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From: TSS ()
Subject: USDA RELEASES TECHNICAL ASSESSMENT ON THE IMPLEMENTATION OF THE CANADIAN FEED BAN
Date: February 25, 2005 at 12:35 pm PST
-------- Original Message --------
Subject: USDA RELEASES TECHNICAL ASSESSMENT ON THE IMPLEMENTATION OF THE CANADIAN FEED BAN
Date: Fri, 25 Feb 2005 14:30:30 -0600
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
To: BSE-L@LISTSERV.KALIV.UNI-KARLSRUHE.DE
##################### Bovine Spongiform Encephalopathy #####################
Release No. 0066.05 Ed Loyd (202) 720-4623
Jim Rogers (202) 690-4755 USDA RELEASES TECHNICAL ASSESSMENT ON THE IMPLEMENTATION OF THE CANADIAN FEED BAN WASHINGTON, Feb. 25, 2005-The U.S. Department of Agriculture today released its assessment of the Canadian ruminant-to-ruminant feed ban. Agriculture Secretary Mike Johanns in a hearing Feb. 3 before the Senate Agriculture Committee stated that USDA would be "absolutely transparent" with the results of the assessment and would immediately release it when it was available.
"After the two recent BSE finds in Canada, it was important to get a team up there to conduct a firsthand assessment of Canada's compliance with the feed ban," said Dr. Ron DeHaven, Administrator of USDA's Animal and Plant Health Inspection Service (APHIS). "This assessment affirms our science-based decision to begin lifting the ban on live ruminants and ruminant products from Canada that have virtually no risk to human or animal health."
USDA assembled a team of technical experts that arrived in Canada on Jan. 24 to gather all relevant information to do an in-depth assessment on Canada's ruminant-to-ruminant feed ban and their feed ban inspection program. USDA took this additional step to ensure compliance with Canada's feed ban control measures. The feed ban has been determined to be an important BSE risk mitigation measure to protect animal health.
The inspection team's report states that "Canada has a robust inspection program, that overall compliance with the feed ban is good and that the feed ban is reducing the risk of transmission of bovine spongiform encephalopathy in the Canadian cattle population."
In both the risk assessment conducted by APHIS as part of the BSE minimal-risk rule and the feed ban assessment announced today, the agency found that compliance by feed mills and rendering facilities in Canada to their feed ban regulations is good and, just like the United States, Canada is continually looking for ways to make it even better.
USDA is confident that the animal and public health measures that Canada has in place to prevent BSE, combined with existing U.S. domestic safeguards and additional safeguards provided in the final rule, provide the utmost protections to U.S. consumers and livestock. When Canadian ruminants and ruminant products are presented for importation into the United States, they become subject to domestic safeguards as well. On Jan. 4, USDA published a final rule that amends the regulations to provide for the importation of certain ruminants, ruminant products and byproducts from regions that pose a minimal risk of introducing BSE. Canada will be the first country recognized as a minimal-risk region and, as such, will be eligible to export to the United States live cattle, as well as certain other animals and products, from animals under 30 months of age. Live cattle imported from Canada under this rule will be subject to restrictions designed to ensure that they are slaughtered by the time they reach 30 months of age. These include permanent marking of the animals as to their origin, requiring them to move in sealed containers to a feedlot or to slaughter, and not allowing them to move to more than one feedlot while in the United States. The rule is to go into effect on March 7, 2005. For a copy of the feed ban assessment, the final rule, and other documents pertaining to BSE, visit the APHIS BSE website at http://www.aphis.usda.gov/lpa/issues/bse/bse.html #TSS USDA News
oc.news@usda.gov
202 720-4623 >"This assessment affirms our science-based decision to begin lifting the ban on live ruminants and ruminant products from Canada that have virtually no risk to human or animal health."
THEY don't know what science base means...
>The inspection team's report states that "Canada has a robust inspection program, that overall compliance with the feed ban is good and that the feed ban is reducing the risk of transmission of bovine spongiform encephalopathy in the Canadian cattle population."
sure it does??? this is what happens when you stack the
deck with corporate industry for decision making while
ignoring all the science $$$
the only thing that matters to these people is opening
up the borders for the global trading again. IF this
happens, they will also be opening the door for the legal
trading of all strains of TSEs. THAT is all in the world
GWs MRR will do, and exactly what it was suppose to do. Working Group Report on
the Assessment of the Geographical BSE-Risk (GBR) of
CANADA snip... Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the
Geographical BSE Risk of Canada
- 11 - snip...
In 1990, when BSE was made notifiable, this awareness was extended to
suspicions of BSE.
" Since 1993 the number of brains examined per year did exceed the number
recommended by OIE
(300 - 336 for countries with a cattle population over 24
months of age of 5.0 to 7.0 Million)
PLEASE NOTE BEFORE GOING ANY FURTHER THAT MOST EVERY COUNTRY THAT WENT BY THOSE
SAME OIE BSE GUIDELINES HAVE BSE NOW. THE ONLY REASON IT WAS NOT DETECTED SOONER
IN THESE COUNTRIES WERE BECAUSE OF THESE SAME OIE GUIDELINES. SIMPLY PUT,
THEY ARE WRONG IN RELATIONS TO TSEs. IT'S NOTHING MORE THAN AN EXCUSE,
ONE THAT FLIES ABOUT LIKE A COW WOULD...TSS
in all years, except in 1995 (table 4).
year 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003
samples 225 645 426 269 454 759 940 895 1´020 1´581 3´377 3´361
Table 4: Number of bovine brains annually examined for CNS diseases, including BSE.
" According to the CD approx. 98% of the examined cattle were older than 24 months
and approx. 90% exhibited neurological symptoms. Although the identification
system of Canada does not document the birth date or age of the animals, according
to the CD, examination of the dentition is used to ascertain the maturity of the
animals.
" The list of neurological differential diagnoses for the 754 brains examined in 1997
included encephalitis (70 cases), encephalomalacia (19), hemophilus (7),
hemorrhage (2), listeriosis (38), meningoencephalitis (36), rabies (22), tumors (2),
other conditions (135) and no significant findings (423).
" Compensation is paid for suspect BSE cases as well as for animals ordered to be
destroyed (90-95% of market value with a maximum of 2,500 Can$ per cow).
" Diagnostic criteria developed in the United Kingdom are followed at ADRI,
Nepean. According to the very detailed protocol for the collection, fixation and
submission of Bovine Spongiform Encephalopathy (BSE) specimens at abattoirs
under inspection by the Canadian Food Inspection Agency, the specimen shall be
shipped to National Center for Foreign Animal Disease, Winnipeg, Manitoba.
" In 2003, around 3000 animals from risk populations have been tested.
" According to the CD, it is aimed to test a minimum of 8000 risk animals (animals
with clinical signs consistent with BSE, downer cows, animals died on farm animals
diseased or euthanized because of serious illness) in 2004 and then continue to
progressively increase the level of testing to 30,000.
" In May 2003, Canada reported its first case of domestic BSE. A second case was
detected in the US on 23 December 2003 and traced back to Canadian origin. Both
were born before the feed ban and originated from Western Canada.
3.3 Overall assessment of the stability
For the overall assessment of the stability, the impact of the three main stability factors
(i.e. feeding, rendering and SRM-removal) and of the additional stability factor,
surveillance, has to be estimated. Again, the guidance provided by the SSC in its
opinion on the GBR of July 2000 (as updated January 2002) is applied.
Until 1997, it was legally possible to feed ruminant MBM to cattle and a certain fraction of
cattle feed (for calves and dairy cattle) is assumed to have contained MBM. Therefore
feeding was Not OK . In August 1997 a ruminant MBM ban was introduced but feeding
of non-ruminant MBM to cattle remained legal as well as feeding of ruminant MBM to
non-ruminant animals. This makes control of the feed ban very difficult because laboratory
differentiation between ruminant and non ruminant MBM is difficult if not impossible.
Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the
Geographical BSE Risk of Canada
- 12 -
Due to the highly specialised production system in Canada, various mammalian MBM
streams can be separated. Such a feed ban would therefore be assessed as "reasonably
OK", for all regions where this highly specialised system exists. However, several areas
in Canada do have mixed farming and mixed feed mills, and in such regions, an RMBM
ban would not suffice. Additionally, official controls for cattle feeds to control for the
compliance with the ban were not started until the end of 2003. Thus, for the whole
country, the assessment of the feeding after 1997 remains "Not OK".
Rendering
The rendering industry is operating with processes that are not known to reduce infectivity.
It is therefore concluded that the rendering was and is Not OK .
SRM-removal
SRM and fallen stock were and are rendered for feed. Therefore SRM-removal is assessed
as Not OK
BSE surveillance
Before 1989, the ability of the system to identify (and eliminate) BSE-cases was limited.
Since 1990 this ability is improved, thanks to a specific (passive) BSE surveillance.
Today the surveillance should be able to detect clinical BSE-cases within the limits set
by an essentially passive surveillance system.
" Passive surveillance has been carried out since 1990. In 1993 surveillance was
intensified and has considerably improved with mandatory reporting and basic
compensation ensured, awareness raising measures and education of veterinarians, and
a specific BSE-surveillance programme targeting cattle showing clinical signs that
could be compatible with BSE.
" The initiated introduction of active surveillance should improve the system
significantly.
Stability of the BSE/cattle system in CANADA over time
Stability Reasons
Period Level Feeding Rendering SRM
removal
BSE
surveillance
1980 to 2000 Mainly
passive
2001 to 2003
Extremely
unstable Not OK Not OK Not OK
Improving
with some
testing of
risk groups
Table 5: Stability resulting from the interaction of the three main stability factors and the BSE
surveillance. The stability level is determined according to the SSC-opinion on the GBR of July 2000 (as
updated in 2002).
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
- 14 -
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.
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
into account.
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
GBR.
" 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
- 15 -
fallen stock and emergency slaughter, by means of rapid screening, would allow
monitoring the efficiency of stability enhancing measures.
Documentation provided to EFSA
" Letter with the ref D(2003)KVD/ip/420722 from the European Commission
requesting a geographical risk assessment for the appearance of BSE in a
country.
" Country Dossier as prepared by the country in response to the EC and EFSA
data collection request.
" Other sources of data information i.e. exports from third countries and
Eurostat data.
" SSC, July 2000. Final opinion on the Geographical Risk of Bovine
Spongiform Encephalopathy (GBR).
" SSC, January 2002. Updated opinion on the Geographical Risk of Bovine
Spongiform Encephalopathy (GBR).
Acknowledgment
Members of the EFSA Scientific Expert Working Group on GBR are acknowledged for
their valuable contribution to this mandate. The members are: Didier Calavas, Aline De
Koeijer, Michael Gravenor, John Griffin, Dagmar Heim, Matthias Kramer, Riitta
Maijala, Mo Salman, Vittorio Silano, Emmanuel Vanopdenbosch, and Stig Widell.
CANADA http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/scr_annexes/563/sr02_biohaz02_canada_report_annex_en1.pdf
TSS
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