/08/01 Minneapolis District Office Animal Proteins Prohibited in Ruminant Feed/Adulterated [PDF] [HTML] Dixon Feeds, Inc. 10/24/01 Seattle District Office Animal Proteins Prohibited in Ruminant Feed/Adulterated [PDF] [HTML] Buckeye Feed Mills, Inc. 9/20/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed/Adulterated/Misbranded [PDF] [HTML] Wilcox Farms, Inc. 9/14/01 Seattle District Office Animal Proteins Prohibited in Ruminant Feed [PDF] [HTML]

http://www.accessdata.fda.gov/scripts/wlcfm/full_text.cfm?full_text=animal+protein&Search=Search

now, compare search on 8/8/01...tss ===================================

'ANIMAL PROTEIN' SEARCH 8/8/01 ==============================

Date: Tue, 28 Aug 2001 11:13:43 -0700 Reply-To: BSE-L Sender: Bovine Spongiform Encephalopathy BSE-L From: "Terry S. Singeltary Sr." Subject: MAD COW FEED BAN WARNING LETTERS U.S.A. AUGUST 8, 2001

DEPARTMENT OF HEALTH AND HUMAN SERVICES

Food and Drug Administration

Seattle District Pacific Region 22201 23rd Drive SE Bothell, WA 98021-4421

Telephone: 426-486-8788 FAX: 426-483-4996

August 8, 2001

VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED

In reply refer to Warning Letter SEA 01-75

William W. Himmelspach, Owner 22195 S.W. 78th Tualatin, Oregon 97062

WARNING LETTER

Dear Mr. Himmelspach:

An investigation at your animal feed manufacturing operation located at 22195 S.W. 78th Tualatin, Oregon 97062, conducted by a Food and Drug Administration investigator on July 12, 2001, found significant deviations from the requirements set forth in Title 21, Code of Federal Regulations, Part 589.2000 - Animal Proteins Prohibited in Ruminant Feed. The regulation is intended to prevent the establishment and amplification of Bovine Spongiform Encephalopathy (BSE). Such deviations cause products being manufactured at this facility to be adulterated within the meaning of Section 402(a)(2)(C), and 402(a)(4) of the Federal Food, Drug and Cosmetic Act (the Act).

Our investigation found a failure to separate the receipt, processing, and storage of the product containing prohibited material from non-prohibited material; failure to establish a written system, including clean-out and flushing procedures, to avoid commingling and cross-contamination of common equipment; and failure to maintain records sufficient to track the materials throughout the receipt, processing, and distribution of your products.

In addition, our investigation found a failure to label your products with the required cautionary, statement "Do Not Feed to Cattle or Other Ruminants," Your pig feeds, containing prohibited materials, were not labeled with the cautionary statement, and you reuse poly-tote bags for ruminant feed and pig feed, where the bags could become contaminated with prohibited material. The FDA suggests the statement be distinguished by different type size or color or other means of highlighting the statement so that it is easily noticed by a purchaser.

The above is not intended to be an all-inclusive list of deviations from the regulations. As a manufacturer of materials intended for animal feed use, you are responsible for assuring that your overall operation and the products you manufacture and distribute are in compliance with

William W. Himmelspach Tualatin, Oregon Re: Warning Letter SEA 01-75 Page 2

your overall operation and the products you manufacture and distribute are in compliance with the law. We have enclosed a copy of the FDA's Small Entity Compliance Guide to assist you with complying with the regulation.

You should take prompt action to correct these violations, and you should establish a system whereby such violations do not recur. Failure to promptly correct these violations may result in regulatory action without further notice, such as seizure and/or injunction.

You should notify this office in writing within 15 working days of receipt of this letter, of the steps you have taken to bring your firm into compliance with the law. Your response should include an explanation of each step being taken to correct the violations, and prevent their recurrence. If corrective action cannot be completed in 15 working days, state the reason for the delay and the date by which the corrections will be completed. Include copies of any available documentation demonstrating that corrections have been made.

Your reply should be directed to the Food and Drug Administration, Attention: Bruce Williamson, Compliance Officer. If you have any questions please contact Mr. Williamson at (425) 483-4976.

Sincerely,

Charles M. Breen District Director

Enclosure; Form FDA 483 Small Entity Compliance Guide

http://www.fda.gov/foi/warning_letters/g1619d.pdf

Warning Letters Index - Search Form Results Company Name Date Issued Issuing Office

Subject

File Adrian Elevator, Inc. 5/03/01 Minneapolis District Office Animal Proteins Prohibited in Ruminant Feed

View File Alaska Garden and Pet Supply, Inc. 4/27/01 Seattle District Office Animal Proteins Prohibited in Ruminant Feed

View File Bryan Enterprises 2/20/01 Cincinnati District Office Feed Mill/Animal Proteins Prohibited in Ruminant Feed/Adulterated

View File Carrollton Farmers Exchange 7/12/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Centerburg Mill and General Store, Inc 3/23/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Centerburg Mill and General Store, Inc. 5/23/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Central Ohio Farmers Cooperative, Inc. 5/24/01 Cincinnati District Office Animal Protein Prohibited in Ruminant Feed

View File Champaign Landmark, Inc. 3/05/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed/Misbranded

View File Countryline Co-Op, Inc. 5/14/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Dorset Milling 4/16/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Earl B. Olson Feed Mill 4/23/01 Minneapolis District Office Animal Proteins Prohibited in Ruminant Feed

View File Faler Feed Store, Inc. 3/21/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Farmers Mill & Elevator Company 3/30/01 Atlanta District Office Animal Proteins Prohibited in Ruminant Feed

View File Farnam Companies, Inc. 7/20/01 Kansas City District Office Animal Proteins Prohibited in Ruminant Feed/Adulterated

View File Greeley Elevator Company 4/04/01 Denver District Office Animal Proteins Prohibited in Ruminant Feed

View File Hartville Elevator Company, Inc. 2/22/01 Cincinnati District Office Feed Mill/Animal Proteins Prohibited in Ruminant Feed/Adulterated

View File Himmelspach, William W. 8/08/01 Seattle District Office Animal Proteins Prohibited in Ruminant Feed

View File Integral Fish Foods, Inc. 6/12/01 Denver District Office Animal Proteins Prohibited in Ruminant Feed

View File Jefferson Milling Company 4/16/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Lime Creek Ag Services, Inc. 4/25/01 Minneapolis District Office Animal Proteins Prohibited in Ruminant Feed

View File Material Resources LLC 5/04/01 Chicago District Office Animal Proteins Prohibited in Ruminant Feed

View File Material Resources, LLC 5/04/01 Chicago District Office Animal Protein Prohibited in Ruminant Feed

View File Medina Landmark, Inc. 3/23/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Minister Farmers Cooperative Exchange, Inc. 4/10/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed/Feed Mill

View File Peco Foods, Inc. 2/23/01 New Orleans District Office CGMP Requirements for Medicated Feeds/Animal Proteins Prohibited in Ruminant Feed

View File Perry Coal and Feed Company 4/16/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Rietdyk's Milling Company 3/05/01 Seattle District Office Animal Proteins Prohibited in Ruminant Feed

View File River Valley Co-Op 3/22/01 Cincinnati District Office Animal Proteins Prohibeted in Ruminant Feed

View File River Valley Co-Op 5/22/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Round Lake Farmers Coop. 5/30/01 Minneapolis District Office Animal Proteins Prohibited in Ruminant Feed

View File Rudy, Inc. 3/22/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Rudy, Inc. 5/22/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Sandy Lake Mills 4/09/01 Philadelphia District Office Animal Proteins Prohibited in Ruminant Feed

View File Shields Feed and Supply Company 3/07/01 New Orleans District Office Animal Proteins Prohibited in Ruminant Feed

View File Stewart's Farm Supply 3/21/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Superior Feeds 6/06/01 Seattle District Office Animal Proteins Prohibited in Ruminant Feed

View File The Scoular Company 5/30/01 Minneapolis District Office Animal Proteins Prohibited in Ruminant Feed

View File University of Minnesota 5/10/01 Minneapolis District Office Animal Proteins Prohibited in Ruminant Feed

View File Valley Feed Mill, Inc. 5/22/01 Cincinnati District Office Animal Proteins Prohibited in Ruminant Feed

View File Wallowa County Grain Growers, Inc. 5/17/01 Seattle District Office Animal Proteins Prohibited in Ruminant Feed

View File Wallowa County Grain Growers, Inc. 5/17/01 Seattle District Office Animal Proteins Prohibited in Ruminant Feed

View File Western Reserve Farm Cooperative 3/21/01 Cincinnati District Office Animal Protein Prohibited in Ruminant Feed

View File Yachere Feed, Inc. 4/09/01 Philadelphia District Office Animal Proteins Prohibited in Ruminant Feed

View File Z & W Mill, Inc. 3/27/01 Denver District Office Animal Proteins Prohibited in Ruminant Feed

View File

http://63.75.126.221/scripts/wlcfm/resultswl.cfm

(TYPE IN 'ANIMAL PROTEIN')

Subject: Meat and Poultry: Better USDA Oversight and Enforcement of Safety Date: Thu, 19 Sep 2002 14:17:59 -0700

Subject: GAO ''BLASTS'' USA FDA HALF-ASS MAD COW FEED BAN RULES (or the lack of) Date: Tue, 26 Feb 2002 11:29:57 -0800 From: "Terry S. Singeltary Sr." Reply-To: Bovine Spongiform Encephalopathy

Investigators: FDA Lax on Mad Cow Tue Feb 26,11:37 AM ET

By PHILIP BRASHER, AP Farm Writer

WASHINGTON - The Food and Drug Administration (news - web sites ) has failed to properly enforce its restrictions on animal feed that are intended to keep mad-cow disease from spreading if it ever gets into the country, congressional investigators say.

Feed mills and other firms that violate the rules are seldom punished, and FDA has never even identified all the businesses that should be inspected, the General Accounting Office (news - web sites) said in a report released Tuesday.

The report also raises concerns about import controls that are supposed to keep infected meat and other material from entering the country

"The continuing absence of (mad cow disease) in the United States today cannot be sufficiently ensured by current federal prevention efforts," the report said.

The agency outlawed the feeding of mammalian meat and bone meal to cattle, sheep and goats in 1997 and imposed a series of rules to ensure that feed mills comply with the ban.

Animals are believed to get the brain-wasting disease, formally known as bovine spongiform encephalopathy (news - web sites ), through eating the brain or nervous system tissue from diseased animals. Meat and bone meal has long been added to animal feed as a protein supplement.

The disease has never been found in the United States but has devastated the beef industry in Europe and spread to Japan.

An FDA spokesman had no immediate comment Tuesday on the GAO report. In a letter to the investigators, however, FDA said it is correcting problems in its inspection system. Improvements in the system "will make the present small risk of introduction and spread (of mad-cow disease even smaller," the agency said.

The food industry became alarmed last year about the problems FDA was having enforcing the rules and began requiring meat processors to certify that the cattle were not given prohibited feed. Slaughterhouses, in turn, started requiring similar paperwork from their cattle suppliers.

The congressional investigators said "the nature and severity of the problem" in FDA's enforcement of the feed ban "point to insufficient attention by FDA management."

The report also says that the Agriculture Department is testing too few cattle for the disease. USDA plans to increase its testing from 5,000 to 12,500 cattle a year.

Sen. Richard Durbin (news ), D-Ill., who requested the GAO report along with Senate Agriculture Committee Chairman Tom Harkin of Iowa and the panel's ranking Republican, Richard Lugar of Indiana, plans to introduce legislation to tighten federal regulation of animal feed and meat processing.

Patrick Boyle, president of the American Meat Institute, said the GAO report "misinterprets, or simply ignores the effectiveness of measures already taken" by the government.

http://story.news.yahoo.com/news?tm...pe/us_mad_cow_3

FULL TEXT OF GOA REPORT BELOW (takes a while to load)

2. Mad Cow Disease: Improvements in the Animal Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention Efforts. GAO-02-183, January 25.

http://www.gao.gov/cgi-bin/getrpt?GAO-02-183

Defense opens case Cattlemen vs. Oprah Winfrey

By CHIP CHANDLER Globe-News Staff Writer

snip...

Van Smith, a reporter with City Paper in Baltimore, testified about an article he wrote on rendering plants. Smith said he saw sheep taken to a plant despite a voluntary ban on using processed sheep in protein-enhanced feed, backing up a statement Lyman made on Winfrey's show.

Under cross-examination, Smith said he was not sure whether the sheep were used for feed or other animal-derived products.

snip...

Van Smith, a reporter with City Paper in Baltimore, testified about an article he wrote on rendering plants. Smith said he saw sheep taken to a plant despite a voluntary ban on using processed sheep in protein-enhanced feed, backing up a statement Lyman made on Winfrey's show.

Under cross-examination, Smith said he was not sure whether the sheep were used for feed or other animal-derived products.

http://www.amarillonet.com/ns-search/stories/021998/036-3052.001.shtml?NS-search-set=/3704d/aaaa2813004db0d&NS-doc-offset=5&

Web posted Wednesday, February 18, 1998 2:02 p.m. CT

Graphic pictures greet Winfrey jury

By KAY LEDBETTER Globe-News Farm and Ranch Editor

Pictures of sheep heads, euthanized pets and roadkill greeted jurors this morning as they returned to the continuation of the cattlemen vs. Oprah Winfrey lawsuit.

The lawsuit continues today in U.S. District Mary Lou Robinson's court, but in a much diminished state.

snip...

Defense lawyer Charles Babcock called Van Smith, a City Paper reporter from Baltimore who had written an article on rendering plants in September 1995.

Smith and Babcock went through more than 50 pictures taken as the reporter toured the Valley Proteins plant in Baltimore and followed a rendering truck to the local animal shelter, a sausage plant and a slaughterhouse.

The pictures showed offal being emptied from the slaughterhouses. They showed animal shelter workers in the euthanasia room; barrels of dead animals in a refrigerated room at the animal shelter; waste meat from the sausage plant; and dead sheep from the slaughterhouse.

http://www.amarillonet.com/stories/021898/graphic.shtml

Web posted Friday, January 23, 1998 5:49 a.m. CT

TSS

Witness testifies some ill cattle sent to rendering plant

By CHIP CHANDLER Globe-News Staff Writer

snip...

Mike Engler -- son of Paul Engler, the original plaintiff and owner of Cactus Feeders Inc. -- agreed that more than 10 cows with some sort of central nervous system disorder were sent to Hereford By-Products.

The younger Engler, who has a doctorate in biochemistry from Johns Hopkins University, was the only witness jurors heard Thursday in the Oprah Winfrey defamation trial. His testimony will resume this morning.

According to a U.S. Department of Agriculture report from which Winfrey attorney Charles Babcock quoted, encephalitis caused by unknown reasons could be a warning sign for bovine spongiform encephalopathy, or mad cow disease.

Encephalitis was indicated on the death certificates -- or ``dead slips'' -- of three Cactus Feeders cows discussed in court. The slips then were stamped, ``Picked up by your local used cattle dealer'' before the carcasses were taken to the rendering plant.

snip...

http://www.amarillonet.com/ns-search/stories/012398/cattle.shtml?NS-search-set=/3704d/aaaa2813004db0d&NS-doc-offset=93&

TSS

Terry S. Singeltary Sr. wrote:

######## Bovine Spongiform Encephalopathy #########

November 12, 2002

MATERIAL FROM CWD-POSITIVE ANIMALS SHOULD NOT BE USED FOR ANIMAL FEED

In a call to State public health and agriculture officials throughout the U.S. today, FDA announced that the Agency will not permit material from Chronic Wasting Disease (CWD)-positive animals, or animals at high risk for CWD, to be used as an ingredient in feed for any animal species. Animals considered to be at high risk for CWD would include animals from CWD-positive captive herds, free ranging animals from the endemic area in Colorado and Wyoming, deer from the eradication zone in Wisconsin, and deer from any areas designated around any new foci of CWD infection that might be identified through surveillance or hunter harvest testing. FDA stated that animal feed or feed ingredients on the market that incorporate this material should be recalled or otherwise removed from the marketplace.

CWD is a neurological (brain) disease of farmed and wild deer and elk that belong in the cervid animal family. The disease has been found in farmed and wild mule deer, white-tailed deer, North American elk, and in farmed black-tailed deer. CWD belongs to a family of animal and human diseases called transmissible spongiform encephalopathies (TSEs). These include bovine spongiform encephalopathy (BSE or "mad cow" disease) in cattle; scrapie in sheep and goats; and classical and variant Creutzfeldt-Jakob diseases (CJD and vCJD) in humans. TSEs are very rare, but are always fatal. Although CWD shares certain features with other TSEs, it is a distinct disease. There is no known treatment for these diseases, and there is no vaccine to prevent them. In addition, there are no validated diagnostic tests for CWD or other TSEs that can be used to test for the disease in live animals or humans.

Only deer and elk are known to be susceptible to CWD by natural transmission. However, there is little scientific evidence to show whether CWD is or is not a hazard to humans or non-cervid animals such as cattle and pigs. Therefore, FDA believes it is prudent that CWD-positive deer and elk not be used in animal feed. During the call to State health and agriculture officials, FDA announced that the Agency plans to issue a Compliance Policy Guide on this issue at a later date.

http://www.fda.gov/cvm/index/updates/CWdup.htm

TSS

########### http://mailhost.rz.uni-karlsruhe.de/warc/bse-l.html ############

########### http://mailhost.rz.uni-karlsruhe.de/warc/bse-l.html ############

Monday, July 21, 2008

FDA's BSE Final Rule Published; New Requirements Imposed on Renderers 2008, Volume VIII, No. I, FDA Veterinarian Newsletter 2008, Volume VIII, No. I, FDA Veterinarian Newsletter [PDF format]

http://madcowfeed.blogspot.com/2008/07/fdas-bse-final-rule-published-new.html

Content-Type: text/plain; charset="ISO-8859-1" Message-ID: <18644F11B670D61197F400065B05995120638E@exchange.sdt.dep.no> Date: Sat, 14 Jun 2003 23:10:28 +0200 Reply-To: Bovine Spongiform Encephalopathy Sender: Bovine Spongiform Encephalopathy From: Karin.Irgens@DYREHELSETILSYNET.NO Subject: risk from US exports of cattle and MBM ######## Bovine Spongiform Encephalopathy #########

Hello all

Terry has now provided US export figures for 'breeding cattle' for 1999, in addition to export statistics for 2002 that he had already provided. On the basis of US export statistics for 1999 and 2002 for live cattle for breeding, and US export statistics for 2002 and 2003 for meat and bone meal (code 23.01.1000), we could try to calculate external challenge from the USA to importing countries. However, _we dont really know_ the situations in most of these importing countries (at least I dont know...). If live cattle from a BSE-infected country are imported to a country that does not have a rendering system for slaughter waste, there would be no resulting BSE-risk to the importing country. If an importing country decides to exclude waste from imported cattle from rendering, or to BSE-test all imported cattle slaughtered at > 30 months age, the risk will be considerably reduced. Canadian and US cattle exported for breeding in recent years may still be alive in the importing countries, and may now be excluded from rendering.

We dont know if all US exports of meat and bone meal "code 23.01.1000" were "mammalian" MBM or if some of it was poultry meal or MBM derived only from pigs. The same code 23.01.1000 can be used for registrations of exports/imports of mammalian MBM and poultry meal. The EU SSC does not consider poultry meal as a BSE-risk, but each country must prove how much of the imports really were poultry meal. It is possible that some countries, for religious reasons, would accept only MBM not derived from pig waste. If such countries imported only poultry meal, the risk would be very low.

We dont know if all registered US exports were correctly coded. It is possible and probable that some exports were in fact other products that shoud not have been coded as 23.01.1000.

And of course we dont know the final destination of "23.01.1000"-products exported by the US, whether or not the MBM reached cattle through feeding in the importing country.

It is therefore not possible to make any real risk estimate, not knowing what happened in each importing country. For countries already assessed by the SSC, such knowledge may be found in the already publisehd GBR assessments.

Here I can only add up exports from US to each country, and only for years 1999 and 2002 (+ january-march 2003), and roughly calculate the numbers of risk units _if_ these imports really represented a risk to cattle in the importing countries. (see list country list below).

It appears that the countries most at risk from US imports, especially MBM would be Bangladesh, Egypt, China, Indonesia, Malaysia, Mexico, Philippines, Taiwan, Thailand, Venezuela, Vietnam. Some other countries have imported much lower amounts of US cattle + MBM in 1999 and 2002/2003, but I dont know if these countries have imported similar (or higher) amounts from the USA in previous years.

According to Rev Sci Tech. 2003 Apr;22(1):237-49. Risk management of transmissible spongiform encephalopathies in Asia - Ozawa Y :

" ...significant quantities of feedstuffs of ruminant origin have been imported into Asia, which may mean that the BSE agent could have reached domestic cattle in most countries... Recycling of BSE through rendering plants is unlikely but cannot be totally excluded in some countries such as the People's Republic of China, India, Japan, Pakistan and Taipei China... "

"...The external challenge has been considerably reduced in recent years as most countries in Asia banned the importation of feedstuffs from _countries with BSE _ ..."

(my comments: but they did not ban MBM from the USA... I think China has the world's largest cattle population...)

quoted from a series of articles on CWD, in 2002 : http://cfapp.rockymountainnews.com/cwd/killer/

" ...the FDA has not imposed the same restrictions on exported MBM. In fact, since the American ban went into effect, annual U.S. exports of MBM have jumped from 291,000 tons to 467,000 tons, a 60 percent increase. American renderers aren't required to warn their foreign customers about feeding ruminant protein -- that rendered from sheep or cattle -- to cattle. However, three large renderers contacted by the News say they label their products that way regardless of the lack of regulations. Denver's National By-Products said it ships its MBM to China and Indonesia in large shipping containers, not in individually marked bags. But it stamps on its bills of lading a warning against feeding the product to ruminants. The stamp is in English. Once American meat and bone meal arrives in the purchasing country, the manufacturer has no further control over how it is labeled, said National By-Products district manager Ken Kage. A spokesman for the USDA and officials with the National Renderers Association say that foreign trade in U.S. MBM is not a problem because there have been no cases of mad cow disease in this country. Some countries importing MBM have had few if any rules concerning its use as cattle feed. Mexico, for example, implemented labeling rules only this year (2002), according to Alberto Celis, the National Renderers Association regional director for Latin America. That was news to many agricultural business people attending an animal feed trade show in Guadalajara in March. Representatives from three animal feed bag manufacturers said they had heard of no such regulations and that their bags remain warning free. Mexico exports over a million live cattle a year to the United States. Mexican cattlemen said these "feeder" cows are not typically fed animal protein, though there is little evidence that the government has an adequate inspection program to make certain. Mexican government officials responded that MBM rules were promulgated last summer, and that they will be vigorously enforced. They said Mexico stopped importing MBM from countries with a BSE problem in 1991 and that there are no known cases of BSE in the country. The World Health Organization says Mexico's experience with American MBM is reflected throughout the world. The United Nations agency was "concerned that some countries which received (MBM) materials do not have surveillance systems to detect the disease in animals or the human population," said WHO's Dr. Maura Ricketts at a news conference in December 2000. She said once the MBM leaves one country, it begins a "murky movement" that is almost impossible to track. Taking heed of such warnings, the European Union (EU) decided that the risk to public health was too great even if an importing country insisted that it would use MBM only as poultry feed -- which, along with pet food, is its major use in the U.S. The EU adopted the ban of all exports of MBM in 2000. Instead of adopting a similar policy, the USDA saw the ban as a golden opportunity. "Importing countries of EU MBM may be forced to seek alternative suppliers of animal protein meals, such as the United States," said a December 2000 report by the USDA. "The United States should be well positioned to take advantage of that situation to increase its own exports of MBM." And it has. Render, the magazine of the National Renderers Association, noted in its April issue that exports of many products were under competitive pressure from vegetable oils. But it noted "a bright spot is meat and bone meal exports that continue to increase." The chief foreign markets for American MBM, in order of sales amounts, were Indonesia, Mexico, Egypt, China, Canada, Thailand, Bangladesh, the Philippines and Venezuela. In 1998, Egypt imported 96,000 metric tons of MBM from the EU, and only 3,100 metric tons from the U.S. By 2001, the U.S dominated the Egyptian market, selling over 73,000 metric tons..."

(r.u = risk unit) (2003 = US exports of "23.01.1000"-products in the period January through March 2003)

Argentina 1999: 9 cattle for breeding (0,09 r.u.)

Australia 1999: 81 breeding cattle from USA (0,8 risk units) 2003: 5 tons MBM from USA (0,5 r.u.)

Bangladesh 2003: 2.217 tons MBM 2002: 12.630 tons MBM (1.484 r.u)

Belize: 2002: 27 cattle for breeding (0,27 r.u.)

Brazil 1999: 440 breeding cattle 2002: 134 breeding cattle (5,7 r.u.) 2002: 12 tons MBM 2003: 12 tons MBM (2,4 r.u.)

China 1999: 84 breeding cattle 2002: 40 + 190 + 26 breeding cattle (2,8 r.u.) 2002: 104.784 tons MBM 2003: 19.552 tons MBM (12.433 r.u)

Colombia 1999: 251 cattle for breeding 2002: 2.363 cattle for breeding (26 r.u.) 2002: 882 tons MBM 2003: 80 tons MBM (96 r.u.)

Colombia has > 100 r.u. from recent imports from the USA. Colombia was previously assessed in category II and might now be re-assessed in category III, unless there is proof that the additional external challenge from USA did not reach Colombian cattle.

Costa Rica 2002: 19 cattle for breeding (0,19 r.u.)

Dominican Republic: 1999: 45 cattle for breeding 2002: 220 cattle for breeding (2, 65 r.u.) 2003: 77 tons MBM (7,7 r.u.)

Ecuador 1999: 120 cattle for breeding (1,2 r.u.) 2002: 14 tons MBM (1,4 r.u.)

Egypt: 2002: 104.408 tons MBM 2003: 15.796 tons MBM (12.019 r.u.) Egypt would already have a high external challenge from previous imports from Europe.

Ghana: 2003: 41 tons MBM (4,1 r.u.)

Guatemala 1999: 23 cattle for breeding 2002: 26 cattle for breeding (0,49 r.u.)

Honduras 2002: 51 cattle for breeding (0,51 r.u.)

Hong Kong: 2002: 41 tons MBM 2003: 61 tons MBM (10 r.u.)

Indonesia 2002: 148.558 tons MBM 2003: 36.999 tons MBM (18.555 r.u.) (according to various figures from newspapers, Indonesia would prevously have been a major importer of British MBM)

Korea, South 1999: 248 cattle for breeding (2, 48 r.u.) 2002: 262 tons MBM (26 r.u.)

Lebanon 1999: 2.228 cattle for breeding (22, 3 r.u.)

Malaysia 2002: 7 cattle for breeding (0,07 r.u.) 2002: 12.646 tons MBM 2003: 2.209 tons MBM (1485 r.u.)

Mexico 1999: 8.780 cattle for breeding 2002: 10.888 cattle for breeding (196 r.u.) 2002: 93.685 other cattle ?? 2002: 62.204 tons MBM 2003: 14.756 tons MBM (7.696 r.u.)

New Zealand 2002: 21 tons MBM (2,1 r.u.)

Niger 2002: 57 tons MBM (5,7 r.u.)

Panama 1999: 17 cattle for breeding 2002: 59 cattle for breeding (0,76 r.u.) 2002: 172 tons MBM 2003: 57 tons MBM (23 r.u.) Panama, previously assessed in category I, might have 23 additonal risk units from recent US imports, and might be re-assessed in category II if this could have reached cattle.

Pakistan 1999: 11 cattle for breeding (0,11 r.u.)

Philippines 2002: 5.585 tons MBM 2003: 1.215 tons MBM (680 r.u.)

Russia: 2002: 390 tons MBM 2003: 1.520 tons MBM (191 r.u.) Russia would probably already be at risk from imports from EU and/or east-European countries.

Saudi Arabia 1999: 884 cattle for breeding (8, 84 r.u.)

Singapore 2003: 4 tons MBM (0, 4 r.u.)

South Africa: 2002: 40 tons MBM (4 r.u.)

Sri Lanka 2002: 351 tons MBM (35 r.u.)

Suriname 2002: 45 cattle for breeding (0,45 r.u.)

Taiwan 2002: 12.421 tons MBM 2003: 1.719 tons MBM (1.414 r.u.)

Thailand 2002: 36.476 tons MBM 2003: 7.314 tons MBM (4.379 r.u.)

United Arab Emirates 2003: 39 tons MBM (3,9 r.u.)

Uruguay: 1999: 7 cattle for breeding (0,07 r.u.)

Venezuela 1999: 473 cattle for breeding 2002: 169 cattle for breeding (6, 4 r.u.) 2002: 1.998 tons MBM (199 r.u.)

Vietnam 2002: 7.618 tons MBM 2003: 2.229 tons MBM (1.048 r.u.)

Best regards Karin Irgens

====================================================

???$$$???

AAMP Member Letter re Latest FDA, USDA Rulemaking on BSE To: Food and Drug Administration USDA Food Safety and Inspection Service USDA Animal & Plant Health Inspection Service Members of Congress (2 Senators and U.S. Representative) As a small meat processor, I am writing to you to raise concerns about new rulemaking that is being considered by the Food and Drug Administration, and two Agencies within USDA: the Food Safety and Inspection Service, and the Animal and Plant Health Inspection Service, to prevent the occurrence of BSE ("mad cow disease") in the cattle herd in the United States. I commend the federal government's continued vigilance in maintaining strong protections against BSE. The efforts by the government to achieve 100 percent compliance with existing feed restrictions are good, although FDA does report that feed restrictions right now are being complied with more than 99 percent of the time, the highest level of observance of any FDA rule. But I am concerned about the proposal for mandatory elimination of Specified Risk Materials (SRMs) from all animal feed. With no "homegrown" BSE case found in the United States at all, this policy would be unnecessary and duplicative in view of other feed restrictions that exist right now. This would result in a huge drop in markets for renderers, and would make it even more difficult for small and very small plants to have their materials picked up by renderers. While large packers generally have their own rendering operations, the small industry is dependent on independent rendering companies for service, especially the smaller rendering firms. It is not going to pay independent renderers to send out to trucks to very small plants to pick up waste materials, especially if the renderers would require them to be separated into SRMs and non-SRMs. The government, including the USDA and FDA, as well as Congress, needs to examine what is going to happen if these regulations are put into effect. These waste materials have to be disposed of in some way. It is not going to be helpful if this waste is dumped on fields, or on other locations. We urge the government to take another look at this issue, and reconsider. The steps are not necessary, and will hurt the small industry severely. Sincerely, (Go to www.congress.org . You will find the names of your U.S. Representative and Senators, with ways to contact them via e-mail, regular mail and telephone.)

http://www.aamp.com/regulatory/documents/BSESampleLetter.pdf

August 13, 2004 Division of Dockets Management (HFA-305) Food and Drug Administration 5630 Fishers Lane, Room 1061 Rockville, MD 20852 RE: Docket No. 2004N-0264: Federal Measures to Mitigate BSE Risks: Considerations for Further Action, Advance Notice of Proposed Rulemaking, Food and Drug Administration, HHS

http://www.aamp.com/documents/FDAFeedBanComments-web_000.pdf

Monday, December 22, 2008 [Docket No. FDA-2008-D-0597] Draft Guidance for Industry: Small Entities Compliance Guide for Renderers-Substances Prohibited From Use in Animal Food

http://madcowfeed.blogspot.com/2008/12/docket-no-fda2008d0597-draft-guidance.html

Saturday, January 24, 2009 Bovine Spongiform Encephalopathy h-BSE ATYPICAL USA 2008 Annual Report Research Project: Study of Atypical Bse

Location: Virus and Prion Diseases of Livestock

2008 Annual Report

1a.Objectives (from AD-416) The objective of this cooperative research project with Dr. Maria Caramelli from the Italian BSE Reference Laboratory in Turin, Italy, is to conduct comparative studies with the U.S. bovine spongiform encephalopathy (BSE) isolate and the atypical BSE isolates identified in Italy. The studies will cover the following areas: 1. Evaluation of present diagnostics tools used in the U.S. for the detection of atypical BSE cases. 2. Molecular comparison of the U.S. BSE isolate and other typical BSE isolates with atypical BSE cases. 3. Studies on transmissibility and tissue distribution of atypical BSE isolates in cattle and other species.

1b.Approach (from AD-416) This project will be done as a Specific Cooperative Agreement with the Italian BSE Reference Laboratory, Istituto Zooprofilattico Sperimentale del Piemonte, in Turin, Italy. It is essential for the U.S. BSE surveillance program to analyze the effectiveness of the U.S diagnostic tools for detection of atypical cases of BSE. Molecular comparisons of the U.S. BSE isolate with atypical BSE isolates will provide further characterization of the U.S. BSE isolate. Transmission studies are already underway using brain homogenates from atypical BSE cases into mice, cattle and sheep. It will be critical to see whether the atypical BSE isolates behave similarly to typical BSE isolates in terms of transmissibility and disease pathogenesis. If transmission occurs, tissue distribution comparisons will be made between cattle infected with the atypical BSE isolate and the U.S. BSE isolate. Differences in tissue distribution could require new regulations regarding specific risk material (SRM) removal.

3.Progress Report The aim of the cooperative research project "Study of atypical BSE" led by CEA (Italian Reference Centre for Animal TSE) and USDA is to compare Italian and U.S. Bovine sponigiform encephalopathy (BSE) confirmatory protocols in the detection of classical (C-) and atypical (H- and L-type) BSE cases. In the course of this project samples of Italian C-BSE and Italian L-type BSE (BASE), both frozen and formalin fixed, have been sent to USDA laboratories in Ames, to undergo Western blot and Immunohstochemical (IHC) comparison studies for PrP**Sc detection according to U.S. and Italian methods. In 2007, the comparative study between U.S. and Italian BSE confirmatory protocols was performed. The collaborator sent a scientist to Ames to assist in performing the Italian IHC protocol on the BSE samples chosen for the study. Results obtained showed that the Italian and U.S. IHC procedures were alike in PrP**Sc detection regarding its distribution, deposition pattern and intensity of staining on all the C-, L- and H-type BSE cases considered. In addition, the U.S. protocol evidenced the characteristic presence of plaques in the frontal cortex of the Italian BASE case similar to the Italian protocol. Methods used for monitoring include email, site visits, and periodic written reports. This project addresses NP 103, component 8.

http://www.ars.usda.gov/research/projects/projects.htm?ACCN_NO=408490&showpars=true&fy=2008

Research Project: Study of Atypical Bse Location: Virus and Prion Diseases of Livestock

Project Number: 3625-32000-086-05 Project Type: Specific Cooperative Agreement

Start Date: Sep 15, 2004 End Date: Sep 14, 2009

Objective: The objective of this cooperative research project with Dr. Maria Caramelli from the Italian BSE Reference Laboratory in Turin, Italy, is to conduct comparative studies with the U.S. bovine spongiform encephalopathy (BSE) isolate and the atypical BSE isolates identified in Italy. The studies will cover the following areas: 1. Evaluation of present diagnostics tools used in the U.S. for the detection of atypical BSE cases. 2. Molecular comparison of the U.S. BSE isolate and other typical BSE isolates with atypical BSE cases. 3. Studies on transmissibility and tissue distribution of atypical BSE isolates in cattle and other species.

Approach: This project will be done as a Specific Cooperative Agreement with the Italian BSE Reference Laboratory, Istituto Zooprofilattico Sperimentale del Piemonte, in Turin, Italy. It is essential for the U.S. BSE surveillance program to analyze the effectiveness of the U.S diagnostic tools for detection of atypical cases of BSE. Molecular comparisons of the U.S. BSE isolate with atypical BSE isolates will provide further characterization of the U.S. BSE isolate. Transmission studies are already underway using brain homogenates from atypical BSE cases into mice, cattle and sheep. It will be critical to see whether the atypical BSE isolates behave similarly to typical BSE isolates in terms of transmissibility and disease pathogenesis. If transmission occurs, tissue distribution comparisons will be made between cattle infected with the atypical BSE isolate and the U.S. BSE isolate. Differences in tissue distribution could require new regulations regarding specific risk material (SRM) removal.

http://www.ars.usda.gov/research/projects/projects.htm?ACCN_NO=408490

snip... SEE FULL TEXT ;

http://bse-atypical.blogspot.com/2009/01/bovine-spongiform-encephalopathy-h-bse.html

----- Original Message ----- From: "TERRY SINGELTARY" To: Sent: Friday, February 13, 2009 10:15 AM Subject: [BSE-L] Research Project: Detection of Prp**d in Tissue Samples and Bodily Fluids of Cattle from the German Bse Pathogenesis Study Location: Virus and Prion Diseases of Livestock

-------------------- BSE-L@LISTS.AEGEE.ORG --------------------

Greetings BSE-L,

I sent of this question to Prof. Dr. Hans A. Kretzschmar asking about this study here ;

Research Project: Detection of Prp**d in Tissue Samples and Bodily Fluids of Cattle from the German Bse Pathogenesis Study Location: Virus and Prion Diseases of Livestock

and if there were any results back and if so, what they were, and or when the results might be published. i got no answer at all yet.

so i was just wondering if anyone else on the BSE-L might know something about these results, which were to end in 2009 sometimes ???

Start Date: Sep 15, 2004 End Date: Sep 14, 2009

thank you, kind regards, terry

Wednesday, February 11, 2009 Atypical BSE North America Update February 2009

Both of the BSE cases ascertained in the US native-born cattle were atypical cases (H-type), which contributed to the initial ambiguity of the diagnosis. 174, 185 In Canada, there have been 2 atypical BSE cases in addition to the 14 cases of the classic UK strain of BSE2: one was the H-type, and the other was of the L-type.198

snip...end

source :

Enhanced Abstract Journal of the American Veterinary Medical Association January 1, 2009, Vol. 234, No. 1, Pages 59-72

Bovine spongiform encephalopathy

Jane L. Harman, DVM, PhD; Christopher J. Silva, PhD

http://avmajournals.avma.org/doi/ref/10.2460/javma.234.1.59

Thursday, December 04, 2008 2:37 PM

"we have found that H-BSE can infect humans."

personal communication with Professor Kong. ...TSS

snip...see full text ;

http://bse-atypical.blogspot.com/2009/02/atypical-bse-north-america-update.html

----- Original Message ----- From: TERRY SINGELTARY To: Hans.Kretzschmar@inp.med.uni-muenchen.de Sent: Saturday, January 17, 2009 9:29 AM Subject: Research Project: Detection of Prp**d in Tissue Samples and Bodily Fluids of Cattle from the German Bse Pathogenesis Study Location: Virus and Prion Diseases of Livestock

To :

Prof. Dr. Hans A. Kretzschmar Universität München Institut für Neuropathologie Marchioninistr. 17 81377 München Tel.: 089-7095-4900 Fax: Hans.Kretzschmar@inp.med.uni-muenchen.de

Hello Prof. Dr. Hans A. Kretzschmar,

A kind greetings from Bacliff, Texas. I was hoping you might be able to help me answer a question or two. I am looking for the final results of the PrP**d tissue distribution and migration in cattle orally infected with Bovine spongiform encephalopathy (BSE) of British origin. The details of the study are below, but I was just very curious as to what the final results were, if there were any yet, and or any results at all to date. Also, I would be curious to know if this study included the h and or l atypical BSE, or the atypical Nor98 Scrapie cases in the USA, and if not, considering the h-type BSE and the typical BSE and the atypical Nor-98 Scrapie have been documented in North America, and probably recycled into feed for both animals and humans at some point in time, would it not seem prudent to include these atypical BSE phenotypes in a study such as this ???

Component 8: Countermeasures to Prevent and Control Transmissible Spongiform Encephalopathies

Scrapie

Chronic Wasting Disease (CWD)

Bovine Spongiform Encephalopathy (BSE)

http://www.ars.usda.gov/research/programs/programs.htm?NP_CODE=103&pf=1

any help will be much appreciated.......

many thanks for your work and time. ...

with kindest regards,

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

Research Project: Detection of Prp**d in Tissue Samples and Bodily Fluids of Cattle from the German Bse Pathogenesis Study Location: Virus and Prion Diseases of Livestock

2008 Annual Report

1a.Objectives (from AD-416) The overall objective of this cooperative project is to evaluate PrP**D tissue distribution and migration in cattle orally infected with BSE of British origin. To achieve this objective, the following specific approaches will be conducted: (1) the protein misfolding cyclic amplification (PMCA) assay will be used on blinded replicate aliquots of tissue from animals in the BSE study to independently confirm whether PrP**D can be detected in the tissue samples. The Cooperator will function as lead investigator and ARS will confirm test results for the presence or absence of PrP**D in any given sample. (2) The Cooperator will analyze the proteome in tissue samples by two dimensional SDS PAGE. (3) NADC will evaluate microscopic pathology and visual function of the retina of available animals and tissues to assess PrP**D accumulation and visual function effects.

1b.Approach (from AD-416) The German BSE oral pathogenesis study involves 56 beef cattle orally dosed with BSE containing brain tissue obtained from British cattle. The animal study is managed by the cooperator and various tissues are collected at prescribed times and at necropsy. These tissues will enable the cooperating parties to perform independent confirmation on the presence or absence of PrP**D for verification of PrP**D distribution in tissues. In addition, retinal samples will be analyzed to assess the extent of retinal pathology in infected cattle and visual system function in available remaining live cattle will be tested using electroretinography.

3.Progress Report The overall objective of this cooperative project is to evaluate PrP**d tissue distribution and migration in cattle orally infected with Bovine spongiform encephalopathy (BSE) of British origin. The live-animal phase of this work was completed this year. Samples from this experiment will be brought to the USDA, ARS, National Animal Disease Center for further characterization in the upcoming year. Methods used for monitoring included phone contact, e-mail, and site visits. This project addresses NP 103, component 8.

http://www.ars.usda.gov/research/projects/projects.htm?ACCN_NO=411017&fy=2008

Research Project: Study of Atypical Bse Location: Virus and Prion Diseases of Livestock

Project Number: 3625-32000-086-05 Project Type: Specific Cooperative Agreement

Start Date: Sep 15, 2004 End Date: Sep 14, 2009

Objective: The objective of this cooperative research project with Dr. Maria Caramelli from the Italian BSE Reference Laboratory in Turin, Italy, is to conduct comparative studies with the U.S. bovine spongiform encephalopathy (BSE) isolate and the atypical BSE isolates identified in Italy. The studies will cover the following areas: 1. Evaluation of present diagnostics tools used in the U.S. for the detection of atypical BSE cases. 2. Molecular comparison of the U.S. BSE isolate and other typical BSE isolates with atypical BSE cases. 3. Studies on transmissibility and tissue distribution of atypical BSE isolates in cattle and other species.

Approach: This project will be done as a Specific Cooperative Agreement with the Italian BSE Reference Laboratory, Istituto Zooprofilattico Sperimentale del Piemonte, in Turin, Italy. It is essential for the U.S. BSE surveillance program to analyze the effectiveness of the U.S diagnostic tools for detection of atypical cases of BSE. Molecular comparisons of the U.S. BSE isolate with atypical BSE isolates will provide further characterization of the U.S. BSE isolate. Transmission studies are already underway using brain homogenates from atypical BSE cases into mice, cattle and sheep. It will be critical to see whether the atypical BSE isolates behave similarly to typical BSE isolates in terms of transmissibility and disease pathogenesis. If transmission occurs, tissue distribution comparisons will be made between cattle infected with the atypical BSE isolate and the U.S. BSE isolate. Differences in tissue distribution could require new regulations regarding specific risk material (SRM) removal.

http://www.ars.usda.gov/research/projects/projects.htm?ACCN_NO=408490

CHAPTER 3 Animal Disease Eradication Programs and Control and Certification Programs

snip...

In FY 2007, two field cases, one validation study case, and two RSSS cases were consistent with a variant of the disease known as Nor98 scrapie.1 These five cases originated from flocks in California, Minnesota, Colorado, Wyoming, and Indiana, respectively.

snip...

http://www.aphis.usda.gov/publications/animal_health/content/printable_version/AHR_Web_PDF_07/D_Chapter_3.pdf

NOR-98 Scrapie FY 2008 to date 1

http://www.aphis.usda.gov/animal_health/animal_diseases/scrapie/downloads/monthly_scrapie_rpt.pps

ATYPICAL TSEs in USA CATTLE AND SHEEP ?

http://www.bseinquiry.gov.uk/files/sc/seac17/tab03.pdf

Monday, December 1, 2008

When Atypical Scrapie cross species barriers

http://nor-98.blogspot.com/2008/12/when-atypical-scrapie-cross-species.html

Sunday, December 28, 2008

MAD COW DISEASE USA DECEMBER 28, 2008 an 8 year review of a failed and flawed policy

http://bse-atypical.blogspot.com/2008/12/mad-cow-disease-usa-december-28-2008-8.html

November 25, 2008

Update On Feed Enforcement Activities To Limit The Spread Of BSE

http://madcowfeed.blogspot.com/2008/11/november-2008-update-on-feed.html

TSS

-------------------- BSE-L@LISTS.AEGEE.ORG --------------------

Owens, Julie From: Terry S. Singeltary Sr. [flounder9@verizon.net] Sent: Monday, July 24, 2006 1:09 PM To: FSIS RegulationsComments Subject: [Docket No. FSIS-2006-0011] FSIS Harvard Risk Assessment of Bovine Spongiform Encephalopathy (BSE)

Greetings FSIS, I would kindly like to comment on the following ; [Federal Register: July 12, 2006 (Volume 71, Number 133)] [Notices] [Page 39282-39283] From the Federal Register Online via GPO Access [wais.access.gpo.gov] [DOCID:fr12jy06-35] ----------------------------------------------------------------------- DEPARTMENT OF AGRICULTURE Food Safety and Inspection Service [Docket No. FSIS-2006-0011] Harvard Risk Assessment of Bovine Spongiform Encephalopathy (BSE) Update; Notice of Availability and Technical Meeting AGENCY: Food Safety and Inspection Service, USDA. ACTION: Notice of availability and announcement of technical meeting. -----------------------------------------------------------------------

snip...

http://www.fsis.usda.gov/OPPDE/Comments/2006-0011/2006-0011-1.pdf

same old song and dance, just different day. it will be interesting to know what the final decision of Agricultural Secretary Tom Vilsack will be on this same old song and dance $$$

TSS

Saturday, February 21, 2009 Renderers say industry not prepared for FDA feed ban rule ??? WHAT, IT'S 2009 FOR PETE'S SAKE $$$ Two recent articles caught my eye ;

Renderers say industry not prepared for FDA feed ban rule

Food Chemical News

February 2, 2009

and

BSE, rendering relate to human safety

Emma Struve 02/17/2009


http://madcowfeed.blogspot.com/2009/02/renderers-say-industry-not-prepared-for.html


-------------------- BSE-L@LISTS.AEGEE.ORG --------------------




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