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From: TSS (
Subject: U.S. offers to count a few teeth for Japan, while Japan ponders science
Date: January 15, 2005 at 6:41 pm PST

-------- Original Message --------
Subject: U.S. offers to count a few teeth for Japan, while Japan ponders science
Date: Sat, 15 Jan 2005 19:39:20 -0600
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy

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

U.S. offers strict checks on cattle age to lift Japan's beef ban

Sunday, January 16, 2005 at 07:21 JST

TOKYO — The United States has offered to provide strict verification of
the ages of cattle to encourage Japan to quickly lift its beef import
ban, sources close to bilateral negotiations said Saturday.

But prospects for Washington's early resumption of beef shipments to
Japan remain murky with Japan still cautious about the new proposal, the
sources said.

In addition, even if Japan lifts the ban based on the U.S. proposal,
U.S. beef traders can only recover less than 20% of their exports
enjoyed before the embargo, imposed since the December 2003 discovery of
the first mad cow disease case in the United States.

The latest U.S. proposal thus suggests Washington's desire to reopen
beef trade with Japan anyway, industry officials said.

Japan and the United States have been divided over how to verify the age
of cattle after they struck a compromise in October to relax screening
of all cows and resume imports of U.S. beef by next spring at the
earliest of animals up to 20 months old.

Washington has said ages can be verified by looking into the quality of
beef while Japan has proposed adopting a more scientific method to
verify them, effectively rejecting the U.S. proposal.

"We will decide whether to lift the ban on the basis of scientific
knowledge," said a senior official at the Ministry of Agriculture,
Forestry and Fisheries.

Differences in verification methods are seen as the last hurdle for
Japan's resumption of U.S. beef imports.

U.S. beef experts will visit Tokyo next week and brief their Japanese
counterparts at a government panel on how best to verify the age of
cattle, Japanese officials said earlier.

But even if the Japanese panel accepts the U.S. method, it needs to get
an approval from the Food Safety Commission of the Cabinet Office,
making an early resumption of U.S. beef shipments to Japan unlikely.
(Kyodo News)

Using Dentition to Age Cattle

For many years, producers, veterinarians, and exhibitors (at cattle
shows) have used cattle dentition to make general age determinations.
Dentition will vary from herd-to-herd and animal-to-animal, because of
the animal’s genetics, their diet, and the varied geographical locations
in which they are raised. Despite individual differences, when the age
of an animal is not known, examination of the teeth serves as the best
and most practical method of age determination. This document will serve
as FSIS guidance for aging cattle.







The Agency is issuing this notice to clarify:


that documentation, rather than dentition, can be the primary
means of determining the age of animals and to describe the types
of documentation that have proven to provide an accurate and
reliable basis for making this determination.


how inspection program personnel should verify that sanitation of
equipment has been properly conducted when there is a possibility
of contamination by specified risk materials (SRMs)

PART I – Determination of the Age of Cattle

The age of cattle is determinative of which parts of cattle are SRMs as
defined in 9 CFR 310.22. The guidance provided by the following
questions and answers clarifies the types of records that an
establishment may use to identify and to separate cattle that are
younger than 30 months of age from cattle that are 30 months of age and
older. VMOs are to conduct the procedures found in FSIS Notice 9-04
to verify
that an establishment is following the procedures, as incorporated into
its HACCP, Sanitation SOPs, or prerequisite program for determining the
age of cattle.

Documentation, rather than dentition, provides the best means for
determining the age of cattle. While dentition can be useful in the
absence of documentation, it only provides a means of making general
determinations about age. Documentation provides the means to
specifically age the animals. Thus, establishments that separate cattle
based on whether they are younger or older than 30 months of age may
rely on documentation. This does not preclude the use of dentition if
documentation is not available.

As set out in FSIS Notice 9-04
, inspection
program personnel are to verify that if an establishment separates
cattle that are younger than 30 months of age from cattle that are 30
months of age and older it follows its procedures for identifying and
separating the cattle and is making appropriate determinations.

While performing verification activities related to the age of cattle,
inspection program personnel are to verify, in establishments using
documentation, that the records support the establishment’s
determinations. If the records do not support the determinations,
inspection program personnel are to verify that the establishment takes
the appropriate corrective action under 9 CFR 417.3(a) or (b).

NOTE: Hands-on dentition examinations are not to be used to determine
the adequacy of the documentation. If a VMO is unsure as to whether the
plant’s procedures are adequate, he or she is to contact the Technical
Service Center for technical assistance.

While performing verification activities related to the age of cattle,
inspection program personnel are to verify, in establishments using
dentition, that the establishment’s determinations are consistent with
the guidance provide in FSIS 5-04
. If the
determinations made by the establishment are not consistent with the
guidelines, inspection program personnel are to verify that the
establishment takes the appropriate corrective action under 9 CFR
417.3(a) or (b).


Question: What are the characteristics of documentation that have proven
to be an accurate and reliable means for determining the age of cattle
offered for slaughter?

Answer: The characteristics of documentation that is most useful in
determining the age of cattle offered for slaughter are:


Documentation (e.g., records or certificates) that can be related
to individual cattle and not just information about an entire lot,


Documentation that provides evidence of age that goes back to the
farm where the cattle were born, including the name and the
address of the owner.

Question: What are examples of accurate and reliable documentation from
the farm or ranch where the cattle were born?

Answer: The following are examples of farm or ranch documentation:


pregnancy check records (checks for individual cows and the
results of the check for each one),


records of which cows were in a herd when a bull was put in with
the herd, and when the bull was removed from the herd (to
determine start of gestation),


records that document when individual cows were artificially


calving records that document where (i.e., name and address of the
producer) and when a calf was born, or


identification applied to calves (e.g., records from branding,
electronic ear IDs, or ear tags).

Question: What are examples of accurate and reliable documentation from
the feedlot where the cattle were held?

Answer: The following are examples of feedlot documentation:


Documentation that identifies the date that the cattle entered the
feedlot and were given individual identification (e.g., eartags)
and documentation that the producer provides with the cattle as
they enter feedlot that includes on-farm records, and


the cattle have individual identification (e.g., eartags) that
were placed on them on the farm, or


the entire herd of cattle are certified as being born on the
farm during a specific range (e.g., certification that a group
of Angus cattle were born during the calving season of Spring
200X or Fall 200X) and based on the information the feedlot
identifies each animal individually (e.g., eartags).

NOTE: When calving birthing ranges are provided, the oldest possible age
based on the ranges should be assigned to the group of cattle.

2. Medication records or worming records at the feedlot that tie back
to when the animal was received by the feedlot and identify the
producer. The feedlot could use these records to identify the
producer, who then could state when the cattle were born.

When an establishment is slaughtering or processing cattle 30 months and
older and cattle younger than 30 months of age, what should inspection
program personnel look for when verifying that the equipment (e.g., saws
and knives) is properly cleaned and sanitized between carcasses or parts?

If separate equipment is used for cutting through SRMs OR if the
establishment segregates the two age groups and slaughters or processes
the younger group first, then routine operational sanitation procedures
apply (in accordance with 9 CFR Part 416). For example:

* The establishment uses a dedicated saw to split the carcass
from cattle 30 months and older.

* The establishment uses a knife to cut through the edible
portions of the carcass and a separate saw to only cut through
the vertebral column (e.g. when quartering a carcass).

Any equipment that is used to cut through SRMs (vertebral column, spinal
cord, dorsal root ganglion, etc. of cattle 30 months and older) must be
cleaned and sanitized before being used on carcasses or parts from
cattle less than 30 months. For example:

* Splitting carcasses of mixed age groups in the slaughter

* Breaking quarters of mixed age groups into smaller portions in
the fabrication department.

* A knife that is used to sever the head from the carcasses of
mixed age groups.

NOTE: The equipment need not be cleaned to a pre-operational state
before sanitizing. The organic materials must be removed to ensure
adequate sanitization (this is similar to what is required when a saw
cuts through an abscess).

For technical assistance contact the Technical Service Center.

/s/ Philip S. Derfler

Assistant Administrator
Office of Policy and Program Development

DISTRIBUTION: Inspection Offices; T/A Inspectors; Plant Mgt; T/A Plant
Mgt; TRA; ABB; TSC, Import Offices NOTICE EXPIRES: 3/01/05 OPI: OPPD

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