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######## Bovine Spongiform Encephalopathy #########
UNITED STATES DEPARTMENT OF AGRICULTURE
FOOD SAFETY AND INSPECTION SERVICE
WASHINGTON, DC FSIS NOTICE
29-04
5-27-04
QUESTIONS AND ANSWERS FOR FSIS NOTICE 28-04 REGARDING ANTE-MORTEM
CONDEMNED CATTLE
http://www.fsis.usda.gov/Frame/FrameRedirect.asp?main=http://www.fsis.usda.gov/OPPDE/rdad/FSISNotices/29-04.htm
TSS
1.
PURPOSE
This notice provides clarification to FSIS Notice 28-04
,
FSIS Sample Collection From Cattle Condemned During Ante-Mortem
Inspection for the Bovine Spongiform Encepholophathy (BSE) Surveillance
Program. The following issues are addressed:
1.
Expectations regarding the Animal and Plant Health Inspection
(APHIS) arrangements, through the APHIS Area
Veterinarian-in-Charge (AVIC), with establishments for APHIS to
test condemned cattle at a central location,
2.
Additional questions FSIS Public Health Veterinarian (PHV) should
seek answers to either at the awareness meeting or at the on-going
weekly meetings,
3.
Why FSIS Notice 28-04 stated FSIS would not collect brain samples
from cattle condemned on ante-mortem inspection that the
establishment elects to have treated pursuant to 9 CFR 309.13(b),
4.
A corrected form number for reimbursement associated with FSIS
sample collections, and
5.
Miscellaneous questions.
Also, this notice issues a revised list of the laboratories where PHVs
are to send samples.
2.
QUESTION AND ANWSERS FOR EACH ISSUE
1.
Issue 1. Expectations regarding the APHIS arrangements with
establishments to test condemned cattle at a central location
Question: What controls does FSIS expect the establishment
to have in place in order for FSIS to recognize an APHIS
arrangement to have FSIS condemned cattle transported
off-site from the establishment to an APHIS central sample
collection point?
Response: FSIS will recognize such arrangements if
establishments provide procedures for ensuring that the PHV
will be notified that the condemned cattle are delivered to
the APHIS central sample collection point for brain sample
collection. The notification by the establishment provides
information that is required under the recordkeeping
requirements in 9 CFR 320.1. NOTE: Condemned cattle will
continue to be denatured in the presence of an inspector at
the establishment, and the U.S. Condemnation tag will be
removed by the FSIS PHV. The FSIS PHV will not be able to
close out the files on these condemned cattle, however,
until notified by the establishment that these condemned
cattle were delivered to the APHIS central sample collection
point.
In order for the FSIS PHV to recognize the arrangement answers to
the following issues should be provided:
1.
The process for denaturing the cattle in a manner that would
not affect the collection of a brain sample,
2.
How the FSIS condemnation tag numbers (the tag are removed
only by FSIS) will remain associated with the condemned cattle
(this does not mean physically attached),
3.
Who will remove the cattle from the establishment and
transport it to the APHIS central sample collection point.
(The transporter of the condemned cattle is to be registered
with FSIS in accordance with 320.5),
4.
The location of the APHIS central sample collection point,
including the address and a contact at the location,
5.
How the APHIS sample collection representative is made aware
that FSIS condemned cattle are being delivered to the APHIS
central sample collection point, and
6.
How the establishment will provide notification to the FSIS
PHV that the condemned cattle were delivered to the APHIS
central sample collection point.
Question 2: What will happen if an establishment that chooses to
send condemned cattle to an APHIS central sample collection
point fails to have or maintain appropriate procedures and
documentation that demonstrates that the cattle were delivered
and arrived at the APHIS central collection point?
Response: The failure of the establishment to ensure that
condemned and denatured cattle are appropriately controlled,
tracked, and delivered to the central collection point will
result in the Agency no longer allowing condemned cattle to be
removed from the premises for sampling and may be treated as a
prohibited act, in violation of the Federal Meat Inspection Act,
21 U.S.C. 610, and the regulations that FSIS has adopted under
21 U.S.C. 603(a) and 9 CFR 314.9.
1.
Issue 2. Questions that the (PHV) should ask the establishment
management at the awareness meeting or at the on-going weekly
meeting.
Answers to the following questions are necessary to better
understand the establishment’s identification and control
procedures for dead cattle, non-ambulatory disabled cattle,
and condemned ambulatory cattle:
For dead cattle
1.
Does the establishment have arrangements with APHIS for
off-site sample collection? (If yes see II. A. of this
notice).
2.
Will dead cattle be off-loaded at the official premises,
or will they be transported to an APHIS central sample
collection point?
3.
If dead cattle are off-loaded in an establishment’s
holding pens, how will the cattle be segregated to
provide for sample collection?
4.
Has an appropriate area been designated for collecting
the brain sample from condemned dead cattle?
5.
Who will be removing the head of condemned cattle?
6.
Has a procedure been established for containing the
condemned cattle (and parts, including blood) during
sample collection in order to prevent an insanitary
condition?
7.
Has a procedure been established to properly clean and
sanitize the sampling area? [NOTE: Special cleaning and
sanitization of pens and holding areas is not required;
normal cleaning is sufficient.]
8.
Will the sampled cattle (carcass and head) be held
pending receipt of laboratory results, or,
alternatively, how will the sampled cattle be disposed of?
[NOTE: There is no requirement by FSIS to hold the
sampled cattle after the brain sample has been
collected. However, the establishment should contact the
APHIS AVIC if there is a problem with the timely pick-up
or removal of sampled cattle.]
For non-ambulatory disabled (live) cattle
1.
Where will cattle be euthanized (e.g., in the
establishment’s holding pens or on the transport
vehicle)? [NOTE: Condemned cattle must be euthanized at
the establishment, under the supervision of FSIS, in
order to ensure that the cattle are humanely handled.
Condemned cattle cannot be removed from the
establishment and euthanized at an APHIS central sample
collection point. The establishment should ensure that
the method of euthanization does not impact the quality
of the brain sample
(e.g., special low velocity 22 ammunition into the
forehead of the condemned cattle would kill the animal,
but would NOT damage the part of the brain for BSE
sampling; a bigger shot would have the capacity to
destroy more of the brain, possibly the brainstem, and
would impact the quality of the brain sample).]
2.
Are all provisions for handling dead cattle being followed?
For condemned ambulatory (live) cattle
Are all provisions for handling non-ambulatory disabled
(live) cattle being followed?
1. Issue 3. Why FSIS Notice 28-04 stated that FSIS would not
collect brain samples from cattle condemned on ante-mortem
inspection that the establishment elects to have treated
pursuant to 9 CFR 309.13(b).
3.
Question: In the May 20, 2004 memorandum from the APHIS and
FSIS Administrators
regarding the BSE sampling of condemned cattle, there was no
mention of an exemption from sampling for cattle being treated
pursuant to 9 CFR 309.13(b). However, FSIS Notice 28-04, also
dated May 20, 2004, does include the exemption (see Section V.
A.). Which policy statement is applicable to FSIS?
Response: FSIS Notice 28-04 contains the procedures that FSIS
inspection program personnel should follow. Although the
memorandum from the Administrators did not specifically
address this exemption, the exemption was already provided for
in FSIS regulations and was not deemed necessary to include in
the memorandum. A copy of the memorandum is attached.
D. Issue 4. Corrected form number for reimbursement associated
with FSIS sample collections.
Question: What is the correct form number to be completed by
FSIS in order to ensure that FSIS gets reimbursed by APHIS for
brain sample collection?
Response: The corrected form number is FSIS Form 5000-11 (BSE
Sampling Tracking Sheet). FSIS Notice 28-04 incorrectly listed
the form number as FSIS Form 5000-9.
E. Issue 5. Miscellaneous questions.
Question 1: Do cattle have to be presented for ante-mortem
inspection in order to be subject to sample collection?
Response: All cattle that are off-loaded from transportation
vehicles are considered to be presented for inspection and,
therefore, are to be test under FSIS
Notice 28-04, where applicable. Dead cattle that are
off-loaded to facilitate the off-loading of live animals, but
that will be re-loaded onto the transport vehicle, are not
subject to sampling by FSIS.
Question 2: Is the PHV responsible for determining whether the
sample is of acceptable quality, (i.e., whether autolysis has
not occurred), before submitting a sample to the laboratory?
Response: The PHV is not responsible for making these
determinations. All samples are to be taken and submitted to
the laboratory.
Question 3: Can PHVs get rabies vaccinations?
Response: Yes, however rabies vaccinations are volunatry. Only
PHVs who are actually involved with BSE sample collection will
be eligible for reimbursement on the vaccination series. PHVs
should make arrangements for the vaccinations with their
private physician. PHVs should contact their Front-line
supervisor for approval on reimbursement prior to beginning
the three shot vaccination series.
Philip S. Derfler /s/
Assistant Administrator
Office of Policy, Program, and Employee Development
DISTRIBUTION: Inspection Offices; T/A Inspectors; Plant Mgt; TRA; ABB;
TSC; Import Offices
NOTICE EXPIRES: 6-1-05
OPI: OPPED
Attachment
Designated Laboratories for BSE Sample Submission
State where sample was collected
Designated laboratory
Arizona, California, Nevada CAHFS-Thurman Bldg.
West Health Science Drive
UC Davis
Davis, CA 95616
Colorado, Kansas, Missouri, Nebraska, North Dakota, South Dakota, Utah,
Wyoming
Dr. Barbara Powers
CO State University
Vet Diagnostic Laboratory
Ft. Collins CO 80523
Arkansas, Louisiana, New Mexico, Texas Texas A & M
TVMDL
Pathology Department
1 Sippel Road
College Station, TX 77843
Minnesota (or NVSL), Wisconsin
Dr. Phil Bochsler
WVDL - TSE Laboratory
6101 Mineral Point Rd.
Madison, WI 53705
Idaho, Montana, Oregon, Washington
Washington State University WADDL
Animal Disease Diagnostic Laboratory
Bazzler Bustad Hall Room 155-N
Pullman WA 99164-7034
Alabama, Florida , Georgia, Mississippi, North Carolina, Oklahoma, South
Carolina, Tennessee, Virginia
Athens Diagnostic Laboratory
College of Vet Med
Doris Miller
University of Georgia
Athens, GA 30602
Connecticut, Delaware, Maine, Maryland, Massachusetts, Michigan, New
Hampshire, New Jersey, New York, Pennsylvania (all Pennsylvania), Rhode
Island, Vermont Cornell University
Animal Health Diagnostic Laboratory
Department of Biomedical Sciences
S2-124 Schurman Hall
Ithaca, NY 14853
Alaska, Hawaii, Illinois, Indiana, Iowa, Kentucky, Minnesota (or WI),
Ohio, Puerto Rico, West Virginia USDA, APHIS, National Veterinary Services
Laboratory (NVSL)
Ames, IA
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