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From: TSS ()
Subject: CONGRESS COWARDS AWAY FROM MAD COW DISPUTE (would rather watch the demented add up)
Date: May 10, 2005 at 12:31 pm PST

-------- Original Message --------
Subject: CONGRESS COWARDS AWAY FROM MAD COW DISPUTE (would rather watch the demented add up)
Date: Tue, 10 May 2005 10:35:38 -0500
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
To: BSE-L@aegee.org


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

Congress Is Staying Clear of Dispute Over Mad Cow


Marcio Jose Sanchez/Associated Press

California ranchers are divided over reopening the Canadian border to
beef. Those who favor lifting the ban said it would help meatpackers and
might persuade countries like Japan to buy American beef again.

Published: May 10, 2005

CHICAGO, May 9 - Congress appears to be unlikely to step in the middle
of a standoff between the Bush administration and American cattlemen
over reopening the border to imports of cattle from Canada.

The cattlemen are concerned about whether the Canadian cows would infect
the American herd with the deadly mad cow disease. The Senate,
responding to that concern, narrowly voted in March to block the
Agriculture Department's ruling that deemed Canadian cattle healthy
enough to allow the border to be reopened.

With the deadline for Congressional action on Saturday, the chairman of
the House Agriculture Committee, Bob Goodlatte, a Republican from
Virginia, has no plans to bring the issue up for a vote, a spokesman for
the committee said Monday. Mr. Goodlatte, who opposed the Senate vote,
plans to let the issue play out in the courts before considering any
action, the spokesman said.

That could set up a showdown in the Montana courtroom of Judge Richard
F. Cebull of Federal District Court, who was sharply critical of the
Agriculture Department's assurances that measures were in place to
assure the safety of the beef coming from Canada. He issued a temporary
injunction on March 2 at the request of cattle ranchers, keeping the
border closed for now. A trial is scheduled for July 27, although
meatpackers and the administration have filed an appeal of Judge
Cebull's injunction with the Ninth Circuit Court of Appeals in San
Francisco.

The United States closed the border to live Canadian cattle and beef
products in May 2003, after mad cow was found in an Alberta beef cow.
Then the discovery in late 2003 of mad cow in Washington State in a
dairy cow that had been imported from Canada led 53 countries to ban
American beef.

The border issue, which has severely crimped the $7.5 billion beef and
cattle industry, continues to be a tense balancing act for the
administration between health and safety concerns and the desire to
re-establish export markets for the American beef industry.

Reopening the border to Canadian beef, the Agriculture Department has
argued, would also protect American meatpackers, who have been forced to
cut their work forces and temporarily idle plants because of a lack of
Canadian cattle. Such a move, officials say, would provide the
administration with a precedent for asking Japan and other crucial
export markets to consider beef from the United States a minimal risk to
health as well. The American beef industry has been losing about $4
billion a year as a result of the bans.

American cattle groups and lawmakers opposed to lifting the ban on
Canada say the Agriculture Department, in a rush to reopen export
markets and support the American meatpacking industry, is not doing
enough to safeguard its cattle from potential infection.

In January, Canada confirmed two additional cases of bovine spongiform
encephalopathy, the clinical name for mad cow, bringing to four the
number of confirmed cases from cattle originating from Canada.

As the ban has continued, the Agriculture Department has quietly relaxed
its initial hard line, allowing back in, for example, certain beef
products. According to documents filed in the Montana case, the
department chose in 2003 not to follow most of the recommendations of
its own scientific advisory board, which said further study was needed
before readmitting Canadian cattle or beef.

In a report filed on June 16, 2003, to a deputy administrator, W. Ron
DeHaven, the advisory body outlined seven general recommendations for
resuming cross-border trade. Most of those, like banning "plate waste,"
or beef discarded at restaurants, from being fed to cattle, or requiring
dedicated mills for the manufacturing of cattle feed to avoid
contamination, were not followed in the department's new rules.

Less than two months after the report, on Aug. 8, the Agriculture
Department decided to allow in packaged beef from Canadian animals
younger than 30 months. The next month, the department allowed American
meatpackers to resume imports of Canadian ground beef and other
processed beef, which the June report by the advisory group listed as
high risk and recommended against allowing in.

Published: May 10, 2005

(Page 2 of 2)

"This reinforces that the administration has placed a higher priority on
achieving a free trade ideal than on maintaining adequate health and
safety standards to protect U.S. consumers," said Bill Bullard, the
chief executive of Ranchers-Cattlemen's Action Legal Fund, the cattle
group that won the injunction in March.

In an interview, Lisa Ferguson, the head of the advisory group, played
down the significance of the report, calling it a "first crack at
categorizing things and attempting to lay out what could be an approach
for safely re-establishing trade." She said as more information became
available the agency made a "more accurate measure of risks" in its
final November 2003 rule. Still, the group's recommendations were more
consistent with what most other countries are doing to combat mad cow
than what the Agriculture Department ultimately decided to do.

As the mad cow issue appears headed to the courts, the government is
proposing ways of containing any outbreaks. Agriculture Secretary Mike
Johanns said last week that the government was looking at creating a
mandatory nationwide system of animal identification that would make it
easier to track every cow, chicken and pig from birth to slaughter.
Under the plan, farmers, feedlots and packing houses would be required
by 2009 to put identification tags on all livestock.

Canada has had such a system in place since 2001 and has used it to
track the origin of infected cattle.

Japan, the largest foreign market for American ranchers at $1.2 billion
a year, has refused American beef because of the single mad cow
discovery in Washington - even though 17 infected cows have been
detected in Japan since August 2001, the latest last month.

Unlike both Canada and the United States, Japan tests all cows that are
slaughtered. Canada, in the first three months of this year, actually
reduced the testing of its cattle, even after finding the two new cases.

Gary Little, acting senior staff veterinarian for the Canadian Food
Inspection Agency, attributed the drop to "seasonal availability" of
cattle for testing and said Canada was on track to exceed its goal to
test 30,000 animals this year, about half of a percent of the country's
six million cattle older than 30 months. "There is no intention on our
part to test fewer animals," Dr. Little said. If mad cow "is present in
our population of cattle we are committed to finding it."

http://www.nytimes.com/

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 fallen stock and emergency slaughter, by means of rapid
screening, would allow
monitoring the efficiency of stability enhancing measures.... snip...end

CANADA

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

MEXICO

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


EFSA Scientific Report on the Assessment of the Geographical BSE-Risk
(GBR) of the United States of America (USA)
Publication date: 20 August 2004

Adopted July 2004 (Question N EFSA-Q-2003-083)

* 167 kB Report
* 105 kB Summary

Summary of the Scientific Report

The European Food Safety Authority and its Scientific Expert Working
Group on the Assessment of the Geographical Bovine Spongiform
Encephalopathy (BSE) Risk (GBR) were asked by the European Commission
(EC) to provide an up-to-date scientific report on the GBR in the United
States of America, i.e. the likelihood of the presence of one or more
cattle being infected with BSE, pre-clinically as well as clinically, in
USA. This scientific report addresses the GBR of USA as assessed in 2004
based on data covering the period 1980-2003.

The BSE agent was probably imported into USA and could have reached
domestic cattle in the middle of the eighties. These cattle imported in
the mid eighties could have been rendered in the late eighties and
therefore led to an internal challenge in the early nineties. It is
possible that imported meat and bone meal (MBM) into the USA reached
domestic cattle and leads to an internal challenge in the early nineties.

A processing risk developed in the late 80s/early 90s when cattle
imports from BSE risk countries were slaughtered or died and were
processed (partly) into feed, together with some imports of MBM. This
risk continued to exist, and grew significantly in the mid 90s when
domestic cattle, infected by imported MBM, reached processing. Given the
low stability of the system, the risk increased over the years with
continued imports of cattle and MBM from BSE risk countries.

EFSA concludes that the current GBR level of USA is III, i.e. it is
likely but not confirmed that domestic cattle are (clinically or
pre-clinically) infected with the BSE-agent. As long as there are no
significant changes in rendering or feeding, the stability remains
extremely/very unstable. Thus, the probability of cattle to be
(pre-clinically or clinically) infected with the BSE-agent persistently
increases.

http://www.efsa.eu.int/science/efsa_scientific_reports/gbr_assessments/573_en.html


What GAO Found
United States Government Accountability Office
Why GAO Did This Study
Highlights
Accountability Integrity Reliability
www.gao.gov/cgi-bin/getrpt?GAO-05-101.
To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Robert A.
Robinson at (202) 512-3841 or
robinsonr@gao.gov.
Highlights of GAO-05-101, a report to
congressional requesters
February 2005
MAD COW DISEASE
FDA"s Management of the Feed Ban Has
Improved, but Oversight Weaknesses
Continue to Limit Program Effectiveness
FDA has made needed improvements to its management and oversight of the
feed-ban rule in response to GAO"s 2002 report, but program weaknesses
continue to limit the effectiveness of the ban and place U.S. cattle at
risk of
spreading BSE. Improvements made include FDA establishing a uniform
method of conducting compliance inspections and training FDA inspectors,
as well as state inspectors who carry out inspections under agreements with
FDA, on the new method. FDA also implemented new data-entry procedures
that are designed to more reliably track feed-ban inspection results.
Consequently, FDA has a better management tool for overseeing compliance
with the feed-ban rule and a data system that better conforms to standard
database management practices. However, various program weaknesses
continue to undermine the nation"s firewall against BSE. For example:
⬢ FDA acknowledges that there are more feed manufacturers and
transporters, on-farm mixers, and other feed industry businesses that are
subject to the feed ban than the approximately 14,800 firms inspected to
date; however, it has no uniform approach for identifying additional
firms.
⬢ FDA has not reinspected approximately 2,800, or about 19 percent, of
those businesses, in 5 or more years; several hundred are potentially
high risk. FDA does not know whether those businesses now use
prohibited material in their feed.
⬢ FDA"s feed-ban inspection guidance does not include instructions to
routinely sample cattle feed to test for potentially prohibited material as
part of the compliance inspection. Instead, it includes guidance for
inspectors to visually examine facilities and equipment and review
invoices and other documents.
⬢ Feed intended for export is not required to carry a caution label
SDo not
feed to cattle or other ruminants,⬝ when the label would be required if
the feed were sold domestically. Without that statement, feed containing
prohibited material could be inadvertently or intentionally diverted back
to U.S. cattle or given to foreign cattle.
⬢ FDA has not always alerted USDA and states when it learned that cattle
may have been given feed that contained prohibited material. This lapse
has been occurring even though FDA"s guidance calls for such
communication.
⬢ Although research suggests that cattle can get BSE from ingesting
even a
small amount of infected material, inspectors do not routinely inspect or
review cleanout procedures for vehicles used to haul cattle feed.
More than 5 million cattle across
Europe have been killed to stop the
spread of bovine spongiform
encephalopathy (BSE), commonly
called mad cow disease. Found in
26 countries, including Canada and
the United States, BSE is believed
to spread through animal feed that
contains protein from BSE-infected
animals. Consuming meat from
infected cattle has also been linked
to the deaths of about 150 people
worldwide. In 1997, the Food and
Drug Administration (FDA) issued
a feed-ban rule prohibiting certain
animal protein (prohibited
material) in feed for cattle and
other ruminant animals. FDA and
38 states inspect firms in the feed
industry to enforce this critical
firewall against BSE. In 2002, GAO
reported a number of weaknesses
in FDA"s enforcement of the feed
ban and recommended corrective
actions. This report looks at FDA"s
efforts since 2002 to ensure
industry compliance with the feed
ban and protect U.S. cattle.
What GAO Recommends
GAO recommends FDA, among
other things, develop procedures
for finding additional firms subject
to the feed-ban and using tests to
augment inspections. FDA said the
study was thorough but disagreed
on four of nine recommendations.
GAO continues to believe that,
given the discovery of BSE in North
America and the oversight gaps
described in the report, the
recommended actions are needed
to protect U.S. cattle from BSE.


3. Mad Cow Disease: FDA's Management of the Feed Ban Has Improved,
but Oversight Weaknesses Continue to Limit Program Effectiveness.
GAO-05-101, Feb. 25.
http://www.gao.gov/cgi-bin/getrpt?GAO-05-101
Highlights - http://www.gao.gov/highlights/d05101high.pdf

Docket No. 2003N-0312 Animal Feed Safety System [TSS SUBMISSION]

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

Docket Management Docket: 02N-0273 - Substances Prohibited From Use in

Animal Food or Feed; Animal Proteins Prohibited in Ruminant Feed

Comment Number: EC -10

Accepted - Volume 2


http://www.fda.gov/ohrms/dockets/dailys/03/Jan03/012403/8004be07.html

PART 2


http://www.fda.gov/ohrms/dockets/dailys/03/Jan03/012403/8004be09.html

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

Greetings FDA,

snip...

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


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

Terry S. Singeltary Sr. P.O. BOX 42 Bacliff, TEXAS USA 77518

#################### https://lists.aegee.org/bse-l.html ####################






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