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From: TSS (216-119-143-200.ipset23.wt.net)
Subject: Re: USDA document cites young mad cow cases and concerns for TSE in young bovine
Date: August 23, 2004 at 11:18 am PST

In Reply to: Re: USDA document cites young mad cow cases and concerns for TSE in young bovine posted by TSS on August 23, 2004 at 10:06 am:

I would like to kindly comment on Docket No. 03-080-1

USDA ISSUES PROPOSED RULE TO ALLOW LIVE ANIMAL IMPORTS FROM CANADA ;

>Under this proposal, ruminant and ruminant products eligible for entry into
>the United States from a BSE minimal risk region would include:
>
>1) bovine
>animals less than 30 months of age for immediate slaughter;
>
>2) bovine
>animals for feeding to be moved to a designated feedlot and then to
>slaughter at less than 30 months of age;
>
snip...

>6) fresh (chilled or frozen)
>meat from bovines less than 30 months of age; 7) fresh (chilled or frozen)
>whole or half carcasses of bovines less than 30 months of age; 8) fresh
>(chilled or frozen) bovine liver; 9) fresh (chilled or frozen) bovine
>tongues;


the myth that cattle under 30 months of age are free from BSE/TSE is
just that, a myth,
and it's a false myth !

the youngest age of BSE case to date is 20 months old; As at: 31 May
2003 Year of onset Age youngest case (mnths) Age 2nd youngest case
(mnths) Age 2nd oldest case (yrs.mnths) Age oldest case (yrs.mnths) 1986
30 33 5.03 5.07 1987 30 31 9.09 10.00 1988 24 27 10.02 11.01(2) 1989 21
24(4) 12.00(2) 15.04 1990 24(2) 26 13.03 14.00 1991 24 26(3) 14.02 17.05
1992 20 26 15.02 16.02 1993 29 30(3) 14.10 18.10 1994 30(2) 31(2) 14.05
16.07 1995 24 32 14.09 15.05 1996 29 30 15.07 17.02 1997 37(7) 38(3)
14.09 15.01 1998 34 36 14.07 15.05 1999 39(2) 41 13.07 13.10 2000 40 42
17.08 19.09 2001 48(2) 56 14.10 14.11 2002 51 52 15.08 15.09(2) 2003 50
62 11.11 14.11

http://www.defra.gov.uk/animalh/bse/bse-statistics/bse/yng-old.html

http://www.defra.gov.uk/animalh/bse/index.html

The implications of the Swiss result for Britain, which has had the most
BSE, are complex. Only cattle aged 30 months or younger are eaten in
Britain, on the assumption, based on feeding trials, that cattle of that
age, even if they were infected as calves, have not yet accumulated
enough prions to be infectious. But the youngest cow to develop BSE on
record in Britain was 20 months old, showing some are fast incubators.
Models predict that 200-300 cattle under 30 months per year are infected
with BSE and enter the food chain currently in Britain. Of these 3-5
could be fast incubators and carrying detectable quantities of prion.

http://www.sare.org/htdocs/hypermail/html-home/28-html/0359.html

> 3) sheep and goats less than 12
>months of age for immediate slaughter; 4) sheep and goats for feeding to be
>moved to a designated feedlot and then to slaughter at less than 12 months
>of age;
>
even if one believes that scrapie does not transmit to humans (without
scientific proof and realizing
scrapie transmits to primates) what about the potential for BSE in
sheep/goats and what about the
many different tissues that are infectious ?

Research into sheep TSEs - audit reports & IAH's response


http://www.defra.gov.uk/animalh/bse/bse-publications/bse-publications-index.html#audit

>5) cervids for immediate slaughter;
>

are you going to test all cervids coming into the USA from Canada for
CWD/TSEs ?
(this should be mandatory).


Commentary by European Microbiologist Roland Heynkes

August 26, 2003 Posted to BSE-L@UNI-KARLSRUHE.DE

> SECRETARY VENEMAN: "Well, thank you, Tony, for your question. As
> you know, we've spent a considerable amount of time on this issue
> of Canada and the single case of BSE. The announcement we made on
> the 8th had several aspects. One was we were going to use a permit
> process to open the border with respect to boxed beef from animals
> under 30 months. As you know, animals under 30 months are generally
> thought to be of virtually no risk of having BSE. Now, we will also
> begin a regulatory process to look at the lowest risk animals,
> those under 30 months. That regulation is in process at this point,
> but it will take some time to actually do the regulation. That will
> include a risk assessment and so forth.
>

in my opinion this is a statement with intent to deceive and it is not
correct. There have been several cases of clinical BSE in British cattle
under 30 months and it is therefore hardly possible to think that cattle
under 30 months have virtually no risk of having BSE. In 1988 the
youngest British BSE case was 24, the second youngest 27 months old. In
1989 the youngest British BSE case was 21 and there were 4 cases only 24
months old. In 1990 there were two cases only 24 and one 26 months old.
In 1991 the youngest British BSE case was 24 and there were 3 cases only
26 months old. In 1992 the youngest British BSE case was 20!, the second
youngest 26 months old. In 1993 there was was a 29 months old case, in
1995 the UK had a 24 months old case and in 1996 one British BSE case
was 29 months old.

http://www.defra.gov.uk/animalh/bse/bse-statistics/bse/yng-old.html

But mainly this wrong statement is misleading, because not the
clinically sick cows are the problem for consumers. The real problem are
those animals that became infected as calves and are still incubating
the infectivity during the incubation time of 5-6 years. For consumers
it is therefore totally irrelevant that cattle are at low risk to reach
the clinical stage before being 30 months old. Important for consumers
is the fact that most British BSE cases became infected as calves
(http://www.heynkes.de/peaks.htm) and that infected calves are already
amplifying the infectivity. The advantage of young calves for consumers
is that the infectivity in infected animals is low and still
concentrated around the gastro- intestinal tract. But this is not
necessarily true for bulls, which are usually slaughtered when they are
19-22 months old. They are too young to give positive results in the
actual BSE tests, but they might be infective for consumers.

For US consumers it is of no importance whether a BSE-infected Canadian
cow will show the first symptoms before or after it becomes 30 months
old. Interesting for the consumers is only

1) if cattle are infected or not,

2) where in the animal is how much of the infectivity and

3) what happens to the infectivity during slaughtering?

If the US government is really interested to reduce consumers risk, it
has to

1) stop cannibalism among farm animals (no farm animal protein and fat
in feeding stuff for farm animals, no possibility of cross contamination
of concentrate feed in mills and no lambing on pastures where scrapie
might be a problem)

2) test slaughter cattle above 24 months for BSE,

3) avoid contamination of the beef with prions from CNS by changing
slaughter methods (electrical stunning instead of captive bolt, no
immobilisation with a pithing rod, no spreading of infectivity by sawing
through the spinal cord),

4) destroy the high risk materials (brain, eyes, spinal cord, dorsal
root ganglia and other peripheral ganglia, nervous and lymphatic tissue
associated with intestine)

5) commit the whole chain from abattoir to counter in shop and
restaurant to label products from cattle and sheep, because it is only a
myth that scrapie is less infective than BSE.

In addition the US government should test all cattle and sheep which
died or had to be killed because of illness. This measure should be hold
out for at least one year in order to see the real BSE- and
scrapie-incidence in the USA....


Microbiologist Roland Heynkes

http://www.heynkes.de/default.htm

Furthermore, for the USA to continue to flagrantly ignore the findings
from Collinge/Asante et al
that BSE transmission to the 129-methionine genotype can lead to an
alternate phenotype that is
indistinguishable from type 2 PrPSc, the commonest _sporadic_ CJD. These
findings could have
major implications for the medical and surgical arena and human health.
this type sporadic CJD
is very prevalent in the USA ;

http://www.fda.gov/ohrms/dockets/ac/03/slides/3923s1_OPH.htm

snip...FULL TEXT;

Docket No. 03-080-1 -- USDA ISSUES PROPOSED RULE TO ALLOW LIVE ANIMAL

IMPORTS FROM CANADA [takes a few minutes to load]


https://web01.aphis.usda.gov/BSEcom.nsf/BSEFrameset?OpenFrameSet&Frame=BottomFrame&Src=_25t156hb3dtmisrjjconjcc9n6ph6ccr66oqjgdpo74qm6e1l68qjcp9hc4o30dhgckq34phfc8rjgoj16orjep9ic8o66c9i64s3achl6pi68cpg60r38eb675i3ujrgcln48rr3elmmarjk4p0nat3f8pp62rb5cg0_

TSS





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