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From: Terry S. Singeltary Sr. (pool143-53.dial-u2.hou.wt.net)
Subject: BSE NORTH AMERICA - CANADA - Latest Information (as of February 2, 2005 - 17:00 EST) BSeee FEED REPORT
Date: February 2, 2005 at 7:18 pm PST

-------- Original Message --------
Subject: BSE NORTH AMERICA - CANADA - Latest Information (as of February 2, 2005 - 17:00 EST) BSeee FEED REPORT
Date: Wed, 2 Feb 2005 21:16:01 -0600
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
To: BSE-L@LISTSERV.KALIV.UNI-KARLSRUHE.DE


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

Latest Information (as of February 2, 2005 - 17:00 EST)

* The National Feed Inspection Program 2003-04 Report - Assessment
of Microscopic Analysis as a Tool for Analysing Composition of
Feed

describes a two stage assessment of microscopic laboratory
analysis as a potential tool for analysing the composition of feed
within the context of the Assessment of Microscopic Analysis as a
Tool for Analysing Composition of Feed 's BSE feed control program.

http://www.inspection.gc.ca/english/anima/heasan/disemala/bseesb/situatione.shtml


National Feed Inspection Program 2003-04
Report - Assessment of Microscopic Analysis as a Tool for Analysing
Composition of Feed

Questions and Answers - Microscopy (Trial)


------------------------------------------------------------------------


EXECUTIVE SUMMARY

The Canadian Food Inspection Agency (CFIA) designs and delivers
inspection programs to provide a reasonable assurance of compliance by
regulated parties and science-based mitigation of risks. As a matter of
routine, CFIA explores opportunities for any incremental improvement in
these programs. From January 1, 2004 to March 31, 2004,CFIA collected
feed samples for a small microscopy trial to evaluate the utility of
this technology as one indicator within a broader system of compliance
checks. The following report describes a two stage assessment of
microscopic laboratory analysis as a potential tool for analysing the
composition of feed within the context of the CFIA's BSE feed control
program.

As a measure for animal health, the BSE feed restrictions were designed
to reduce the spread of BSE within the cattle herd to a level that would
result in eradication of the disease over time. The extent to which the
feed controls minimize exposure of cattle to potentially infective feed
determines the pace at which BSE will be eradicated from the animal
population in Canada.

The results of the microscopy trial illustrate that the limitations of
this laboratory technique outweigh its potential utility. For example,
microscopy is not capable of differentiating between animal tissues that
can enter the feed chain through the grain harvesting and feed
distribution system (e.g., incorporation of small mammals or birds) from
those that would present an animal health risk for BSE within the scope
of Canada's feed controls. In the end, it was necessary to rely on
physical inspection of facilities and records, as is routinely done
within the scope of the Agency's ongoing inspection program.

Physical inspection of facilities and reports identified that the vast
majority of samples did not contain prohibited material. In 11
domestically generated samples of the total of 110 samples (65 of which
came from Canada), the CFIA was unable to rule out the possibility that
some (likely incidental level of) prohibited material may have been
among the animal tissues detected by microscopy. Given that microscopy
is a limited tool in that it could not determine conclusively that there
was no prohibited material in these samples, the CFIA has verified,
where appropriate, that the establishments involved have enhanced their
record keeping, flushing and/or sequencing practices in compliance with
Canada's BSE feed controls.


BACKGROUND

The food safety measure which protects Canadian consumers of beef from
BSE risk is the requirement to remove specified risk materials (SRM)
from all cattle slaughtered in Canada for human consumption. SRM are
tissues such as brain and spinal cord that, in infected cattle, are
capable of transmitting BSE. The animal health risk is addressed through
restrictions on feeding certain proteins, including SRM, to cattle and
other ruminant animals potentially susceptible to BSE.

Canada implemented its BSE feed controls in 1997 to reduce the potential
spread of BSE, should it have already gained a foothold in North America
at some undetected level. As an animal health measure, the feed controls
prohibit the feeding of ruminant animals (e.g. cattle, sheep, goats,
deer etc.) with animal proteins of mammalian origin (termed "prohibited
material") with the following exceptions:

* proteins derived exclusively from porcine animals;
* proteins derived exclusively from equine animals;
* blood products from any species (including ruminants); and
* milk products from any species (including ruminants).

Limiting the potential spread of BSE among the animal population in this
manner is expected to lead to the eradication of the disease over time.
The relative degree to which the ban minimizes the exposure of cattle to
potentially infective feed, determines the rate of decline of BSE in the
cattle population and, therefore, over what period of time eradication
may be achieved. No ban is one hundred percent airtight. Nevertheless,
experience in the United Kingdom has demonstrated that the introduction
of its ruminant-to-ruminant feed ban, even if imperfectly implemented,
remains the single most effective measure taken to reverse the BSE
epidemic in Europe. Results to date from progressively intensified and
targetted surveillance testing for BSE in Canada continue to show that
there is a low incidence of BSE in the Canadian cattle herd. This
surveillance result is consistent with effective feed control measures.

The CFIA designs and delivers inspection programs that provide a
reasonable assurance of compliance by regulated parties and mitigation
of risks. In this case, Canada's BSE feed controls were designed
according to science-based international standards for animal health. In
order to make its inspection programs as complete as possible, CFIA
continually searches for new assessment tools to supplement established
practices. This report describes an assessment of microscopic laboratory
analysis as a tool for analyzing the composition of feed.


MICROSCOPY TRIAL

From January 1, 2004 to March 31, 2004, the CFIA collected feed samples
for a small field trial to evaluate the potential usefulness of
microscopic analysis of the composition of feed within its inspection
program. The trial included distinct stages, the first of which involved
laboratory analysis of feed samples using microscopy - that is, viewing
microscopic sized particles of animal feed mounted on a glass slide. As
a second stage, laboratory results were then reviewed with inspection
reports for the feed manufacturing establishment from which the samples
were taken. The intent was to determine the degree to which inferences
could be drawn about the implementation of the feed ban using a
combination of these two different information sources.

In stage one, the laboratory results by themselves were not intended to
nor are they capable of determining compliance, or non-compliance, with
the feed control measures. As such, the trial was undertaken by the CFIA
with the understanding that microscopic analysis as a testing technique
on its own has some significant limitations. It enables the detection of
extremely small pieces of animal material (feathers, hair, muscle
fragments, bone fragments, lactose and blood meal) generally, but it
cannot be used to identify particular species or whole tissues (e.g.
porcine versus ruminant meat and bone meal, or small mammals picked up
during grain harvesting and feed distribution). Test results are
qualitative in nature (the analyst reports what is seen, e.g., hair,
muscle fragment) and cannot determine the origin or how much animal
material might be in the feed. Therefore, the trial included microscopic
analysis in combination with inspection activities so that the CFIA
could better evaluate microscopic analysis as a non-specific screening
tool for animal material.

Two categories of feeds were eligible for sampling :

* Feed ingredients (bulk or packaged ingredients that are commonly
used in feeds for ruminants such as cereals and cereal byproducts,
oilseed meals, grain screenings); and,
* Ruminant feeds (bulk or packaged complete feeds, supplements and
macro-premixes for cattle, sheep, goats, deer, elk, bison etc.);
formulations of ruminant feeds sampled were not intended to
contain any animal protein products although formulations
containing blood and milk products were acceptable.


DETAILED RESULTS AND ANALYSIS

A total of 110 samples of livestock feeds and ingredients were obtained
by the CFIA inspection staff. At the time of sampling, inspection staff
also conducted a brief inspection of the facility with the purpose of
obtaining basic manufacturing information related to the sample and the
facility where it was obtained. Of the 110 samples taken, 65 were of
domestic origin and 45 of imported origin.

At stage one, a total of 43 samples reported no detection of animal
material and there were 67 samples where a result of detected was
reported for animal material. (Table 1).

Table 1: Stage One - Sample Results

Total number of samples analysed Laboratory analysis alone
Animal material of any kind
Not Detected
(# of samples) Animal material of any kind
Detected
(# of samples)
110 (Domestic + Imported) 43 (16 domestic, 27 imported) 67 (49 domestic,
18 imported)

Where the laboratory result did not detect the presence of any kind of
animal material it was possible to conclude that the samples did not
contain any prohibited material under the ban. Where animal material of
any kind was detected, it was necessary to undertake further analysis
beyond the laboratory in order to draw any meaningful conclusions.

Laboratory results which detected unspecified animal material in
domestic samples were considered within the context of the second stage
of the trial as summarized in Table 2. In stage 2, based on reporting
from the laboratory combined with a review of pre sampling inspection
reports, it was possible to determine that another 22 samples did not
contain prohibited material on the basis that the establishments from
which the samples were taken did not handle prohibited material.

For those domestic samples where review of the pre sampling inspection
reports alone could not rule out the potential for prohibited material
to be among the animal materials detected, i.e., where the facility
handled both prohibited animal material and made feed for ruminants, an
additional onsite inspection was conducted by CFIA. Based on the
follow-up inspections, it was determined that another 16 samples did not
contain prohibited material on the basis that all appropriate control
procedures were being strictly adhered to in the establishments from
which these samples were taken.

For the other 11 domestic samples, the CFIA could not rule out the
possibility that some (likely an incidental level of) prohibited
material may have been among the animal tissues detected in the
laboratory. For 7 of these, the establishments enhanced their record
keeping, flushing and/or sequencing practices, all of which have been
verified by CFIA inspectors. With respect to the other 4 samples, the
single establishment from which they were taken has ceased operation and
no further action is required.

Table 2: Stage Two - Domestic Sample Results

Break-down of sample resutls, out of 65 Stage 1: lab test result Stage
2: review of pre-sampling insepction record Stage 2: additional onsite
inspection Stage 2: Assessment of Microscopic Analysis as a Tool for
Analysing Composition of Feed verification of corrective action taken be
establishment
16 Animal material not detected NO FURTHER INVESTIGATION REQUIRED
22 Animal material detected: more analysis required Not prohibited
material NO FURTHER INVESTIGATION REQUIRED
16 Animal material detected: More analysis requried More analysis
required Not prohibited material NO FURTHER INVESTIGATION REQUIRED
7 Animal material detected: More analysis required More analysis
required Could not rule out possibility of some (likely incidental level
of) prohibited material - corrective action taken Yes NO FURTHER
INVESTIGATION REQUIRED
4 Animal material detected: More analysis required More analysis
required Could not rule out possibility of some (likely incidental level
of) prohibited material - business ceased operation1 Not necessary NO
FURTHER INVESTIGATION REQUIRED

For samples of feeds imported from other countries for which a result of
detected was reported, there was no direct means within the context of
this trial of conducting pre-sampling or follow-up inspections at the
foreign establishment where the imported feed or ingredient originated.
Importers were advised of the findings and asked to contact their
suppliers for additional information. Any further analysis of the
additional information provided will be considered outside the context
of this trial. A summary of these results is contained in Table 3.

Table 3: Stage Two - Imported Sample Results

Break-down of sample results2 Stage 1: lab test result Stage 2: solicit
additional information from importer
27 Animal material not detected NO FURTHER INVESTIGATION REQUIRED
18 Animal material detected Importers requested to follow-up with
suppliers FURTHER DISCUSSION WITH EXPORTING COUNTRY


CONCLUSION

The results of the trial illustrate that the limitations for CFIA of
this laboratory technique outweigh its potential utility. For example,
microscopy is not capable of differentiating between animal tissues that
can enter the feed chain through the grain harvesting and feed
distribution system (e.g., incorporation of field mice or small mammals)
from those that would be of concern in managing animal health risks for
BSE within the scope of Canada's feed control measures. In the end, it
was necessary to rely upon physical inspection of facilities and
records, as is routinely done within the scope of the Agency's ongoing
inspection program.

At this time, microscopy as a tool for evaluating compliance would only
be seen as useful if undertaken in conjunction with existing inspection
programs and with full recognition of its potential limitations.

1All samples from same establishment.
2Imported Samples were from the United States and France.

Canadian Food Inspection Agency
February 2, 2005

http://www.inspection.gc.ca/english/anima/feebet/rumin/microe.shtml


Questions and Answers
Microscopy (Trial)

Trial Design and Methodology

| Results and Analysis


Q1. What was the purpose of this trial?
A1. From January 1, 2004 to March 31, 2004, the CFIA collected feed
samples for a small field trial to evaluate the potential usefulness of
microscopic analysis of the composition of feed within its inspection
program.

The intent of the trial was to determine the degree to which inferences
could be drawn about compliance with feed controls using information
from microscopy analysis of feed samples - that is, viewing microscopic
sized particles of animal feed mounted on a glass slide.

The CFIA designs and delivers inspection programs that provide a
reasonable assurance of compliance by regulated parties and mitigation
of risks. In this case, Canada's BSE feed controls were designed
according to science-based international standards for animal health. In
order to make its inspection programs as complete as possible, CFIA
continually searches for new assessment tools to supplement established
practices. This report describes an assessment of microscopic laboratory
analysis as a tool for analyzing the composition of feed.

Q2. How does the feed ban work? Does it have to be water tight to do its
job?
A2. The feed ban works by reducing the potential spread of BSE from
animal to animal through feed. Limiting the potential spread of BSE
among the animal population in this manner is expected to lead to the
eradication of the disease over time. The relative degree to which the
ban minimizes the exposure of cattle to potentially infective feed,
determines the rate of decline of BSE in the cattle population and,
therefore, over what period of time eradication may be achieved. No ban
is one hundred percent airtight. Nevertheless, experience in the United
Kingdom has demonstrated that the introduction of its
ruminant-to-ruminant feed ban, even if imperfectly implemented, remains
the single most effective measure taken to reverse the BSE epidemic in
Europe. Results to date from progressively intensified and targeted
surveillance testing for BSE in Canada continue to show that there is a
low incidence of BSE in the Canadian cattle herd. This surveillance
result is consistent with effective feed control measures.
Q3. Does the trial show that the feed ban is not working?
A3. >No. The CFIA collected feed samples for a small microscopy trial to
evaluate the utility of this technology as one indicator within a
broader system of compliance checks. The test was not designed or able
to measure compliance with the feed ban on its own. For example,
microscopy is not capable of differentiating between animal tissues that
can enter the feed chain through the grain harvesting and feed
distribution system (e.g., incorporation of small mammals or birds) from
those that would present an animal health risk for BSE within the scope
of Canada's feed controls.

The purpose of implementing the feed ban was to limit the spread of BSE
if it happened to be present but undetected in our cattle population.
Results to date from surveillance for BSE in Canada suggest that the
incidence is low and that the feed ban has been effective in checking
the spread of BSE.

Q4. Does the CFIA regularly conduct this type of trial to monitor
compliance with the feed ban?
A4. The CFIA has not tested feeds for compliance to the feed ban because
of the limitations associated with existing testing methods.

The CFIA actively verifies compliance with the ban at multiple points in
the feed chain. Regular comprehensive inspections are conducted to
confirm that manufacturing procedures, production and distribution
records and product labels comply with regulatory requirements. The rate
of compliance has averaged at 95% over the last three years, as reported
at the end of each fiscal year, as reported at the end of each fiscal year.

Furthermore, results to date from progressively intensified and targeted
surveillance testing for BSE in Canada continue to show that there is a
low incidence of BSE in the Canadian cattle herd. This surveillance
result is consistent with effective feed control measures.


TRIAL DESIGN AND METHODOLOGY

Q1. What is microscopic analysis and why was it tested during this trial?
A1. Feed microscopic analysis -- that is, viewing microscopic sized
partied particles of animal feed mounted on a glass slide -- has been
developed collaboratively with regulatory agencies in North America. The
U.S. began using microscopic analysis to test feeds several years ago.
It is, however, recognized that microscopic analysis as a testing
technique on its own has some significant limitations. Microscopic
analysis enables the detection of animal materials (feathers, hair,
muscle fragments, bone fragments, lactose and blood meal) generally, but
it cannot be used to identify particular species or tissues (e.g.
porcine versus ruminant meat and bone meal).

Microscopic analytical results are qualitative in nature (the analyst
reports what is seen) but cannot determine how much animal material
might be in the feed.

Therefore, the trial was proposed in combination with inspection
activities so that the Canadian Food Inspection Agency could better
evaluate microscopic analysis as a potentially sensitive screening tool
for analysing the composition of feed.

Q2. How was the trial conducted?
A2. The trial included two distinct stages, the first of which involved
laboratory analysis of feed samples using microscopy. As a second stage,
laboratory results were reviewed with pre-sampling inspection reports
for the feed manufacturing establishment from which the samples were taken.

The intent of the trial was to determine the degree to which inferences
could be drawn about compliance with feed controls using a combination
of these two different information sources.


RESULTS AND ANALYSIS

Q1. How many samples did the CFIA take?
A1. A total of 110 samples of livestock feeds and ingredients were
obtained by the Canadian Food Inspection Agency inspection staff. At the
same time that the samples were collected, inspection staff inspected
the facility to find out how the sampled feed was manufactured and
handled. Of the 110 samples taken, 65 were of domestic origin and 45 of
imported origin.
Q2. In how many of the 110 feed samples was animal material detected in
the first stage of the trial?
A2. At stage one of the trial, laboratory analysts visually detected
animal material in 67 of the samples. Animal material was not detected
in 43 of the samples. Where the laboratory result did not detect any
kind of animal material, it was possible to conclude that the samples
did not contain any prohibited material under the ban. Where animal
material of any kind was detected (67 samples), it was necessary to
undertake further analysis beyond the laboratory in order to draw any
meaningful conclusions.
Q3. >What about in stage two?
A3. In stage 2, based on reporting from the laboratory combined with a
review of pre sampling inspection reports, it was possible to determine
that another 22 of the domestic samples did not contain prohibited
material on the basis that the establishments from which the samples
were taken did not handle prohibited material.

Where review of the pre-sampling inspection reports alone could not rule
out the potential for prohibited material to be among the animal
materials detected, i.e., where the facility handled both prohibited
animal material and made feed for ruminants, an additional onsite
inspection was conducted by the CFIA.

Based on the follow-up inspections, it was determined that another 16
samples did not contain prohibited material on the basis that all
appropriate control procedures were being strictly adhered to in the
establishments from which these samples were taken.

For the other 11 domestic samples, the CFIA could not rule out the
possibility that some (likely an incidental level of) prohibited
material may have been among the animal tissues detected in the
laboratory. For 7 of these, the establishments enhanced their record
keeping, flushing and/or sequencing practices, all of which have been
verified by CFIA inspectors. With respect to the other 4 samples, the
single establishment from which they were taken has ceased operation and
no further action is required.

Q4. What about the imported samples?
A4. For samples of feeds imported from other countries for which a
result of detected was reported, there was no direct means within the
context of this trial of conducting pre-sampling or follow-up
inspections at the foreign establishment where the imported feed or
ingredient originated. Importers were advised of the findings and asked
to contact their suppliers for additional information.
Q5. What was the overall conclusion of the trial?
A5. The results of the trial illustrate that the limitations of
microscopic analysis outweigh its potential utility. For example,
microscopy is not capable of differentiating between animal tissues that
can enter the feed chain through the grain harvesting and feed
distribution system (e.g., incorporation of field mice or small mammals)
from those that would be of concern in managing animal health risks for
BSE within the scope of Canada's feed control measures. In the end, it
was necessary to rely upon physical inspection of facilities and
records, as is routinely done within the scope of the Agency's ongoing
inspection program.

At this time, microscopy as a tool for evaluating compliance would only
be seen as useful if undertaken in conjunction with existing inspection
programs and with full recognition of its potential limitations.

Q6. Will the CFIA be using microscopy again?
A6. The results of the trial illustrate that the limitations of
microscopy outweigh its potential utility. At this time, microscopy as a
tool for evaluating compliance would only be seen as useful if
undertaken in conjunction with existing inspection programs and with
full recognition of its potential limitations.

http://www.inspection.gc.ca/english/anima/feebet/rumin/microqueste.shtml


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


snip...

Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the
Geographical BSE Risk of Canada
- 13 -
On the basis of the available information, it has to be concluded that
the country's
BSE/cattle system was extremely unstable until today, i.e., it would
have recycled and
amplified BSE-infectivity very fast, should it have entered the system.
The stability of the
BSE/cattle system in Canada overtime is as given in table 5 above.
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 90's 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.

- 14 -
5.2 The expected development of the GBR as a function of the past and
present stability and challenge
. As long as the system remains unstable, it is expected that the GBR
continues to
grow, even if no additional external challenges occur.
. Since recent improvements in the safety of MBM production in many
countries or
significant recent reductions in the incidence of BSE are not taken into
account for
the assessment of the external challenge, the external challenge
assessed after 2001
could be overestimated and is the worst case assumption. However all
current GBR
conclusions are not dependent on these assumptions in any of the
countries assessed.
For future assessments and when the impact of the production,
surveillance and true
incidence changes has been fully quantified, these developments should
be taken
5.3 Recommendations for influencing the future GBR
. Enhancing the stability of the system, in particular by ensuring that
cattle have no
access to mammalian MBM in combination with appropriate rendering and
exclusion of
SRM and fallen stock from any feed chain could lead, over time, to a
reduction of the
. Improved passive and active surveillance, i.e. sampling of animals not
showing
signs compatible with BSE from "at-risk" cattle populations, such as
adult cattle in
Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the
Geographical BSE Risk of Canada
country.
Acknowledgment

snip...

CANADA

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


USA

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


MEXICO

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


Congress of the United States Washington, DC 20515
January 5, 2005 The Honorable Michael Johanns Governor State of Nebraska
Office of the Governor P.O. Box 94848 Lincoln, NE 68509-4848 Dear
Governor Johanns: On January 4, 2005, the U.S. Department of Agriculture
announced that it would lift the ban on cattle imports from Canada,
effective on March 7. A principal rationale for USDA's decision is that
Canada has a "rigorous" and "effective" feed ban in place, which
prevents the spread of "mad cow disease" by preventing protein derived
from cattle from being fed to cattle. It appears, however, that USDA has
failed to review significant evidence that calls into question the
effectiveness of the Canadian feed ban. If, as expected, you are
confirmed as Secretary of Agriculture, we urge you to assess this new
information carefully before proceeding with the plan to reopen the U.S.
border to the importation of millions of Canadian cattle. We have
learned that: " U.S. regulators have discovered animal muscle, hair,
blood and bone in Canadian feed. Over the last 15 months, the U.S. Food
and Drug Administration (FDA) has issued "import alerts" blocking the
importation of products from 17 Canadian companies, including two of the
largest feed manufacturers in the country. FDA found muscle tissue in 15
products, animal hair in five, blood in eight, and bone in two. Eight
"import alerts'' on Canadian feed are still active today. " Recent tests
have shown that Canadian feed often contains unanticipated animal
protein. Over two-thirds of samples of vegetarian animal feed
manufactured in Canada and recently tested by the Canadian regulators
contained "undeclared animal materials." In an internal memo, a senior
regulator called the test results "worrisome." " Major noncompliance
with Canadian feed rules persists. Recent inspections have revealed that
seven Canadian feed mills had "major non-compliance" issues, and three
were failing "to prevent contamination of... feeds." In one recent case,
potentially contaminated feed was consumed by cattle. " Canada
recognizes gaps in its own feed ban. On December 10, 2004, Canadian
regulators concluded that "the current framework provides opportunities
for prohibited proteins to be accidentally included in or
cross-contaminate feeds." Canada then proposed changes to its feed ban.
The Honorable Michael Johanns January 5, 2005 Page 2 These findings,
which are discussed in detail in the attachments to this letter, have
significant implications. The recent discovery of another case of mad
cow disease in Canada underscores the potential risk of inadequate
measures to prevent the spread of the disease. If Canada's feed ban is
not effective, then Canada does not qualify as a "minimal risk" country
under the new definition put forward by USDA, and the importation of
Canadian cattle cannot resume. It is imperative that these issues be
thoroughly investigated before authorizing Canadian imports. For these
reasons, we urge you to consult with FDA about the "import alerts"
against Canadian feed suppliers and assess their implications for the
effectiveness of the Canadian feed ban. We also urge you to review the
Canadian documents questioning industry's compliance with the feed ban
and to talk to Canadian officials about the limitations of their current
feed ban. After undertaking this investigation, we urge you to appear
before Congress to communicate your findings. Sincerely, Henry A. Waxman
Ranking Minority Member Committee on Government Reform U.S. House of
Representatives Kent Conrad Senator U.S. Senate

PLEASE SEE FULL TEXT 9 PAGES...TSS


http://www.democrats.reform.house.gov/Documents/20050105172715-33292.pdf

"If the science doesn't fit what the White House wants it to be, it
distorts the science."

http://www.house.gov/waxman/news.htm

[PDF] Secret tests reveal cattle feed contaminated by animal parts


http://www.r-calfusa.com/BSE/Attachment%2520C,%252012-16-04,%2520The%2520Vancouver%2520Sun,%2520animal%2520parts%2520in%2520feed.pdf

Secret tests reveal cattle feed contaminated by animal parts
Mad cow fears spark review of 'vegetable-only' livestock feeds

Chad Skelton
Vancouver Sun


December 16, 2004

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CREDIT: John Lucas, CanWest News Service
A majority of the first batch of 70 'vegetable-only' cattle feed samples
were found to be contaminated with animal protein.


Click here to find out more!


A series of secret tests on cattle feed conducted by the federal
government earlier this year found that more than half the feed tested
contained animal parts not listed on the ingredients, according to
internal documents obtained by The Vancouver Sun.

The test results raise troubling questions about whether rules banning
the feeding of cattle remains to other cattle -- the primary way in
which mad cow disease is spread -- are being routinely violated.

According to internal Canadian Food Inspection Agency documents --
obtained by The Sun through the Access to Information Act -- 70 feed
samples labelled as vegetable-only were tested by the agency between
January and March of this year. Of those, 41 (59 per cent) were found to
contain "undeclared animal materials."

"The presence of animal protein materials [in vegetable feeds] may
indicate ... deliberate or accidental inclusion of animal proteins in
feeds where they are not supposed to be," said an internal memo to the
president of the Canadian Food Inspection Agency last April that
described the test results as "worrisome."

The memo, from Sergio Tolusso, feed program coordinator for the CFIA,
said the contamination could also have been caused inadvertently -- for
example, through the transporting of different feeds in the same trucks.

Controlled experiments have shown an animal needs to consume as little
as one milligram of infected material -- about the size of a grain of
sand -- from an animal with bovine spongiform encephalopathy (BSE) to
develop the brain-wasting disease.

Michael Hansen, an expert on mad cow disease with the U.S.-based
Consumers Union, the independent research institute that publishes
Consumer Reports, said the CFIA tests are troubling.

"The fact that stuff that is labelled as vegetable feed, that 59 per
cent of it has animal material, that's incredibly high," said Hansen,
who has a PhD in biology. "This should be a wake-up call to CFIA. It
doesn't look good."

Michael McBane, national co-ordinator for the Canadian Health Coalition,
a watchdog group, said the tests suggest the feed ban is not being
adequately enforced.

"It demonstrates the fact that the [feed] ban is basically meaningless,"
McBane said. "It's pretty well recognized that we have mad cow disease
in Canada because of contaminated feed. It's the frontlines in the
battle to stop the spread."

Consumption of beef from cows infected with BSE has been linked to the
development in humans of variant Creutzfeldt-Jakob disease (vCJD), a
deadly brain-wasting illness.

In the 1990s, the United Kingdom suffered an outbreak of BSE that was
followed by more than 100 people dying of vCJD.

In 1997, as a precaution, Canada implemented a ban on feeding ruminants
-- like sheep and cattle -- to other ruminants. However, ruminant
remains can still be fed to chicken and pigs, and chicken and pig
remains can be fed to cattle.

With the discovery of a lone Alberta cow with BSE in May 2003, the feed
ban took on added importance.

"Compliance with the existing ban is a critical factor in preventing the
disease from spreading to other animals," Tolusso wrote in January in an
internal memo to CFIA president Dick Fadden. "Major non-compliance with
the feed ban cannot be tolerated, and measures to address the risks of
domestic ruminants being exposed to prohibited animal proteins must be
initiated promptly."

...Continued

According to the documents, concerns about the integrity of Canada's
feed were first raised in the summer of 2003, when U.S. authorities
turned back seven separate shipments of vegetable feed from Canada
because they were contaminated with animal parts.

"The animal proteins detected in these [shipments] were not supposed to
be in the feeds," Tolusso explained to Fadden in an August 2003 memo.
"While the results initially appear to be very worrying, it is difficult
to interpret the real significance of these findings."

To determine if there was a wider problem with Canadian feed, the CFIA
initiated a nationwide testing program of both domestic and imported
feed in early 2004.

To make the job easier for its scientists, the agency collected only
samples that were labelled as vegetable-only, such as soy meal or grain
-- feed that shouldn't have any animal parts in it at all.

The samples were tested by CFIA scientists in Ottawa, who looked at a
few grams of each sample under a microscope.

The first batch of 70 samples found that a majority contained animal
protein.

And the worst results were for feed manufactured in Canada.

Of the 28 domestic feed samples tested by the agency, 20 had undeclared
animal protein in them -- 71 per cent of all the samples.

In comparison, just under half of the imported samples -- 19 of 39 --
contained animal parts.

(Three of the 70 samples were of undetermined origin.)

In an interview with The Sun, Tolusso said he couldn't say how many of
the contaminated feed samples contained cattle remains.

"In the absence of real identifiable material like feathers and hairs,
[scientists are] left looking at bone fragments and pieces of muscle
tissue, and those are virtually impossible to determine what species
they might come from," Tolusso said.

As a result, he said, the agency doesn't have a clear idea of how much
cattle remains have been fed to other cattle.

"We knew entering this testing survey that there was a possibility we
could generate more questions for ourselves than we could answer," he
said. "We hadn't done this before and to some extent we weren't sure
what we were going to find. And it does make it worse that you can't
explain what they actually are."

In addition to concerns over testing, the CFIA documents obtained by The
Sun also reveal problems with the feed mills that produce animal feed.

There are about 550 commercial feed mills in Canada.

According to a memo to Fadden last March, an initial inspection last
year of several hundred of those mills found that 21 per cent were not
complying with federal regulations.

Most of those violations were minor and quickly corrected.

However, the report notes that seven mills had "major non-compliance
issues" involving things like proper labelling and record-keeping.

...Continued

And three mills were failing "to prevent the contamination of ruminant
feeds with non-ruminant feeds containing ruminant meat and bone meal" --
the exact type of contamination that can spread BSE.

Two of those three mills successfully recalled their contaminated
product, but the report notes that in one case, some of the feed was
sent out and consumed by cattle.

Tolusso said the CFIA's feed tests led to some follow-up inspections in
feed mills, but no further recalls of feed.

Earlier this month, the CFIA announced it would ban the parts of cattle
most susceptible to BSE infection -- such as the spine and brains --
from all feed, including that destined for pigs and chickens.

Such animal parts are known as specified risk materials (SRMs).

Tolusso acknowledged the agency's tests were one reason for the stricter
regulations.

"If we recognize there are lots of opportunities for the wrong kind of
protein to get in the wrong kind of feed ... then perhaps the more
prudent thing to do is to remove some of these higher-risk tissues
altogether," he said.

Some experts have argued that Canada should go even further and keep
cattle remains out of feed altogether, as is done in Europe.

"What they need to do is cut out the loopholes [and] stop feeding
mammalian protein to food animals," Hansen said.

McBane agreed.

"At the end of the day, the only way to stop the transmission of BSE is
a complete stop on recycling animal protein," he said.

Tolusso said the CFIA believes a ban on just the riskiest materials --
like cow brains -- will eliminate most of the risk of BSE spreading in
Canada.

But he said the agency hasn't ruled out a total ban on cattle remains in
feed.

"At this point, we've put our best guess forward [on] the most
appropriate approach," he said. "But that doesn't preclude that ... we
might have to go to a more strict ban."

cskelton@png.canwest.com

© The Vancouver Sun 2004

http://www.canada.com/vancouver/vancouversun/news/story.html?id=892f5a65-1b99-4b84-8359-6629bbd1f419

http://www.canada.com/vancouver/vancouversun/news/story.html?id=892f5a65-1b99-4b84-8359-6629bbd1f419&page=2

http://www.canada.com/vancouver/vancouversun/news/story.html?id=892f5a65-1b99-4b84-8359-6629bbd1f419&page=3

also;

http://www.healthcoalition.ca/new-bse.pdf

TSS

######### https://listserv.kaliv.uni-karlsruhe.de/warc/bse-l.html ##########






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