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From: Terry S. Singeltary Sr. (
Subject: Johanns to Senate: March 7 border opening stands THE FINAL WORD (what about TSE and infectivity from tongue?)
Date: February 6, 2005 at 9:57 am PST

-------- Original Message --------
Subject: Johanns to Senate: March 7 border opening stands THE FINAL WORD (what about TSE and infectivity from tongue?)
Date: Sat, 5 Feb 2005 09:40:24 -0600
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy

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

THE FINAL WORD Issue 133 Feb. 4, 2005

Alan Guebert

1.) Johanns to Senate: March 7 border opening stands

Between much hemming and hawing before the Senate Ag Committee
Thursday, Secretary of Agriculture Mike Johanns said repeatedly that the
scheduled March 7 border reopening between the US and Canada "is moving
Johanns was called to the special "mad cow" Senate hearing--and
was its only witness--to defend the Administration's Dec. 29 proposed
border reopening rule that would bring younger Canadian live cattle into
the US.
Despite Johanns steadfast defense of reopening the border to
live cattle under 30 months of age and boxed, slaughtered cattle over 30
months of age, Republican and Democratic members of the committee took
turns expressing problems with the rule.
Most of their concerns centered on what many viewed as
contradictive evidence that the rule, in USDA's shopworn phrase, is
"based on sound science."
Ranking Committee Democrat Tom Harkin of Iowa, captured most
members' worries in noting--at both the hearing and in letter sent to
Johanns Tuesday--that the rule was "inconsistent" with BSE guidelines
from the Office of International des Epizootic, or OIE, the Paris-based
group USDA has linked to its BSE control policies.
OIE guidelines urge ruminant-to-ruminant feed bans of eight
years, Harkin reminded Johanns. Both the US and Canada enacted the bans
in Aug. 1997, or seven year and six months ago.
That plainly means, Harkin pointed out, that USDA's opening of
the border March 7 will be five months short of what OIE strongly urges.
"We all agree on using 'sound science' here," Harkin pointedly
remarked, "and USDA says it does. But on this point, the rule falls
Johanns accompanied by Keith Collins, USDA chief economist and
Dr. Ron DeHaven, administrator of USDA's Animal Plant Health Inspection
Service (APHIS), parried Harkin's concerns by noting the border rule
encompasses a "risk standard."
"You do everything you can to minimize BSE," the Secretary
explained, admitting the March 7 date was "a few months short of
eight-year feed ban."
Harkin also noted that "Canada is only 95% in compliance" with
the feed ban, explaining that the nation's track record on banning
ruminant additives to feed had not 100% enforced.
DeHaven try to tamper down Harkin's math by noting the OIE feed
guidelines really aren't hard rules, but more of a "holistic approach...
they aren't prescriptive, just guidelines," he explained.
Fine, noted Harkin, but that's not the way USDA sold OIE rules
to Congress and the public when it took steps to mitigate BSE's initial
impact in the US after the Washington state mad cow turned up in Dec.
"If you add up all the OIE regulations," Harkin concluded,
"Canada is not a minimal risk country," as USDA defines it in the border
rule. "It's a moderate risk country."
Past committee chairman Richard Lugar, R-IN, chimed in by noting
that while he wants to maximize trade with all nations, opening the
US-Canadian border before opening up the $1.5 billion per year Japanese
export market to American beef producers could be harmful to US
Noting USDA's own economic analysis predicts as many as 2
million beef animals could cross into the US from Canada, Lugar asked,
"Shouldn't we be holding our horses and wait this (Japanese market
reopening) out?"
Not to be taken off message, Johanns replied not really. "We
need to ready to lead by example," he said weakly. Economist Collins
piped in to note that the number of cattle expected to float south after
the border reopening varied from 800,000 to 2 million.
And, he added, the economic analysis USDA performed prior to
releasing the rule Dec. 29 suggested "fed cattle prices here would drop
from $85 per hundredweight to $82 per hundredweight." He called that
drop "moderate."
Minnesota Democrat Mark Dayton blew a gasket at the Collins'
breezy characterization. Calling USDA's economic analysis of the rule
"something out of Mad Magazine," Dayton, his voice rising in anger, said
the "moderate" price drop explanation was both "ignorant and offensive."
US cattlemen stand to lose $2.9 billion when the border reopens,
said Dayton--citing USDA's own estimate--even as the US meatpacking
industry moves plants and American jobs to Canada to slaughter over
30-months-of-age cows not permitted to enter US markets under the rule.
"This is a disaster," added Dayton, "...a creation of this
The disparity of the rule--allow under 30-months-of-age cattle
in, keep over 30-months-of-age cattle out--will "cost us jobs," nearly
shouted Dayton, adding that "it's like (this rule) was crafted to
benefit Canada and the larger processors."
Kansas Republican Pat Roberts questioned Johanns on the
yet-to-be released report on USDA's plan to expand imports of processed
beef items like tongues. Would the Secretary take the report into
account prior to opening the border?
Johanns, while still stressing the need to reopen the border,
promised he would need to be confident that any imported item permitted
under the rule would not harm US markets or undermine confidence in the
US food supply.
Colorado's new senator, Ken Salazar, put Johanns' rough hearing
in perspective. "What you're hearing from everyone," said the freshman
Democrat, "is we have a problem with this rule and we should be fixing
the rule before we open the border."
Salazar then emphasized one of the rule's gaping holes to prove
his point: "How are you going to verify which of these 900,000-plus
animal (coming from Canada) are under 30 months of age?"
Again, Johanns' leaned on the Administration's biggest reason
for reopening the border. "Without good, sensible export policy this
industry is in trouble. Like it or not, the (meatpacking) industry is
adjusting and boneless beef (from Canada) is coming."
The tone of the Senate hearing was far more rancorous than the
love-fest Johanns encountered in his confirmation hearing just three
weeks ago. But the senators' tough questions and evident worry over the
rule reflect largely where cattlemen themselves are on the rule--deeply
divided and deeply concerned.
At the National Cattlemen's Beef Association annual meeting in
San Antonio this, cattlemen appeared split over the border reopening.
While most agree that the Japanese market needs to be reopened to
American beef exports, many wondered if reopening the Canadian border is
the right method to do it.
(Johanns will address the NCBA convention Friday. His message
will be simple: Japan and Canada are linked, therefore the March 7
border reopening with Canada is essential to resume all exports.)
After the Senate Ag Committee hearing, Iowa's Harkin explained
that he and other ag state senators are searching for a Congressional
way to block the March 7 border reopening.

2.) News, views and at least some relation to truth

--Great Falls of Fire: "Great Falls, Mont.--President Bush took
his proposal for a new Social Security system on the road on Thursday
with a stark warning to younger workers that the retirement program will
go 'bust' within four decades if it is not overhauled and with a call
for his supporters to demand action from Congress." Feb. 3, New York

--But privatization doesn't help: "The Administration official
acknowledged what analysts have long known--private accounts themselves
do nothing to restore solvency. The official stated: 'So in a long-term
sense, the personal accounts would have a net neutral effect on the
fiscal situation of the Social Security and on the federal government.'
"A reporter subsequently asked the senior Administration
official: ' I right in assuming... that it would be fair to
describe this as having--the personal accounts by themselves, that it
would be fair to describe this as having--the personal accounts by
themselves as having no effect whatsoever on the solvency issue?'
"The senior Administration official replied: 'That's a fair
inference.'" Feb. 2, White House briefing, Center on Budget and Policy

--Despite Canada, tough talk to Japan: "'Efforts to re-open this
market have drawn on resources across the federal government and the
highest political levels,' Johanns said.
"Johanns also pointed out that he had met 'during my first few
days as secretary' with the Japanese ambassador to the United States and
that U.S. Ambassador to Japan Howard Baker continues to push the issue
in Tokyo.
"Johanns also said that resumption of U.S. beef imports into
Japan had been 'a major focus of direct discussions between President
Bush and Japanese Prime Minister Koizumi."" Feb. 3, DTN.

--Oh yeah, now what? "Japan confirmed on Friday its first case
of the human variant of mad cow disease, a fatal brain disease thought
to be contracted by eating infected beef.
"The Health Ministry said that a Japanese man had died last
December from variant Creutzfeldt-Jakob disease (vCJD), adding that he
probably contracted the fatal illness during a month-long stay in
Britain in 1989.
"'I know that this will make many people worry, but we must take
note of the fact that his stay was only one month," Tetsuyuki Kitamoto,
a Tohoku University professor and head of the ministry panel on the
disease, told a news conference...
"Japan has reported 14 cases of BSE and began testing all its
cattle for the disease after the first case in September 2001.
"It also banned imports of Canadian beef in May 2003 and of U.S.
beef in December 2003 after cases of mad cow disease were found in those
countries, and is in drawn-out talks on when to lift the ban..." Feb. 4,

--Hey, didn't you guys support the President? "The American Farm
Bureau Federation today, along with a diverse coalition of more than 100
organizations, sent a letter to Agriculture Secretary Mike Johanns
voicing concern about possible agriculture spending reductions. The Bush
administration's proposed 2006 budget is set to be released Monday.
"According to the coalition letter, reductions or restructurings
of the 2002 Farm Bill would 'seriously undermine many nutrition,
conservation, crop insurance and farm programs that are important to all
'Many of these critically important programs already have
sustained budget reductions in recent years,' the letter continued,
citing reductions in funding for many discretionary agriculture
programs, and reductions of $4 billion in mandatory agriculture
spending." Feb. 3, AgPRonline.

--Treating symptoms, not the disease: "The disease we face in
farming today is not farm subsidies. The disease we face is low farm
prices, here and around the world. Subsidies are the crucial medication
and critical to the treatment of the disease. If you farm in the U.S.,
the medication (subsidies) is currently affordable and you will receive
just enough to survive --- maybe. But if you live in a developing
country where the medication is not affordable or not available, the
disease of low prices is fatal." Feb. 1, American Corn Growers Assoc.

(c) 2004 ag comm The Final Word comes to you each Friday by special
arrangement. Alan Guebert's regular column, the Farm and Food File, is
published weekly in more than 75 newspapers around the US and Canada.
Contact him at

Issue #129 - Fri, Jan 7, 2005

USDA’s Mad Cow Circus Reopens for 2005

The US Dept. of Agriculture’s Dec. 29 proposal to reopen the long-closed
US border to imports of live Canadian cattle and a wider range of
Canadian boxed beef ran headlong into consumer, rancher and export
market concern when Canada’s Food Inspection Agency confirmed Sunday,
Jan. 2 that nation’s second case of mad cow disease.

The animal, an 8-year-old Holstein dairy cow in Alberta, was suspected
of the disease before USDA released its border-opening rule last
Wednesday. According to Canadian government officials, USDA knew about
the suspected positive prior to Dec. 29.

Despite the Canadian confirmation, USDA said it would proceed with its
new rule, which could open the US market to Canadian live fat and feeder
cattle under 30 months of age by March 7.

The new rule also alters the boxed-beef import rule in place since last
August. The new rule allows bone-in, boxed beef from cattle of any age
into the US from Canada. The current rule allows only boned, boxed beef
from cattle 30 months old or younger.

The new case of mad cow means all three cases of North American BSE have
Canadian roots: the first Alberta cow in May 2003 that closed the
US-Canadian border to live cattle imports; the second Washington State
cow, found in Dec. 2003 that was born in Canada; and now the Jan. 2005

Since the Dec. 2003 Washington State cow, US beef exports have tumbled
from $3 billion per year to less than $400 million. Key Asian markets,
especially Japan, Korea and Taiwan, continue to limit US beef exports.

In defending the proposed rule Jan. 3, Ron DeHaven, administrator of
USDA’s Animal Plant Health Inspection Service (APHIS) noted that the
recent Canadian mad cow did not mean Canada should remain shutout of the
US market.

Under the World Organization of Animal Health standards, explained
DeHaven, Canada’s “roughly 5.5 million cattle over 24 months of age”
could eventually show “up to 11 cases of BSE in this population and
still be considered a minimal-risk country...”

Some in Congress and in the country immediately called for USDA to
suspend the rule. Sen. Byron Dorgan, D-ND, formally asked Agriculture
Secretary Ann Veneman Monday to take the new import rule off the table.

“I know this is a tough blow to Canadian beef producers,” Dorgan noted,
“...but our first responsibility is to protect the American beef
industry, which has taken a significant hits in its export markets as a
result of the Canadian cow that was discovered in Washington State last

Dorgan’s colleague, Kent Conrad, D-ND, echoed the sentiment, noting
opening the US border to Canadian cattle and less-restricted boxed beef
was “premature.”

R-CALF, the Billings, MT-based ranching group angrily denounced the rule
before and after the discovery of the Canadian mad cow, saying the cow
proves that Canada does not--never did--enforce the ban on animal
protein in livestock feed. Recycled animal protein in livestock feed is
thought to foster BSE in ruminants.

R-CALF will challenge the rule both in Congress and in federal court.
“The new rule is arbitrary and capricious,” notes R-CALF’s chief Bill
Bullard. “We will work with Congress to kill it and, at the same time,
go to court to get it tossed out.”

The American Meat Institute, lobbyist for the nation’s giant
meatpackers, have already filed suit in Washington, D.C. federal court
claiming the rule doesn’t go far enough or quickly enough to open the

According to Michael Stumo of the Organization of Competitive Markets,
AMI is using the proposed Dec. 29 rule to attack the present, no live
cattle import rule. “The goal, as I understand it,” says Stumo, “is to
litigate the correctness of the proposed rule in order to have the
underlying rule declared void,” explains Stumo.

The National Farmers Union called on USDA to “withdraw their plan to
reopen the border for live cattle trade with Canada” and “not speed up
the process” with it.

Moreover, added NFU President Dave Frederickson, US consumers will be
unable to determine if the meat they are buying after March 7 is
American or Canadian because USDA “continues to oppose mandatory country
of origin labeling and mandatory BSE testing of animals from countries
with documented BSE cases.”

Keith Bolin, president of the American Corn Growers Assoc. and a corn
and livestock producer from Illinois, questioned USDA’s decision to go
forward with the import rule.

USDA, Bolin said Jan. 5, should “move more slowly and cautiously for the
safety of the American consumer and protect the profitability of the
American cattleman. Failure to do so will have far-reaching consequences
on all components of the US food and agriculture sectors.”

Despite the calls from Congress, farm groups and consumer groups to
delay the rule, Veneman’s only comment was no comment.

Trade, Not Safety, Behind Rule to Import Canadian Cattle, Meat

In the 90-page cost/benefits analysis that accompanied USDA’s Dec. 29
rule to expand imports of Canadian beef into the US, the Animal Plant
Health Inspection Service gave three reasons for the change now.

First, noted APHIS, “This rule ensures the continued protection of the
U.S. food and feed supply from BSE.”

Second, the rule “remove(s) unnecessary prohibitions on the importation
of certain commodities from minimal-risk regions.”

And third, “By establishing criteria for minimal-risk regions, the
United States has taken a leadership role in fostering trade of low-risk
products with countries that have a low incidence of BSE and
historically strong risk mitigation measures.”

We’re not making this up.

APHIS says the US needs to import cattle from the only North American
nation known to have BSE in order to protect the US from BSE; needs to
removes unnecessary rules surrounding that protection; and needs to
bring in cattle from a nation known to have BSE so we can export more
cattle from a nation that doesn’t have BSE.

As whacky as those reasons are each shows just how creative the
pro-packers forces inside APHIS can be to aid their friends--in this
case, the giant meatpackers who operate on both side of the 48th
parallel--in agribusiness.

After all, the rule would make Canada the first “minimal risk”
country--that’s Potomac-speak for “yes, there’s mad cow in Canada,
but...”--to export beef to the US despite confirmed evidence of BSE.

By itself, the rule and what it permits should be cause to reconsider
allowing any Canadian beef into the US. Currently, boxed, deboned
Canadian beef from cattle younger than 30 months of age is exported to
the US.

The new rule, however, allows live fat and feeder cattle less than 30
months into the US and virtually any and all boxed, bone-in beef of any
age--including cows--into the US.

That latter fact undermines USDA’s every reason for the rule. All three
Canadian-origin cattle found to have mad cow since May 2003 were cows:
two Holsteins and one beef cow. Given that simple fact, how can allowing
bone-in cow beef into the US make the US meat supply safer?

It can’t and it defies simple common sense that it will.

Also, just what are “unnecessary prohibitions” when it comes to
protecting the health of America’s 95 million beef cattle and 9 million
dairy cows? We can’t think of one, especially when considering rules
surrounding BSE.

Indeed, if just one mad cow is found in the US or Canada after the
effective March 7 date of the rule, the biggest segment of US
Agriculture--beef, responsible for nearly $60 billion of 2004’s $210
billion in gross farm sales--the new rule will be cost many of America’s
meat producers their livelihoods.

Moreover, due to the undying efforts of meatpackers, the 2002 Farm
Bill’s requirement to label the country of origin for all meat sold in
America is still not in place. That means American consumers will be
unable to distinguish between US and Canadian beef when buying meat
after March 7.

That failure by itself almost guarantees US meat sales will take hit
when bone-in Canadian cow beef enters the US early this spring.

And that’s before one considers the effect of the rule on US beef
exports. APHIS attempts to address this by noting all imported Canadian
fats and feeders will tagged, monitored, raised and slaughtered as a
group once inside the US.

The reason for the stringent tracking is simple: USDA hopes to reassure
foreign buyers of the US beef that they will not receive Canadian beef
when the imports start to flow south.

Take a moment to consider what that actually means.

First, the tracking of Canadian animals in the US means the US will
mandate live cattle identification, tracking and segregation both in the
feedlot and slaughter plant of the imported animals. All are measures
USDA, meatpackers and the packer lackeys at the National Cattlemen’s
Beef Association have fought against for years.

Now, however, all and more can and will be done to accommodate Canadians
imports and reassure US export customers.

That’s confuses us. If all this be done to support Canadian beef imports
and US beef export customers, why can’t it also be done for US beef and
US consumers?

In short, USDA’s Canadian beef rule undermines every argument the agency
has ever made against the mandatory country of origin labeling.

Also, USDA, packers and the NCBA have stopped mandatory country of
labeling in the US on grounds that it would be too costly. They peg it
costs at an out-of-this-world price of estimated over $20 per head.

APHIS now estimates its proposed tracking of Canadian cattle under the
proposed Canadian cattle rule at $10 per head.

If accurate, how is it that segregating, tracking and slaughtering
Canadian cattle in the US is one-half the cost of segregating, tracking
and slaughtering US cattle in the US?

It’s not, of course, but few American cattlemen are pushing USDA to
explain it.

The point here is as obvious as a 1,100-pound steer in your bedroom: The
Dec. 29 rule is not about American food safety or import regulations.
It’s about trade.

According to the APHIS cost benefit analysis, USDA reckons the net
benefit of the rule--what the nation gets by importing Canadian cattle
and more Canadian boxed beef, other than the threat of more BSE--at
between $16 million and $75 million.

That means, explains one noted ag economist, American consumers will
save between 6-cents and 26-cents per person because beef prices to
consumers will (hopefully) drop when the imports hit American markets.

APHIS also notes that the importation of live Canadian cattle, estimated
at 1.5 million to 2 million head, and the bringing in of more boxed
Canadian beef, will drain $2.96 billion to $3.11 billion from US cattle

That cost, however, may be tiny compared to the devastation cattlemen
will suffer if just one more mad cow shows up in either Canada or the US
after March 7, the effective date of the new APHIS rule.

Congress can stop this madness, however, by rejecting the rule and
slamming USDA and APHIS back into their rightful place--protectors of
American consumers and American markets, not of global meatpackers.

Already, both the Senate and the House ag committees have promised
separate hearings on the rule and impact on US cattlemen.

Hear Ye, Hear Ye: Johanns Says Little at Confirmation

If there’s one rule Presidential appointees need to follow when
testifying before Senate committees during confirmation hearings it’s
this: As long as you don’t stand on the witness table, get naked and
bark like a mad dog it’s 99% certain you’ll be confirmed.

Ag secretary-nominee Michael Johanns followed the rule Thursday, Jan. 6,
in his confirmation hearing before the Senate Ag Committee and the
Committee actually confirmed him to run USDA while the three-hour
hearing continued.

Love, not luck, was in the air at the hearing. Senators from both
parties parried more with each other--in tossing bouquets and kudos to
Nebraska governor--than with the nominee. To hear them talk Thursday, US
farmers and ranchers should canonize the corporate farming supporter
Johanns immediately.

For his part, the not-yet two term governor from one of the nation’s
largest meat and grain producing states was barely pushed to answer any
tough question. But his dull, listless answers did provide valuable
insight to his future tenure at USDA.

When Sen. Max Baucus, D-MT, pressed Johanns to offer his personal stand
on country of origin labeling, the soon-to-be-secretary said the Bush
Administration didn’t favor COOL and, since he worked for the Bush
Administration, he didn’t favor it either.

How’s that for boldness and independence? At least he’s loyal to the boss.

Sen. Tom Harkin, the committee’s ranking minority member, kindly
reminded Johanns that the White House and Veneman-led USDA had sliced
$1.2 billion from mandated, 2002 Farm Bill programs like conservation,
rural development and broadband for rural citizens.

Would the 2006 Bush budget renew this required spending, asked Harkin.

Johanns reply was that of a career politician: Frankly, he noted, he had
not been privy to any 2006 USDA budget talks at the White House and,
more importantly, had not sought a briefing on the budget.

Golly, what you don’t know you can’t testify to, right?

Johanns often reached back to his Nebraska days to assure senators that
he knew farmers and ranchers and ag trade and biotechnology and sugar
and ... and on and on and on. Sen. Pat Roberts, R-KS, was so taken by
the nominee that he said Johanns is the kind a fella’ “who can sit on
the wagon tongue and talk to farmers.”

Of course, nothing might fall from the new secretary’s tongue while
seated on the wagon tongue, but that was OK by Roberts whose last
brainstorm was Freedom to Farm.

When asked about USDA’s controversial new rule to allow more Canadian
beef imports, Johanns trotted out every nominee’s stock reply--“As
nominee I would not indicate a position”--and got away with it.

So much for USDA’s role in protecting US consumers while promoting packers.

The hearing reached its zenith by not reaching at all. No senator
pressed Johanns to explain his 2004 attempt to gut Nebraska’s Initiative
300, the nation’s toughest anti-corporate farming law.

The only moment of unvarnished honesty in the lengthy, nap-inducing
exercise occurred when Colorado’s new senator, Democrat Ken Salazar,
abruptly stopped his questioning.

The halt caused an uncharacteristic moment of perfect silence and caught
Sen. Pat Robert, chairing the hearing at this point, off-guard. Is the
senator through his questions, asked Roberts?

No, replied Salazar, but my time to question the nominee has expired.

Well, said Roberts, with a little more experience the new senator will
soon learn that the only rule the Senate does follow is that time means

So too, it seems, do confirmation hearings.

>Kansas Republican Pat Roberts questioned Johanns on the
>yet-to-be released report on USDA's plan to expand imports of processed
>beef items like tongues.

Journal of Virology, January 2003, p. 583-591, Vol. 77, No. 1
0022-538X/03/$08.00+0 DOI: 10.1128/JVI.77.1.583-591.2003
Copyright © 2003 , American Society
for Microbiology . All Rights Reserved.

Rapid Prion Neuroinvasion following Tongue Infection

Jason C. Bartz,1 Anthony E. Kincaid,2 and Richard A. Bessen1*

Department of Medical Microbiology and Immunology,1 Department of
Physical Therapy, Creighton University, Omaha, Nebraska 681782

Received 24 July 2002/ Accepted 30 September 2002

Food-borne transmission of prions can lead to infection of the
gastrointestinal tract and neuroinvasion via the splanchnic and vagus
nerves. Here we report that the transmission of transmissible mink
encephalopathy (TME) is 100,000-fold more efficient by inoculation of
prions into the tongues of hamsters than by oral ingestion. The
incubation period following TME agent (hereinafter referred to as TME)
inoculation into the lingual muscles was the shortest among the five
nonneuronal routes of inoculation, including another intramuscular
route. Deposition of the abnormal isoform of the prion protein, PrPSc,
was first detected in the tongue and submandibular lymph node at 1 to 2
weeks following inoculation of the tongue with TME. PrPSc deposits in
the tongue were associated with individual axons, and the initial
appearance of TME in the brain stem was found in the hypoglossal nucleus
at 2 weeks postinfection. At later time points, PrPSc was localized to
brain cell groups that directly project to the hypoglossal nucleus,
indicating the transneuronal spread of TME. TME PrPSc entry into the
brain stem preceded PrPSc detection in the rostral cervical spinal cord.
These results demonstrate that TME can replicate in both the tongue and
regional lymph nodes but indicate that the faster route of brain
invasion is via retrograde axonal transport within the hypoglossal nerve
to the hypoglossal nucleus. Topical application of TME to a superficial
wound on the surface of the tongue resulted in a higher incidence of
disease and a shorter incubation period than with oral TME ingestion.
Therefore, abrasions of the tongue in livestock and humans may
predispose a host to oral prion infection of the tongue-associated
cranial nerves. In a related study, PrPSc was detected in tongues
following the intracerebral inoculation of six hamster-adapted prion
strains, which demonstrates that prions can also travel from the brain
to the tongue in the anterograde direction along the tongue-associated
cranial nerves. These findings suggest that food products containing
ruminant or cervid tongue may be a potential source of prion infection
for humans.

* Corresponding author. Mailing address: Department of Medical
Microbiology and Immunology, Creighton University, 2500 California
Plaza, Omaha, NE 68178. Phone: (402) 280-3072. Fax: (402) 280-1875.
E-mail: .

Journal of Virology, January 2003, p. 583-591, Vol. 77, No. 1
0022-538X/03/$08.00+0 DOI: 10.1128/JVI.77.1.583-591.2003
Copyright © 2003 , American Society
for Microbiology . All Rights Reserved.


© SEAC 2003 1
SEAC were asked to advise on the possible BSE risk to the UK population
from the
consumption of tonsil present on ox tongue. Although the scientific
evidence does not
conclusively prove that tonsil tissue on ox tongue could be infective,
SEAC agreed it was
prudent to assume this was the case. SEAC considered that in view of the
level of
scientific uncertainty in this area it was not possible to advise
precisely on the magnitude
of that risk. However, the committee agreed that any BSE risk from
eating tongue was
likely to be very small.
The Committee published a statement in October 2002 when it considered
new research
showing BSE infectivity had been found in bovine palatine tonsil. The
recommended that an assessment of BSE risk from bovine tonsil be
conducted. This
work was commissioned by the Food Standards Agency, and presented to
SEAC at the
June 2003 meeting.
The Committee was asked to advise on two reports
• A Veterinary Laboratories Agency (VLA) report on the presence of
tonsil tissue on
ox tongue.
• An assessment of BSE risk from bovine tonsil carried out by DNV consulting
© SEAC 2003 2
Distribution of tonsil tissue in Ox tongue
Bovine tonsil is not a single organ but comprises tissue that is
discrete (palatine tonsil)
and tissue organised more diffusely, such as lingual tonsil present on
ox tongue. Bovine
tonsil is Specified Risk Material (SRM) from 6 months of age in cattle
from the UK and
Portugal, and from 12 months of age in cattle from other EU countries.
Ox tongue is not
classified as SRM and is sold for human consumption. The location of
palatine tonsil
means that it is unlikely to be removed with ox tongue, but there is a
possibility that some
lingual tonsil might be present in tongue prepared for human consumption.
In October 2002, the Committee recommended that it would be prudent to
carry out
further examination of the amount and distribution of tonsillar tissue
present in ox tongue
prepared for human consumption. Subsequently, an examination of current
showed that the majority of tongues prepared for human consumption
contained some
lingual tonsil. Twenty four percent (24%) of tongues examined were free of
macroscopically visible lingual tonsil. In 26% of tongues examined, the
majority of lingual
tonsil was removed but identifiable tonsillar tissue was still present.
However, a
significant amount of tonsillar tissue was present on about 50% of
tongues examined. It
was also shown that even when all macroscopically visible tonsil tissue
had been
removed from ox tongue, microscopic tonsil tissue could still be present.
The Committee noted the implications of these findings with respect to
new EU
legislation due for introduction in October 2003. The research showed
that the EU
proposed method of harvesting ox tongue would not exclude all tonsillar
tissue from
tongues intended for human consumption.
Infectivity in tonsil tissue
Cattle were experimentally infected with BSE, and pooled palatine tonsil
tissue was taken
from animals culled 10 months post inoculation (m.p.i.). Samples of this
tissue were
inoculated (intracerebrally) into five calves. The Committee was
notified in September
2002 when one animal from this group developed BSE at 45 m.p.i. These
assays are
still ongoing and to date the other four animals in this group remain
healthy with no
clinical evidence of BSE at 58 m.p.i. Additional groups that received
pooled palatine
tonsil taken from animals at different time points after inoculation
with BSE (6,18 & 26
m.p.i.) are also still healthy at 51 to 55 m.p.i.
© SEAC 2003 3
The Committee acknowledged that a single finding supports the evidence
for infectivity of
palatine tonsil. They agreed that there was no direct evidence to
suggest that lingual
tonsil on ox tongue was infective. However, the positive finding in
palatine tonsil meant
that infectivity in the lingual tonsil, which has not been specifically
assayed for infectivity,
could not be ruled out. No infectivity was detected in ox tongue in the
mouse bioassay
but ox tongue has not been tested in the more sensitive cattle bioassay.
The Committee
reiterated their previous opinion that, although the possibility of
experimental artefact
could not be excluded, it was prudent to assume that this research
suggested evidence
of infectivity in all bovine tonsil tissue.
The Committee recommended that tongue from experimentally challenged animals
should be examined for the presence of prion protein (PrPSc). A positive
result would
indicate the potential for infectivity although a negative result would
not necessarily
exclude this possibility. A positive result would also help to ascertain
if PrPSc was
associated with discrete follicular, diffuse lymphoid tissue or with
other structures in
lingual tonsil as this could influence the final evaluation of risk.
Members highlighted the scientific uncertainty over the postulated route
of infection for
tonsil. To date, no infectivity has been detected by the mouse bioassay
in material from
the tongue, cranial cervical ganglion and lymph nodes of the head from
preclinical or
clinical cases of BSE, whether experimental or naturally infected.
Pooled lymph nodes
and spleen taken from naturally infected BSE cases did not show evidence
of infectivity
in the cattle bioassay. Also, infectivity has not been detected in
mesenteric, prescapular
and popliteal lymph nodes (some pooled) in the cattle pathogenesis
experiment following
intracerebral inoculation of tissues collected at 6, 18 and 26 month
post exposure. The
Committee noted that this assay is ongoing and currently at 52 to 55 m.p.i.
Members noted that if infectivity is detected in bovine tongue it may
not necessarily
derive from lymphoid tissue but could reside in the associated nerves.
This suggestion
was based on experimental research on scrapie pathogenesis in hamsters,
showed that the hypoglossal nerve in the tongue could act as a reservoir
of prion
infection after direct inoculation into the tongue as well as
intracerebral inoculation.
© SEAC 2003 4
Assessment of potential public health implications
The risk assessment considered the possible range of human exposure to
BSE infectivity
from the consumption of bovine tonsil present on ox tongue.
As the amount of tonsil that might be consumed with tongue was not
defined, one
exposure estimate in the risk assessment was based on the assumption
that 100% of the
tonsil tissue, estimated to be 50g, is present on every tongue consumed.
The Committee
agreed this was a precautionary estimate. It was likely that tongue
would be peeled
before consumption. This would remove the superficial layer, reducing
the amount of any
adherent tonsil tissue and thus the exposure. Also, tongue meat is
usually served sliced
making it unlikely that one person would consume all the lymphoid tissue
remaining on
any one tongue.
The risk assessment also considered a more plausible scenario in which
10% of tonsil
tissue was present on the tongue when consumed.
Estimates of infectivity of tonsil tissue
For the purposes of the risk assessment, the total infectivity of a
tonsil was estimated as
0.25 bovine oral ID50 units in an infected animal. It was assumed that
infectivity was
present in the tonsil tissue at a similar level over the entire
incubation period of the
disease. The quantitative estimate of worst-case exposure to infectivity
for a population
(assuming all tonsil was included with the tongue) was calculated as 90
bovine oral ID50
units per year, distributed over the tongue-eating population.
The Committee identified a number of key scientific uncertainties in
this estimate. The
main area of uncertainty was the level of infectivity in tonsil tissue.
This was estimated by
extrapolation of the BSE incubation period for palatine tonsil (45
m.p.i.) from a dose
response curve based on BSE-infected brain tissue. Members agreed it
would have been
preferable to base the estimate of infectivity of tonsil on a dose
response curve derived
from lymphoid tissue, but this information was not currently available.
The Committee
noted that inter-animal variations in incubation period could also
increase the uncertainty
in estimates of tonsil infectivity.
© SEAC 2003 5
This research does not conclusively show that tongue is infective.
However, the
Committee agreed that in view of the paucity of data, it was prudent to
assume that a risk
existed for those who consumed bovine tongue.
The Committee agreed the risk of human infection was likely to be very
small but
concluded that it was not possible to advise the FSA precisely on the
magnitude of the
risk due to the uncertainty inherent in the data used for the risk
The long incubation period of BSE in the animal that developed disease
after challenge
with palatine tonsil and the fact that only a single animal has to date
developed disease
suggests that the infectivity of this tissue was low. The Committee
reiterated its previous
advice that any potential BSE risk was likely to be low given the
decline of the BSE
epidemic in the UK and the existing feed controls.
The Committee identified further scientific work that would help refine
the risk estimates
and reiterated previous recommendations that further study on lymphoid
tissues and
tongue from cattle should be carried out, using the most sensitive
assays, as these
become available.


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