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From: TSS (216-119-143-195.ipset23.wt.net)
Subject: Re: BSE NORTH AMERICA ''CANADIAN UPDATE'' Latest Information (as of January 21, 2005 - 16:00 EST)
Date: January 22, 2005 at 7:27 pm PST

In Reply to: BSE NORTH AMERICA ''CANADIAN UPDATE'' Latest Information (as of January 21, 2005 - 16:00 EST) posted by Terry S. Singeltary Sr. on January 22, 2005 at 7:25 pm:

SOME FACTS PLEASE ;


Working Group Report on
the Assessment of the Geographical BSE-Risk (GBR) of
MEXICO
2004

snip...

- 11 -
4. CONCLUSION ON THE RESULTING RISKS
4.1 Interaction of stability and challenges
In conclusion, the stability of the Mexico BSE/cattle system in the past and the
external challenges the system has coped with are summarized in the table 5 below.
From the interaction of the two parameters stability and external challenge a
conclusion is drawn on the level of internal challenge that emerged and had to be
met by the system, in addition to external challenges that occurred.
INTERACTION OF STABILITY AND EXTERNAL CHALLENGE IN MEXICO
Period Stability External Challenge Internal challenge
1980 to 1985
1986 to 1990
Negligible Highly unlikely
1991 to 1995 Very high
1996 to 2000
2001 to 2003
Very unstable
Extremely high
Likely to be present and growing
since 1993
Table 5: Internal challenge resulting from the interaction of the external challenge and stability.
The internal challenge level is determined according to guidance given in the SSC - opinion on
the GBR of July 2000 (as updated in 2002).
An external challenge resulting from cattle import could only lead to an internal
challenge once imported infected cattle were rendered for feed and this contaminated
feed reached domestic cattle. Cattle imported for slaughter would normally be
slaughtered at an age too young to harbour large amounts of BSE infectivity or to
show signs, even if infected prior to import. Breeding cattle, however, would
normally live much longer and only animals having problems would be slaughtered
younger. If being 4 - 6 years old when slaughtered, they could suffer from early signs
of BSE, being approaching the end of the BSE - incubation period. In that case, they
Annex to the EFSA Scientific Report (2004) 4, 1-13 on the Assessment of the
Geographical BSE Risk of Mexico
would harbour, while being pre - clinical, as much infectivity as a clinical BSE case.
Hence cattle imports could have led to an internal challenge about 3 years after the
import of breeding cattle (that are normally imported at 20 - 24 months of age) that
could have been infected prior to import. In case of Mexico this implies that an
internal challenge caused by live cattle imports (predominantly from USA or Canada)
first occurred in the mid to late 1990s and continued to the present.
On the other hand imports of contaminated MBM would lead to an internal challenge
in the year of import, if fed to cattle. The feeding system is of utmost importance in
this context. If it could be excluded that imported, potentially contaminated feed stuffs
reached cattle, such imports might not lead to an internal challenge at all. In case of
Mexico this implies that an internal challenge caused by MBM imports
(predominantly from USA or Canada) first occurred around 1993 and continued to the
present.
In view of the above - described consideration the combination of the very / extremely
high external challenges with a very unstable system makes the occurrence of an
internal challenge likely in Mexico from approximately 1993 onwards.
4.2 Risk that BSE infectivity entered processing
It is likely that BSE infectivity entered processing at the time of imported at - risk
MBM (1993) and at the time of slaughter of imported live at - risk cattle (mid to late
1990s). The high level of external challenge is maintained throughout the reference
period, and the system has not been made stable, leading to increased internal
challenge.
4.3 Risk that BSE infectivity was recycled and propagated
It is likely that BSE infectivity was recycled and propagated from approximately
1993. The risk has since grown consistently due to a maintained internal and external
challenge and lack of a stable system.
5. CONCLUSION ON THE GEOGRAPHICAL BSE - RISK
5.1 The current GBR as function of the past stability and challenge
The current geographical BSE risk (GBR) level is III, i.e. it is likely but not confirmed
that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent.

snip...

MEXICO

http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/scr_annexes/566/sr04_biohaz02_mexico_report_annex_en1.pdf


Working Group Report on
the Assessment of the Geographical BSE-Risk (GBR) of
CANADA
2004

snip...

- 13 -
4. CONCLUSION ON THE RESULTING RISKS
4.1 Interaction of stability and challenges
In conclusion, the stability of the Canada BSE/cattle system in the past and the external
challenges the system has coped with are summarised in the table 6.
INTERACTION OF STABILITY AND EXTERNAL CHALLENGE IN CANADA
Period Stability External Challenge Internal challenge
1980 to 1990 Low Unlikely but not excluded
1991 to 1995 High
1996 to 2000 Extremely high
Likely and rapidly growing
2001 to 2003
Extremely
unstable
Very high Confirmed at a lower level
Table 6: Internal challenge resulting from the interaction of the external challenge and stability. The
internal challenge level is determined according to guidance given in the SSC-opinion on the GBR of
July 2000 (as updated in 2002).
From the interaction of the two parameters stability and external challenge a
conclusion is drawn on the level of internal challenge that emerged and had to be met
by the system, in addition to external challenges that occurred.
An external challenge resulting from cattle import could only lead to an internal
challenge once imported infected cattle were rendered for feed and this contaminated
feed reached domestic cattle. Cattle imported for slaughter would normally be
slaughtered at an age too young to harbour plenty of BSE infectivity or to show signs,
even if infected prior to import. Breeding cattle, however, would normally live much
longer and only animals having problems would be slaughtered younger. If being 4-6
years old when slaughtered, they could suffer from early signs of BSE, being
approaching the end of the BSE-incubation period. In that case, they would harbour,
while being pre-clinical, as much infectivity as a clinical BSE case. Hence cattle imports
could have led to an internal challenge about 3 years after the import of breeding cattle
(that are normally imported at 20-24 months of age) that could have been infected prior
to import. In case of Canada this implies that cattle imported in the mid eighties could
have been rendered in the late eighties and therefore led to an internal challenge in the
early 90s.
On the other hand imports of contaminated MBM would lead to an internal challenge in
the year of import, if fed to cattle. The feeding system is of utmost importance in this
context. If it could be excluded that imported, potentially contaminated feed stuffs
reached cattle, such imports might not lead to an internal challenge at all. In case of
Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the
Geographical BSE Risk of Canada
Canada this implies that it was possible that imported MBM reached domestic cattle and
lead to an internal challenge in the early 90s.
4.2 Risk that BSE infectivity entered processing
A certain risk that BSE-infected cattle entered processing in Canada, and were at least
partly rendered for feed, occurred in the early 1990s when cattle imported from UK in
the mid 80s could have been slaughtered. This risk continued to exist, and grew
significantly in the mid 90s when domestic cattle, infected by imported MBM, reached
processing. Given the low stability of the system, the risk increased over the years with
continued imports of cattle and MBM from BSE risk countries.
4.3 Risk that BSE infectivity was recycled and propagated
A risk that BSE-infectivity was recycled and propagated exists since a processing risk
first appeared; i.e. in the early 90s. Until today this risk persists and increases fast
because of the extremely unstable BSE/cattle system in Canada.
5. CONCLUSION ON THE GEOGRAPHICAL BSE-RISK
5.1 The current GBR as function of the past stability and challenge
The current geographical BSE-risk (GBR) level is III, i.e. it is confirmed at a lower level
that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent.
This assessment deviates from the previous assessment (SSC opinion, 2000) because at
that time several exporting countries were not considered a potential risk.
into account.
GBR.

snip...


http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/scr_annexes/563/sr02_biohaz02_canada_report_annex_en1.pdf


Working Group Report on
the Assessment of the Geographical BSE-Risk (GBR) of
UNITED STATES OF AMERICA
2004

snip...

- 14 -
4. CONCLUSION ON THE RESULTING RISKS
4.1 Interaction of stability and challenges
In conclusion, the stability of the USA BSE/cattle system in the past and the external
challenge the system has coped with, are summarised in table 5 below.
From the interaction of the two parameters stability and external challenge a
conclusion is drawn on the level of internal challenge that emerged and had to be
met by the system, in addition to external challenges that occurred.
Interaction of stability and external challenge in the USA
Period Stability External Challenge Internal challenge
1980 to
1985
1986 to
1990
Moderate Possibly present
1991 to
1995 Very high
1996 to
2000
2001 to
2003
Extremely
unstable
Extremely high
Likely to be present and
growing
Table 5: Internal challenge resulting from the interaction of the external challenge and stability.
The internal challenge level is determined according to guidance given in the SSC-opinion on
the GBR of July 2000 (as updated in 2002).
An external challenge resulting from cattle import could only lead to an internal
challenge once imported infected cattle were rendered for feed and this contaminated
feed reached domestic cattle. Cattle imported for slaughter would normally be
slaughtered at an age too young to harbour plenty of BSE infectivity or to show signs,
even if infected prior to import. Breeding cattle, however, would normally live much
longer and only animals having problems would be slaughtered younger. If being 4-6
years old when slaughtered, they could suffer from early signs of BSE, being
approaching the end of the BSE-incubation period. In that case, they would harbour,
while being pre-clinical, as much infectivity as a clinical BSE case. Hence cattle
imports could have led to an internal challenge about 3 years after the import of
Annex to the EFSA Scientific Report (2004) 3, 1-17 on the Assessment of the
Geographical BSE Risk of USA
- 15 -
breeding cattle (that are normally imported at 20-24 months of age) that could have
been infected prior to import.
In the case of the USA a few potentially infected cattle were imported from the UK
and more from other BSE-risk countries. Furthermore, large numbers of imported
animals came from Canada. This implies that cattle imported in the mid eighties could
have been rendered in the late eighties and therefore led to an internal challenge in the
early 90s.
On the other hand imports of contaminated MBM would lead to an internal challenge
in the year of import, if fed to cattle. The feeding system is of utmost importance in
this context. If it could be excluded that imported, potentially contaminated feed stuffs
reached cattle, such imports might not lead to an internal challenge at all.
In case of the USA this implies that it was possible that imported MBM reached
domestic cattle and lead to an internal challenge in the early 90s.
If Canadian imports would be excluded from this assessment, we find that the USA
receives a moderate challenge for all 5-year intervals since 1980, a high challenge
between 1985 and 2000 and a low challenge thereafter. If combining these moderate
to high challenges due to imports with the extremely unstable system, the conclusion
would still be that the occurrence of an internal challenge is possible during the early
80s and likely in the late 80s.
4.2 Risk that BSE infectivity entered processing
A processing risk developed in the late 80s/early 90s when cattle imports from BSE
risk countries were slaughtered or died and were processed (partly) into feed, together
with some imports of MBM. This risk continued to exist, and grew significantly in the
mid 90s when domestic cattle, infected by imported MBM, reached processing. Given
the low stability of the system, the risk increased over the years with continued
imports of cattle and MBM from BSE risk countries.
4.3 Risk that BSE infectivity was recycled and propagated
A risk that BSE-infectivity was recycled and propagated exists since a processing risk
first appeared, i.e. in the early 90s. Until today this risk persists and increases fast
because of the extremely/very unstable BSE/cattle system in the USA.
5. CONCLUSION ON THE GEOGRAPHICAL BSE-RISK
5.1 The current GBR as function of the past stability and challenge
" The current geographical BSE risk (GBR) level is III, i.e. it is likely but not
confirmed that domestic cattle are (clinically or pre-clinically) infected with the
BSE-agent.
Note1: It is also worth noting that the current GBR conclusions are not dependent on
the large exchange of imports between USA and Canada. External challenge due to
exports to the USA from European countries varied from moderate to high. These
Annex to the EFSA Scientific Report (2004) 3, 1-17 on the Assessment of the
Geographical BSE Risk of USA
challenges indicate that it was likely that BSE infectivity was introduced into the
North American continent.
Note2: This assessment deviates from the previous assessment (SSC opinion, 2000)
because at that time several exporting countries were not considered a potential risk.
include
feed,

snip...

http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/scr_annexes/574/sr03_biohaz02_usa_report_annex_en1.pdf

From: Terry S. Singeltary Sr. [flounder@wt.net]
Sent: Tuesday, July 29, 2003 1:03 PM
To: fdadockets@oc.fda.gov
Cc: ggraber@cvm.fda.gov; Linda.Grassie@fda.gov; BSE-L
Subject: Docket No. 2003N-0312 Animal Feed Safety System [TSS SUBMISSION
TO DOCKET 2003N-0312]

Greetings FDA,

snip...

PLUS, if the USA continues to flagrantly ignore the _documented_ science to date about the known TSEs in the USA (let alone the undocumented TSEs in cattle), it is my opinion, every other Country that is dealing with BSE/TSE should boycott the USA and demand that the SSC reclassify the USA BSE GBR II risk assessment to BSE/TSE GBR III 'IMMEDIATELY'. for the SSC to _flounder_ any longer on this issue, should also be regarded with great suspicion as well. NOT to leave out the OIE and it's terribly flawed system of disease surveillance. the OIE should make a move on CWD in the USA, and make a risk assessment on this as a threat to human health. the OIE should also change the mathematical formula for testing of disease. this (in my opinion and others) is terribly flawed as well. to think that a sample survey of 400 or so cattle in a population of 100 million, to think this will find anything, especially after seeing how many TSE tests it took Italy and other Countries to find 1 case of BSE (1 million rapid TSE test in less than 2 years, to find 102 BSE cases), should be proof enough to make drastic changes of this system. the OIE criteria for BSE Country classification and it's interpretation is very problematic. a text that is suppose to give guidelines, but is not understandable, cannot be considered satisfactory. the OIE told me 2 years ago that they were concerned with CWD, but said any changes might take years. well, two years have come and gone, and no change in relations with CWD as a human health risk. if we wait for politics and science to finally make this connection, we very well may die before any decisions
or changes are made. this is not acceptable. we must take the politics and the industry out of any final decisions of the Scientific community. this has been the problem from day one with this environmental man made death sentence. some of you may think i am exaggerating, but you only have to see it once, you only have to watch a loved one die from this one time, and you will never forget, OR forgive...yes, i am still very angry... but the transmission studies DO NOT lie, only the politicians and the industry do... and they are still lying to this day...TSS


http://www.fda.gov/ohrms/dockets/dockets/03n0312/03N-0312_emc-000001.txt

Terry S. Singeltary Sr. P.O. BOX 42 Bacliff, TEXAS USA





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