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From: TSS ()
Subject: USDA FSIS NOTICE 15-05 2-28-05 IMPORTATION OF CANADIAN CATTLE, SHEEP, AND GOATS INTO THE UNITED STATES
Date: March 2, 2005 at 9:59 am PST

-------- Original Message --------
Subject: USDA FSIS NOTICE 15-05 2-28-05 IMPORTATION OF CANADIAN CATTLE, SHEEP, AND GOATS INTO THE UNITED STATES
Date: Tue, 1 Mar 2005 14:41:38 -0600
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
To: BSE-L@LISTSERV.KALIV.UNI-KARLSRUHE.DE


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

UNITED STATES DEPARTMENT OF AGRICULTURE
FOOD SAFETY AND INSPECTION SERVICE
WASHINGTON, DC
FSIS NOTICE 15-05 2-28-05
IMPORTATION OF CANADIAN CATTLE, SHEEP, AND GOATS INTO THE UNITED
STATES
I. PURPOSE
This notice provides instructions to Food Safety and Inspection Service
(FSIS)
personnel regarding the receipt, slaughter, and inspection of certain
ruminants imported
from Canada. Regulatory requirements for the importation of certain Canadian
ruminants will begin March 7, 2005, and will apply to cattle, sheep, and
goats. As set
out in this notice, in certain limited circumstances, if inspection
program personnel find
that animals that have been delivered to a slaughter plant under the
Animal and Plant
Health Inspection Service (APHIS) regulations do not comply with those
regulations,
inspection program personnel are to hold the animals under the Animal Health
Protection Act (AHPA), pursuant to the authority delegated by APHIS.
II. BACKGROUND
On January 4, 2005, APHIS published the final rule, Bovine Spongiform
Encephalopathy: Minimal-Risk Regions and Importation of Commodities (70
FR 460 
553). This final rule amended APHIS regulations (9 CFR parts 93-96, see
Attachment
1) to provide for the importation of certain ruminants, and ruminant
products and
byproducts from regions that pose a minimal risk of introducing bovine
spongiform
encephalopathy (BSE) into the United States (U.S.), and designated
Canada as the first
minimal-risk region. These actions will continue to protect against the
introduction of
BSE into the U.S. while removing unnecessary prohibitions on the
importation of certain
commodities from minimal-risk regions for BSE. The rule was promulgated
under the
AHPA.
Only cattle that are less than 30 months of age and sheep and goats that
are less
than 12 months of age are eligible for importation into the U.S. from
Canada and eligible
for slaughter. The importation and slaughter of cattle 30 months of age
or older or of
sheep and goats 12 months of age or older is prohibited.
DISTRIBUTION: Inspection Offices;
T/A Inspectors; Plant Mgt; TRA;
ABB; TSC; Import Offices
NOTICE EXPIRES: 3/1/06 OPI: OPPED
Animals imported from Canada will go through specific ports of entry as
listed in
9 CFR 93.403(b) or as provided for in (9 CFR 93.403(f)). At the port,
the APHIS
veterinarian reviews documents and inspects the shipment to ensure that
it is being
imported in compliance with the regulations. The APHIS veterinarian also
has the
authority to offload animals for verification. Animals shipped directly
for slaughter will go
to official establishments in sealed trucks, will bear a Canadian ear
tag, will be
accompanied by VS Form 17-33 and a Canadian Health Certificate, and are
to be
slaughtered or euthanized within two weeks of entry into the U. S. and
are not to leave
the official premises.
Animals shipped to a feedlot and then to an official establishment for
slaughter will
bear a Canadian ear tag, and a C?N brand (for cattle), or a C brand (for
sheep and
goats), and will be accompanied by VS Form 1-27 and a copy of the
Canadian Health
Certificate, which indicates the age and other descriptive information
on each of the
animals. A federally accredited veterinarian, state representative, or USDA
representative at the feedlot will verify the presence of the Canadian
ear tag,
appropriate brands, and that cattle, sheep and goats meet all
requirements when they
go directly to slaughter under seal.
Only a USDA representative can break the seal on the truck containing
Canadian
animals upon arrival at an official establishment (i.e., FSIS inspection
program
personnel, an APHIS Technician or other APHIS representatives). FSIS
strongly
recommends that establishments receiving such ruminants implement
procedures that
ensure that trucks carrying the animals arrive at the establishment when
a USDA
representative is readily available to promptly break the seals on the
truck. These
procedures will facilitate prompt unloading of these ruminants and
humane handling in
connection with slaughter of these ruminants. However, in all cases, the
establishment
is to ensure that animals are humanely handled in accordance with the Humane
Methods of Slaughter Act and 9 CFR part 313.
An establishment is to have procedures in place to ensure that animals
arriving
directly from Canada for immediate slaughter are slaughtered as a group
(9 CFR 93.
436(a)(6)). This is not required for animals that arrive at slaughter
via a feedlot because
they may be separated and sent to different official establishments for
slaughter. To
facilitate the determination as to whether animals are eligible for
slaughter, a prudent
establishment should also maintain the identity of the animals from
Canada via a feedlot
until the marks of inspection are applied.
Although there are no new food safety requirements related to the
receipt of animals
from Canada, FSIS is reiterating that establishments receiving cattle
from Canada are
subject to the regulations regarding Specified Risk Materials (SRMs) at
9 CFR 310.22. Therefore, in accordance with 9 CFR 310.22(d)(3) an
establishment is
to evaluate the effectiveness of its procedures for the removal,
segregation, and
disposition of SRMs (as incorporated into its HACCP plans, Sanitation
SOPs, or
prerequisite program (9 CFR 310.22(d)(1)) whenever a change occurs that
could affect
the procedures such as ensuring that the Canadian animals are properly
identified.
Also, in accordance with 9 CFR 417.4(a)(3), an establishment is to
reassess its HACCP
system whenever there is a change in raw materials or in the source of
raw materials,
2
FSIS NOTICE 15-05
as would be the case here. Therefore, an official establishment that
begins to receive
eligible cattle from Canada will need to evaluate its SRM procedures,
reassess its
HACCP system, and incorporate necessary changes. The SRM requirements do not
apply to sheep and goats; however, an establishment receiving sheep and
goats from
Canada is to reassess its HACCP system and ensure that sheep and goats
presented
for slaughter are less than 12 months of age.
Unless the establishment can demonstrate through records or other means
that the
cattle are less than 30 months of age, FSIS will consider the cattle to
be 30 months of
age or older (9 CFR 310.22(e)) and therefore ineligible for slaughter.
FSIS will also
consider sheep and goats to be 12 months of age or older unless the
establishment can
demonstrate through records or other means that the sheep or goats are
less than
12 months of age.
III. DEFINITION AND FORMS
Hold: For purposes of this notice, when cattle 30 months of age or older
or sheep
and goats 12 months of age or older arrive at an official establishment,
or when the
proper documentation (i.e., seals, forms, tags) is not present or
accurate, inspection
program personnel are to ensure that the animals in question are
segregated and are
not moved to slaughter or outside the official premises (see the AHPA
and the
regulations at 9 CFR 93-96). In all cases, animals in question will be
moved off of the
means of transportation, into an area or pen at the official
establishment, and treated
under humane conditions. To execute the holding of animals and to
restrict their
movement under the AHPA, inspection program personnel will use a U.S.
Retained
tag applied to the pens containing the affected animals.
In addition to Canadian Health Certificates, the Veterinary Services
(VS) APHIS forms
that must accompany shipments of animals from Canada are as follows:
For Animals from Canada for Immediate Slaugther:
VS Form 17-33, Animals Imported for Immediate Slaughter
For Animals from Canada Shipped to a Designated/Approved Feedlot in the U.S.
Before Shipment to an Official Establishment:
VS Form 1-27, Permit for Movement of Restricted Animals
IV. INSPECTION PROGRAM PERSONNEL RESPONSIBILITIES REGARDING
HACCP SYSTEMS
A. Upon receipt of this notice Public Health Veterinarians (PHVs) are to
have an
awareness meeting at establishments that may choose to receive animals from
Canada. PHVs are to inform the establishment that if it decides to
receive animals from
Canada it will need to reassess its HACCP system as set out in 9 CFR
417.4(a)(3)
because the receipt of the animals, as a new source of raw materials, is
a change at the
establishment that may affect the HACCP system. The establishment needs
to be
3
separately approved by APHIS to receive these restricted Canadian
animals and can
obtain a list of plants approved to handle animals for immediate
slaughter at:
www.aphis.usda.gov/vs/ncie.
NOTE: If an establishment plans to receive bison from Canada, inspection
program
personnel are to contact the Technical Service Center.
B. In a memorandum of interview, the PHV is to document who was present
at the
initial awareness meeting, the date and time of the meeting, what was
discussed, and
any documents that were shared with management. Inspection program
personnel are
to maintain a copy of the memorandum in the official government file and
provide a
copy to the plant management.
C. After the establishment has performed its reassessment, PHVs are to
verify into
which programs (i.e., HACCP plans, Sanitation SOPs, or prerequisite
programs) the
establishment incorporated any procedures adopted as a result of its
reassessment.
PHVs are to verify that the establishment has appropriately addressed
in its HACCP
system the receipt of animals from Canada to ensure that animals
ineligible for
slaughter are not slaughtered. PHVs also are to verify, consistent with
the regulations
and current policy, that for cattle that are slaughtered, the SRMs are
properly
segregated, removed, and disposed (See 9 CFR 310.22, FSIS Notice 9-04,
Verification
Instructions For The Interim Final Rule Regarding Specified Risk
Materials (SRMs) In
Cattle, and FSIS Notice 10-04, Questions and Answers, Regarding the Age
Determination of Cattle and Sanitation).
D. Inspection program personnel will verify the execution of the
establishments
food safety systems and will issue a Noncompliance Record and take the
necessary
enforcement action if an establishment fails to follow its written
procedures as
incorporated into its food safety systems, (e.g., fails to ensure that
only animals of a
specified age are presented for slaughter). (See FSIS Directive 5000.1,
Revision 1,
FSIS Notices 9-04 and 10-04, and 9 CFR 417.3 and 416.15.) On-line inspection
program personnel are to notify the PHV or, if unavailable, other
off-line inspection
program personnel if they have reason to believe that an establishment's
SRM control
program, or the establishments segregation of Canadian animals, may be
ineffective
(for example, when repeated presentation of contaminated cattle heads or
carcasses for
post-mortem inspection at the rail and head inspection station indicates
failure to control
SRM contamination, or Canadian animals for direct slaughter are not
slaughtered as a
group). The PHV or other off-line personnel will perform the appropriate
HACCP or
Sanitation SOP procedures to evaluate the process.
V. VERIFICATION ACTIVITIES WHEN ANIMALS FROM CANADA ARRIVE AT
OFFICIAL ESTABLISHMENTS
A. Animals Shipped From Canada For Immediate Slaughter
Inspection program personnel will perform the following activities when
animals
are shipped from Canada for immediate slaughter.
1. Inspection program personnel will verify that a seal is present and
intact on
the shipping truck. The vehicle will be sealed with either a Canadian
government seal,
4
FSIS NOTICE 15-05
or a U.S. government seal. If the seal on the truck is missing or
broken, or otherwise
tampered with, inspection program personnel are to:
a. have all animals unloaded from the truck onto the official premises,
b. institute a hold on the animals in the pen and restrict movement using a
U.S. Retained tag applied to the pens,
c. promptly contact the District Office so that it can notify the APHIS AVIC
with jurisdiction in the state where the official establishment is
located. (See
http://www.aphis.usda.gov/vs/area_offices.htm for addresses of AVICs).
2. The AVIC will directly notify the establishment on disposition of the
affected
animals. An establishment may have a letter on file from the AVIC
regarding the
disposition of animals from Canada, and the establishment is to dispose
of the animals
in accordance with the letter.
NOTE: Inspection program personnel are to consider Canadian animals that
are on the
truck and that are nonambulatory-disabled or dead on arrival to be
presented for
inspection. Inspection program personnel are to verify that they are
handled humanely,
euthanized (where applicable), entered into e-ADRS, and, for cattle,
sampled for the
BSE surveillance program as set out in FSIS Notice 28-04 and 29-04.
3. After verifying that the truck is properly sealed, inspection program
personnel
are to break the seal. Only a USDA representative can break the seal on
the truck (i.e.,
FSIS inspection program personnel, an APHIS Technician or other APHIS
representatives).
4. Inspection program personnel are to verify that the establishment
follows its
procedures for immediately off-loading and segregating the entire group
of animals onto
the official premises.
5. Inspection program personnel are to verify that:
a. a VS Form 17-33 and a Canadian Health Certificate are present,
b. the establishment follows its procedures to ensure that there are no
animals in the group that are not listed on the Health Certificate, and
c. the establishment follows its procedures to ensure that the animals
listed
on the VS Form 17-33 are tagged as follows:
i. bovine are to be individually identified by an official Canadian Food
Inspection Agency (CFIA) ear tag, and
ii sheep and goats are to be individually identified by an official CFIA ear
tag.
5
NOTE: Animals may arrive with forms in addition to the VS Form 17-33 and
Canadian
Health Certificate. Inspection program personnel are to maintain copies
of any
additional documents in the inspection file, however there are no
verification or
distribution activities that inspection program personnel are to perform
related to these
other documents.
6. Inspection program personnel are to institute a hold on the animals in
question with a U.S. Retained tag applied to the pens and promptly
contact the District
Office so that it can notify the APHIS AVIC if:
a. the VS 17-33 or the Canadian Health Certificate is not present,
b. the establishment has found animals that are not listed on the Health
Certificate,
c. the establishment has failed to follow its procedures referenced in
paragraph V. A. 4 of this notice.
7. The AVIC will directly notify the establishment of subsequent actions. An
establishment may have a letter on file from the AVIC regarding the
disposition of any
ineligible animals from Canada, and the establishment is to dispose of
the ineligible
animals in accordance with the letter.
8. Inspection program personnel are to verify that the establishment
takes the
appropriate action as set out its procedures for the removal,
segregation, and disposition
of SRMs and as incorporated into its HACCP system.
B. Animals from Canada Shipped to a Feedlot into the U.S. before Shipment to
an Official Establishment
1. Inspection program personnel will follow the instructions in section
V. A. 1.
through 4.
2. Inspection program personnel are to verify that:
a. VS Forms 1-27 and a Canadian Health Certificates accompany the
shipment, and
b. the establishment follows its procedures to ensure that there are no
animals in the group that are not listed on the VS Forms 1-27.
NOTE: Due to the fact that Canadian origin animals may leave the feedlot
at different
times, the Canadian Health Certificates may have more animals listed
than on the VS
Forms 1-27, and there may be more than one Canadian Health Certificate
attached to
the VS Forms 1-27. Inspection program personnel are to maintain copies
of any
additional documents in the inspection file, however there are no
verification or
distribution activities that inspection program personnel are to perform
related to these
6
FSIS NOTICE 15-05
other documents.
3. Inspection program personnel are to institute a hold on the animals
in question
with a U.S. Retained tag applied to the pens and promptly contact the
District Office so
that it can notify the APHIS AVIC if:
a. The VS Forms 1-27 or the Canadian Health Certificates is not present,
b. the establishment has found animals that are not listed on the VS Form
1-27, or
c. the establishment has failed to follow its procedures that are
referenced in
paragraph V. B. 2. b. of this notice.
4. The AVIC will directly notify the establishment of subsequent actions. An
establishment may have a letter on file from the AVIC regarding the
disposition of any
ineligible animals from Canada, and the establishment is to dispose of
the ineligible
animals in accordance with the letter.
5. Inspection program personnel are to verify that the establishment
takes the
appropriate action as set out its procedures for the removal,
segregation, and
disposition of SRMs and as incorporated into its HACCP system.
VI. ANTEMORTEM AND POSTMORTEM VERIFICATION ACTIVITIES
A. Antemortem Inspection
1. Inspection program personnel are to conduct routine antemortem
inspection,
after the establishment has completed the procedures it has in place for
segregating
cattle and as incorporated into its HACCP system. (See FSIS Notice 7-04, and
9-04). As instructed in FSIS Notice 10-04:
a. while performing verification activities related to the age of
cattle, inspection
program personnel are to verify, in establishments using documentation,
that the
records support the establishments determinations. If the records do
not support the
determinations, inspection program personnel are to verify that the
establishment takes
the appropriate corrective action under 9 CFR 417.3(a) or (b).
NOTE: Hands-on dentition examinations are not to be used to determine
the adequacy
of the documentation. If a PHV is unsure as to whether the plants
procedures are
adequate, he or she is to contact the Technical Service Center for
technical assistance.
b. while performing verification activities related to the age of
cattle, inspection
program personnel are to verify, in establishments using dentition, that the
establishments determinations, which are typically made at postmortem,
are consistent
with the guidance provided in FSIS Notice 5-04. If the determinations
made by the
establishment are not consistent with the guidelines, inspection program
personnel are
to verify that the establishment takes the appropriate corrective action
under 9 CFR
7
417.3(a) or (b).
NOTE: For sheep and goats, inspection program personnel are to conduct
routine
antemortem inspection, after the establishment has completed the
procedures it has in
place for segregating the animals and as incorporated into its HACCP system.
Inspection program personnel are to follow the instructions above related to
documentation to verify that such animals are not 12 months of age or
older. In an
establishment slaughtering sheep and goats that are using dentition,
inspection
program personnel are to verify the establishments determinations,
which are typically
made at postmortem are consistent with the permanent incisor eruption as
shown on
the Technical Service Center Website: www.fsis.usda.gov/ofo/tsc.
2. For ruminants arriving under VS Form 17-33, inspection program personnel
are to verify that the establishment is properly executing its
procedures to ensure that
the cattle, sheep, and goats are slaughtered as a group until the marks
of inspection are
applied.
NOTE: If animals are pregnant, the collection of fetal bovine serum is
prohibited and is
to be dispose of as set out by the AVIC. (See 3 and 4 below).
3. If an establishment fails to prevent Canadian origin animals that are
ineligible
for slaughter from being presented for slaughter, PHVs are to institute
a hold on
affected animals using a U.S. retained tag applied to the pens and
promptly contact the
District Office so that it can notify the APHIS AVIC.
4. The AVIC will directly notify the establishment of subsequent actions. An
establishment may have a letter on file from the AVIC regarding the
disposition of any
ineligible animals from Canada, and the establishment is to dispose of
the ineligible
animals in accordance with the letter.
5. Inspection program personnel are to verify that the establishment
takes the
appropriate action as set out its procedures for the removal,
segregation, and
disposition of SRMs and as incorporated into its HACCP system.
6. For antemortem condemnations on eligible animals from Canada under 9 CFR
Part 309, inspection program personnel are to continue to follow current
regulations and
directives.
7. If inspection program personnel observe any animal with a C?N brand (for
cattle), and C brand (for sheep and goats) or CFIA ear tag while
performing antemortem
inspection on any domestic cattle lots, they are to institute a hold on
the animals using a
U.S. Retained tag applied to the pens and the PHV is to contact the
District Office so
that it can notify the APHIS AVIC. The AVIC will directly notify the
establishment of
subsequent actions and inspection program personnel are to verify that the
establishment takes the appropriate action as set out its procedures for
the removal,
segregation, and disposition of SRMs and as incorporated into its HACCP
system.
B. Postmortem Inspection
8
FSIS NOTICE 15-05
1. Off-line inspection program personnel are to verify execution of
establishment
programs for ensuring that animals ineligible for slaughter were not
slaughtered and that
eligible animals direct from Canada are slaughtered as a group until the
marks of
inspection are applied.
2. If an establishment slaughters animals that are ineligible for
slaughter, PHVs
are to institute a hold on the carcass and parts with a U.S. Retained
tag. PHVs are to
promptly contact the District Office so that it can notify the AVIC.
Inspection program
personnel are to verify that the establishment takes the appropriate
action as set out its
procedures for the removal, segregation, and disposition of SRMs and as
incorporated
into its HACCP system.
3. PHVs are to collect and hold for the AVIC all means of
identification (i.e.,
eartags, the VS-Form 1-27, and Health Certificate) and evidence
regarding the age of
the animals (i.e., a picture, when a camera is available, or a written
description
regarding a dentition finding).
4. The AVIC will contact the establishment, under its obligations as an
establishment approved by APHIS to receive these animals, to ensure specific
disposition and disposal requirements. An establishment may have a
letter on file from
the AVIC regarding the disposition of any ineligible animals (including
a fetus) from
Canada, and the establishment is to dispose of the ineligible animals in
accordance with
the letter.
5. If PHVs have concerns regarding the establishments disposal, or
failure to
dispose of carcasses or parts of ineligible animals, they are to notify
the District Office
so that it can notify the APHIS AVIC. The AVIC will initiate any
necessary investigation.
6. Any SRMs will be disposed in accordance with plant programs under 9 CFR
310.22.
7. For postmortem condemnations of eligible Canadian animals under 9 CFR
Part 310, inspection program personnel are to continue to follow current
regulations and
directives. No special reporting of any condemnations on eligible
animals is required.
VII. COMPLETING AND DISTRIBUTING FORMS
A. For animals from Canada that were shipped for immediate slaughter
After the slaughter of the shipment of animals, inspection program
personnel are to:
1. sign and date the VS Form 17-33, (See Outlook Public Folders/All Public
Folders/OFO/Technical Service Center/BSE Training Info for additional
information
about the VS Form 17-33),
2. maintain a copy of the VS Form 17-33 and the Canadian Health
Certificate and
9
any other documentation arriving with the shipment in the inspection
file, and
3. send a copy of the signed and dated VS Form 17-33 (Part 3) to the port of
entry as written on the form.
B. For animals from Canada that were shipped to a feedlot before shipment to
an official establishment
After the slaughter of the shipment of animals, inspection program
personnel are to:
1. sign and date the VS Form 1-27, (See Outlook Public Folders/All Public
Folders/OFO/Technical Service Center/BSE Training Info for additional
information
about the VS Form 1-27),
2. maintain a copy of the VS Form 1-27 and the Canadian Health
Certificate (see
above) and any other documentation arriving with the shipment in the
inspection file,
and
3. send a copy of the signed and dated VS Form 1-27 (Part 2), to the APHIS
AVIC in the state where the designated feedlot is located.
Direct technical questions regarding this notice to the Technical
Service Center at
1-800-233-3935. Direct other questions through supervisory channels.
Philip S. Derfler /s/
Assistant Administrator
Office of Policy, Program, and Employee Development
10

http://www.fsis.usda.gov/OPPDE/rdad/FSISNotices/15-05.pdf

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...

- 2 -
2. EXTERNAL CHALLENGES
2.1 Import of cattle from BSE-Risk2 countries
An overview of the data on live cattle imports is presented in table 1 and is based on
data as provided in the country dossier (CD) and corresponding data on relevant exports
as available from BSE risk countries that exported to Canada. Only data from risk
periods are indicated, i.e. those periods when exports from a BSE risk country already
represented an external challenge, according to the SSC opinion on the GBR (SSC July
2000 and updated January 2002).
" According to the CD, 231 cattle were imported from UK during the years 1980 to
1990 and no cattle imports from UK were recorded after 1990.
" According to Eurostat, altogether 198 cattle have been imported from the UK during
the years 1980 to 1990, Additionally 500 were recorded in 1993; this import is
1 For the purpose of the GBR assessment the abbreviation MBM refers to rendering products, in particular
the commodities Meat and Bone Meal as such; Meat Meal; Bone Meal; and Greaves. With regard to imports
it refers to the customs code 230110 flours, meals and pellets, made from meat or offal, not fit for human
2 BSE-Risk countries are all countries already assessed as GBR III or IV or with at least one confirmed
Annex to the EFSA Scientific Report (2004) 2, 1-14 on the Assessment of the
Geographical BSE Risk of Canada
- 3 -
mentioned in Eurostat and the updated UK export statistic as male calves, but not
mentioned in the original UK export statistics. According to the CD, detailed
investigations were carried out and it is very unlikely that the 500 calves have been
imported. Therefore, they were not taken into account.
" According to the CD, in 1990 all cattle imported from UK and Ireland since 1982
were placed in a monitoring program.
" Following the occurrence of the BSE index case in 1993 (imported from UK in 1987
at the age of 6 months), an attempt was made to trace all other cattle imported from
UK between 1982 and 1990.
" Of the 231 cattle imported from the UK between 1980 and 1990, 108 animals had
been slaughtered and 9 had died. From the remaining, 37 were exported, 76 were
sent to incineration and one was buried; these were not entering the rendering system
and therefore not taken into account.
" According to the CD, 16 cattle were imported from Ireland (according to Eurostat
20), of which 9 were slaughtered, 3 died. The remaining 4 were incinerated and did
therefore not enter the rendering system. According to the CD, the 6 animals which
were imported in 1990 according to Eurostat, were never imported.
" Moreover 22 cattle have been imported from Japan (through USA), of which 4 were
exported (excluded from the table) and 14 were destroyed and therefore not entering
the rendering system, 4 were slaughtered.
" Of 28 imported bovines from Denmark, 1 was destroyed and 1 was exported. Of the
19 buffalos imported in 2000, 1 was incinerated and the others were ordered to be
destroyed.
" Additionally in total 264 cattle according to the CD (276 according to other sources)
were imported from Austria, France, Germany, Hungary, Italy, The Netherlands and
Switzerland.
" The numbers imported according to the CD and Eurostat are very similar. Some
discrepancies in the year of import can be explained by an extended quarantine;
therefore it is likely that imports according to Eurostat in 1980 and imports
according to the CD in 1981 are referring to the same animals.
" Additionally, between 16.000 and 340.000 bovines have annually been imported
from US, almost all are steers and heifers. In total, between 1981 and 2003,
according to the CD more than 2.3 million, according to other sources 1.5 million
cattle have been imported.
" According to the CD, feeder/slaughter cattle represent typically more than 90% of
the imported cattle from the USA; therefore, only 10% of the imported cattle have
been taken into account.

snip...


Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the
Geographical BSE Risk of Canada
- 5 -
2.2 Import of MBM or MBM-containing feedstuffs from BSE-Risk
countries
An overview of the data on MBM imports is presented in table 2 and is based on data
provided in the country dossier (CD) and corresponding data on relevant exports as
available from BSE risk countries that exported to Canada. Only data from risk periods
are indicated, i.e. those periods when exports from a BSE risk country already
represented an external challenge, according to the SSC opinion on the GBR (SSC, July
2000 and updated January 2002).
According to the CD, no imports of MBM took place from UK since 1978 (initially
because of FMD regulations).
" According to Eurostat data, Canada imported 149 tons MBM from the UK in the
period of 1993 to 2001. According to up-dated MBM statistics from UK (August
2001) no mammalian MBM was exported to Canada from 1993  1996. As it was
illegal to export mammalian meat meal, bone meal and MBM from UK since
27/03/1996, exports indicated after that date should only have included nonmammalian
MBM. Therefore, these imports were not taken into account.
" According to the CD, imports of MBM have taken place from Denmark, Germany,
France, Japan and US.
" According to Eurostat Canada imported MBM from Denmark, Belgium, France and
Ireland.
" According to the CD further investigations concluded that all imported MBM from
Denmark consisted of pork and poultry origin and was directly imported for
aquaculture, the imported MBM from France was feather meal, the imported MBM
from Germany was poultry meal for aquaculture and the imported MBM from
Belgium was haemoglobin; therefore these imports were not taken into account.
" The main imports of MBM were of US origin, according to the CD around 250.000
tons, according to other sources around 310.000 tons between 1988 and 2003.

snip...

Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the
Geographical BSE Risk of Canada
- 7 -
2.3 Overall assessment of the external challenge
The level of the external challenge that has to be met by the BSE/cattle system is
estimated according to the guidance given by the SSC in its final opinion on the GBR of
July 2000 (as updated in January 2002).
Live cattle imports:
In total the country imported according to the CD more than 2.3 million, according to
other data 1.5 million live cattle from BSE risk countries, of which 231 (CD)
respectively 698 (other sources) came from the UK. The numbers shown in table 1 are
the raw import figures and are not reflecting the adjusted imports for the assessment of
the external challenge. Broken down to 5 year periods the resulting external challenge is
as given in table 3. This assessment takes into account the different aspects discussed
above that allow to assume that certain imported cattle did not enter the domestic
BSE/cattle system, i.e. were not rendered into feed. In the case of Canada, the 500 cattle
imported from UK according to Eurostat were not taken into account and it is assumed
that all incinerated, buried, exported animals and the animals still alive did not enter the
rendering system and were therefore excluded from the external challenge.
MBM imports:
In total the country imported according to the CD around 300.000 tons, according to
other sources nearly 360.000 tons of MBM from BSE risk countries, of which 149 tons
came from the UK. The majority consisted of MBM imported from the US. The
numbers shown in table 2 are the raw import figures and are not reflecting the adjusted
imports for the assessment of the external challenge. Broken down to 5 year periods the
resulting external challenge is as given in table 3. This assessment takes into account
the different aspects discussed above that allow to assume that certain imported MBM
did not enter the domestic BSE/cattle system or did not represent an external challenge
for other reasons. As it was illegal to export mammalian meat meal, bone meal and
MBM from UK since 27/03/1996, exports indicated after that date should only have
included non-mammalian MBM. In the case of Canada all imported MBM from UK,
Germany, Belgium, Denmark and France was not taken into account.
On the basis of the available information, the overall assessment of the external
challenge is as given in table 3 below.
Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the
Geographical BSE Risk of Canada
- 8 -
External Challenge experienced by CANADA
External challenge Reason for this external challenge
Period Overall Level Cattle
imports
MBM
imports
Comment
1980 to 1990 Low Low Negligible
1991 to 1995 High Moderate High
1996 to 2000 Extremely
high High Extremely
high
2001 to 2003 Very high High Very high
Table 3: External challenge resulting from live cattle and/or MBM imports from the UK and other BSE risk
countries. The challenge level is determined according to the SSC-opinion on the GBR of July 2000 (as
updated in January 2002).
3. STABILITY
3.1 Overall appreciation of the ability to avoid recycling of BSE
infectivity, should it enter processing
Feeding
The annual Canadian production of MBM is approximately 575,000 tons of which
approx. 40,000 tons are exported each year, mainly to USA.
Use of MBM in cattle feed
" Before the feed ban, dairy cattle received supplementary feed containing MBM
during their productive life (maximum 200-400 g MBM per day). Beef cattle in the
western part of the country do not usually receive complementary feed. Beef cattle
in the eastern part receive normally no supplement protein but the calves could have
access to creep feeds containing MBM, after weaning the ratios may have contained
supplemental protein containing MBM (100-400 g per day).
" According to the CD, MBM is mainly fed to pigs and poultry and included in pet
food.
" According to the CD, only a proportion of dairy cattle may have received MBM.
Feed bans
" Before 1997, there was no legal restriction to include MBM into cattle feed.
" An MBM-ban was introduced in August 1997; it is forbidden since to feed
mammalian MBM to ruminants except if of pure porcine, equine and non
mammalian origin, i.e. in practice a ruminant-to-ruminant ban (RMBM-ban).
Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the
Geographical BSE Risk of Canada
- 9 -
Potential for cross-contamination and measures taken against
" Cross-contamination in the about 600 feed mills is assumed to be possible as long as
cattle and pig feed is produced in the same production lines, and premises.
" Cross-contamination during transport is possible, particularly if the same trucks are
used for transporting ruminant MBM (RMBM) and non-ruminant MBM (porcine or
poultry MBM which still might be included into cattle feed) or for transporting
pig/poultry feed and cattle feed.
" On-farm cross-contamination is regarded to be possible.
" Cross-contamination of cattle feed with RMBM can not be excluded. Hence, as
reasonable worst case scenario, it has to be assumed that cattle, in particular dairy
cattle, can still be exposed to RMBM and hence to BSE-infectivity, should it enter
the feed chain.
Control of Feed bans and cross-contamination
" With the introduction of the RMBM ban (1997) the feed mills (approximately 600)
were checked for compliance with the ban, including good manufacturing practices
(GMP) and record keeping, i.e. the separation in production of MBM containing
ruminant material (RMBM) from non-ruminant MBM.
" The feed mills had previously  since 1983  been regularly checked in relation to
production of medicated feed.
" No examinations are performed to assess cross-contamination with RMBM of the
protein (e.g. non ruminant MBM) that enters cattle feed. Differentiation would
anyway be difficult.
Rendering
Raw material used for rendering
" Ruminant material is rendered together with material from other species, but
according to the CD only in the production of MBM prohibited for use in ruminant
feeds.
" Slaughter by-products, including specified risk material (SRM) and fallen stock are
rendered.
" The country expert estimated that 20% of the rendering plants, processing 20% of
the total amount of raw material, are connected to slaughterhouses. Their raw
material is more than 98 % animal waste from these slaughterhouses while less than
2 % is fallen stock. No estimation was given for the remaining 80% of the rendering
capacity.
" There are 32 rendering plants of which 3 are processing blood exclusively.
Rendering processes
" The rendering systems (parameters) were specified for 6 plants producing mixed
MBM, none of these fulfilled the 133/20/3 standard. Of these, 5 have dedicated
facilities to produce products for use in ruminant feed and products not permitted for
use in ruminant feed.
" The remaining plants process porcine or poultry material exclusively.
SRM and fallen stock
" There is an SRM ban for human food in place since 2003.
Annex to the EFSA Scientific Report (2004) 2, 1-15 on the Assessment of the
Geographical BSE Risk of Canada
" However, SRM are rendered together with other slaughter waste and fallen stock.
However, according to the CD, MBM with SRM is not permitted to be fed to
ruminants.
Conclusion on the ability to avoid recycling
" Between 1980 and 1997 the Canadian system would not have been able to avoid
recycling of the BSE-agent to any measurable extent. If the BSE-agent was
introduced into the feed chain, it could have reached cattle.
" Since 1997 this ability gradually improved with the introduction of the ruminant
MBM ban and its implementation.
" Since cross-contamination cannot be excluded, and as SRM is still rendered by
processes unable to significantly reduce BSE-infectivity, the system is still unable to
avoid recycling of BSE-infectivity already present in the system or incoming.
3.2
BSE surveillance
laboratory tests).
i.e. formalin fixation.

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


Docket No. 03-080-1 -- USDA ISSUES PROPOSED RULE TO ALLOW LIVE ANIMAL
IMPORTS FROM CANADA


"Terry S. Singeltary Sr."

11/03/2003 01:19 PM


To:

regulations@aphis.usda.gov

cc:


bcc:


Subject:

Docket No. 03-080-1 -- USDA ISSUES PROPOSED RULE TO ALLOW LIVE ANIMAL
IMPORTS FROM CANADA

I would like to kindly comment on Docket No. 03-080-1 USDA ISSUES
PROPOSED RULE TO ALLOW LIVE ANIMAL IMPORTS FROM CANADA ; >Under this
proposal, ruminant and ruminant products eligible for entry into >the
United States from a BSE minimal risk region would include: > >1) bovine
>animals less than 30 months of age for immediate slaughter; > >2)
bovine >animals for feeding to be moved to a designated feedlot and then
to >slaughter at less than 30 months of age; > snip... >6) fresh
(chilled or frozen) >meat from bovines less than 30 months of age; 7)
fresh (chilled or frozen) >whole or half carcasses of bovines less than
30 months of age; 8) fresh >(chilled or frozen) bovine liver; 9) fresh
(chilled or frozen) bovine >tongues; the myth that cattle under 30
months of age are free from BSE/TSE is just that, a myth, and it's a
false myth ! the youngest age of BSE case to date is 20 months old; As
at: 31 May 2003 Year of onset Age youngest case (mnths) Age 2nd youngest
case (mnths) Age 2nd oldest case (yrs.mnths) Age oldest case (yrs.mnths)
1986 30 33 5.03 5.07 1987 30 31 9.09 10.00 1988 24 27 10.02 11.01(2)
1989 21 24(4) 12.00(2) 15.04 1990 24(2) 26 13.03 14.00 1991 24 26(3)
14.02 17.05 1992 20 26 15.02 16.02 1993 29 30(3) 14.10 18.10 1994 30(2)
31(2) 14.05 16.07 1995 24 32 14.09 15.05 1996 29 30 15.07 17.02 1997
37(7) 38(3) 14.09 15.01 1998 34 36 14.07 15.05 1999 39(2) 41 13.07 13.10
2000 40 42 17.08 19.09 2001 48(2) 56 14.10 14.11 2002 51 52 15.08
15.09(2) 2003 50 62 11.11 14.11
http://www.defra.gov.uk/animalh/bse/bse-statistics/bse/yng-old.html
http://www.defra.gov.uk/animalh/bse/index.html The implications of the
Swiss result for Britain, which has had the most BSE, are complex. Only
cattle aged 30 months or younger are eaten in Britain, on the
assumption, based on feeding trials, that cattle of that age, even if
they were infected as calves, have not yet accumulated enough prions to
be infectious. But the youngest cow to develop BSE on record in Britain
was 20 months old, showing some are fast incubators. Models predict that
200-300 cattle under 30 months per year are infected with BSE and enter
the food chain currently in Britain. Of these 3-5 could be fast
incubators and carrying detectable quantities of prion.
http://www.sare.org/htdocs/hypermail/html-home/28-html/0359.html

SNIP...FULL TEXT ;


https://web01.aphis.usda.gov/BSEcom.nsf/0/b78ba677e2b0c12185256dd300649f9d?OpenDocument&AutoFramed


TSS


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