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From: TSS (216-119-162-4.ipset44.wt.net)
Subject: Docket No. 02N-0273 – Substances Prohibited From Use In Animal Food Or Feed (TSS SUBMISSION)
Date: January 18, 2003 at 8:35 am PST

In Reply to: Livestock Industry Continues to Oppose Stricter Regs Against Mad Cow Type Diseases posted by TSS on January 15, 2003 at 7:00 am:

Re: Docket No. 02N-0273 – Substances Prohibited From Use In Animal Food Or Feed;

Greetings FDA and public,

we must ban _all_ ruminant-to-ruminant feeding and we _must_
ban all SRMs (specified risk materials) and MRMs
(mechanically recovered meats).

i find it very disturbing that in comments made by 'the industry';

> However, no new risks or science support the
> proposed changes set forth in the ANPR.

this is false. i don't suppose anyone from
the USDA/APHIS or the agencies and their corporations
below are even concerned that new science is indeed
forth coming, science they do not want to admit from
Collinge et al, that BSE transmission to the 129-methionine
genotype can lead to an alternate phenotype which is
indistinguishable from type 2 PrPSc, the commonest
sporadic CJD. how many of the sporadic CJDs in the USA
are type 2 PrpSc? please read this letter from Collinge et al;

Subject: re-BSE prions propagate as either variant CJD-like or
sporadic CJD
Date: Thu, 28 Nov 2002 10:23:43 -0000
From: "Asante, Emmanuel A"
To: "'flounder@wt.net'"

Dear Terry,

I have been asked by Professor Collinge to respond to your request. I am a Senior Scientist in the MRC Prion Unit and the lead author on the paper. I have attached a pdf copy of the paper for your attention. Thank you for your interest in the paper.

In respect of your first question, the simple answer is, yes. As you will find in the paper, we have managed to associate the alternate phenotype to type 2 PrPSc, the commonest sporadic CJD.

It is too early to be able to claim any further sub-classification in
respect of Heidenhain variant CJD or Vicky Rimmer's version. It will take further studies, which are on-going, to establish if there are sub-types to our initial finding which we are now reporting. The main point of the paper is that, as well as leading to the expected new variant CJD phenotype, BSE transmission to the 129-methionine genotype can lead to an alternate phenotype which is indistinguishable from type 2 PrPSc.

I hope reading the paper will enlighten you more on the subject. If I can be of any further assistance please to not hesitate to ask. Best wishes.

Emmanuel Asante

<>
____________________________________

Dr. Emmanuel A Asante
MRC Prion Unit & Neurogenetics Dept.
Imperial College School of Medicine (St. Mary's)
Norfolk Place, LONDON W2 1PG
Tel: +44 (0)20 7594 3794
Fax: +44 (0)20 7706 3272
____________________________________

> In fact, several scientific studies have
> confirmed the fundamental soundness

and several scientific studies have confirmed the
USA BSE/TSE surveillance as terribly flawed, and one of
those groups was the GAO report, please see below, and please
read data on potential BSE/TSE/FMD 'SUITCASE BOMBS' and more
on that so-called 'triple firewall'. PLUS, the federal government
has ceased to make public ruminant-to-ruminant feed ban
violations since May 2002, now we must go through the FOIA.
i have pasted this data and a thread with USDA/APHIS officals
below;

Subject:
re-USA BSE/TSE RUMINANT-TO-RUMINANT FEED BAN VIOLATIONS ''cover-up''
From:
"Terry S. Singeltary Sr."
Date:
Tue, 3 Dec 2002 15:16:58 -0600
To:
BSE-L

Greetings Dr. Gomez and other List members and Lurkers,

Gomez, Thomas M. wrote:

Subject: Re: Speaking Note on BSE Agriculture Council, Brussels, 2 8
November 2002 (compare TSE testing)
Date: Tue, 3 Dec 2002 10:21:41 -0500
From: "Gomez, Thomas M."
Reply-To: BSE-L

> 1. I'm not able to comment on feed ban violations.
> Regulatory authority for Substances Prohibited From Use in
> Animal Food or Feed; Animal Proteins Prohibited in Ruminant
> Feed is the FDA, not the USDA.

snip...

thank you again Dr. Gomez, i did not realize you
could not speak about the ruminant-to-ruminant
feed ban. odd some FDA lurkers have not replied?
maybe Dr. Freas will know, but i don't think the
big guns lurk here. like Dr. Detwiler, she has her
other people do the dirty work here, replies through
them. odd, you replied about 50 State BSE Conference
call on Jan. 9, 2001, and that's pretty much all that
was about was all the BSE feed ban violations in the USA.
no matter, i will ask FDA officials.

Subject: USDA/APHIS response to BSE-L--U.S. 50 STATE CONFERENCE CALL
Jan. 9, 2001
Date: Wed, 10 Jan 2001 14:04:21 -0500
From: "Gomez, Thomas M."
Reply-To: Bovine Spongiform Encephalopathy

USDA/APHIS would like to provide clarification on the following point
from Mr. Singeltary's 9 Jan posting regarding the 50 state conference call.

[Linda Detwiler asking everyone (me) not to use emergency BSE number,
unless last resort. (i thought of calling them today, and reporting the
whole damn U.S. cattle herd ;-) 'not']

Dr. Detwiler was responding to an announcement made during the call to
use the FDA emergency number if anyone wanted to report a cow with signs
suspect for BSE. Mr. Singeltary is correct that Dr. Detwiler asked
participants to use the FDA emergency number as a last resort to report
cattle suspect for BSE. What Mr. Singeltary failed to do was provide
the List with Dr. Detwiler's entire statement. Surveillance for BSE in
the United States is a cooperative effort between states, producers,
private veterinarians, veterinary hospitals and the USDA. The system
has been in place for over 10 years. Each state has a system in place
wherein cases are reported to either the State Veterinarian, the federal
Veterinarian in Charge or through the veterinary diagnostic laboratory
system. The states also have provisions with emergency numbers. Dr.
Detwiler asked participants to use the systems currently in place to
avoid the possibility of a BSE-suspect report falling through the
cracks. Use of the FDA emergency number has not been established as a
means to report diseased cattle of any nature...

snip...

FYI see full text with my reply here;

http://www.vegsource.com/talk/madcow/messages/8219.html

and a better reply than mine would be here;

>would you and the USDA/APHIS be so kind as to supply
>this list with a full text version of the conference
>call and or post on
>your web-site?

>if not, why not?
>
>> The system has been in place for over 10 years.
>
> only test 10,700 cattle from some 1.5 BILLION head (including
>calf crop). Especially since French >are testing some 20,000 weekly and
>the E.U. as a whole,

==-=-=

Right. The US has 101 million cows where as France has 5.7 million. This
being 17.7 as many cows, the US would need to test 17.7 x 20,000 =
354,386 cows a week to be testing proportionately. This compares to
about 50 cows a week tested now. In other words, the US needs to test
7,000 cows where it is now testing 1 to keep up with international norms.

Once a country starts serious testing, they get religion. After
stomaching some bad results, then they want their trading partners to
test just like they did.

No one can predict what, if anything, would turn up in the US from a
European scale of testing. Right now the US has not been using the
international gold standard of the Prionics test.

Just as Austria and Belgium have been forced into unwilling testing, the
US is going to have to test at an adequate level or forget about foreign
trade in bovine byproducts, cosmetics, nutriceuticals, veterinary
products, and pharmaceuticals. You can see this just from announcements
in Japan.

Nobody is going to buy into theoretical reasons why there shouldn't be
BSE in the US or Canada when the choice is real-world testing that
proved so informative in other theoretical countries such as Germany.

In my opinion, the US should have been preparing long ago for a soft
landing with the consumer instead of going with the heavy-handed
germanic denial system.

http://www.vegsource.com/talk/madcow/messages/8222.html

i have also sent many letters to FDA with no reply.
i have ask all parties that represent this industry
to respond to my question, with no luck. so again,
i ask all USA Gov. lurkers on this list, including
all FDA officials, please answer my question;

where are the ruminant-to-ruminant feed ban violations
now being documented for public viewing ???

for some humorist reading;

http://www.fda.gov/ohrms/dockets/dailys/01/Nov01/112901/01N-0423-EC-18.html

http://www.fda.gov/ohrms/dockets/dailys/01/Nov01/112901/01N-0423-EC-20.html

http://www.fda.gov/ohrms/dockets/dailys/01/Nov01/112901/01N-0423-EC-11.html

http://www.fda.gov/ohrms/dockets/dailys/01/Nov01/112901/01N-0423-EC-19.html

http://www.fda.gov/OHRMS/DOCKETS/98fr/100501b.htm

http://www.access.gpo.gov/nara/cfr/waisidx_01/21cfr589_01.html

snip...

As of March 11, CVM had received inspection reports covering inspections
(both initial inspections and re-inspections) of 10,458 different firms.
The majority of these inspections (around 80%) were conducted by State
officials under contract to FDA and the remainder by FDA officials.

Various segments of the feed industry had different levels of compliance
with this feed ban regulation. The results to date are reported here
both by "segment of industry" and "in total".

RENDERERS

(These firms are the first to handle rendered protein and send materials
to feed mills and ruminant feeders.)

*

NUMBER OF FIRMS WHOSE INITIAL INSPECTION HAS BEEN REPORTED TO CVM
- 239
*

NUMBER OF FIRMS HANDLING MATERIALS PROHIBITED FOR USE IN RUMINANT
FEED - 171 (72% of those firms inspected/reported).
* Of the 171 renderers handling prohibited materials, at their most
recent inspection (could have been an initial or a follow-up inspection):
- 4 (2%) had products that were not labeled as required
- 3 (2%) did not have adequate systems to prevent co-mingling
- 1 (1%) did not adequately follow record keeping regulations
- 4 (2%) firms were found to be out of compliance (some firms
were out of compliance with more than one aspect of the rule)

FDA LICENSED FEED MILLS

(FDA licenses these mills to produce medicated feed products. This
licensing has nothing to do with handling prohibited materials under the
feed ban rule: 21 CFR 589.2000. A license from FDA is not required to
handle materials prohibited under 21 CFR 589.2000.)

*

NUMBER OF FIRMS WHOSE INITIAL INSPECTION HAS BEEN REPORTED TO CVM
- 1,203
*

NUMBER OF FIRMS HANDLING MATERIALS PROHIBITED FOR USE IN RUMINANT
FEED - 370 (31% of those firms inspected/reported)
* Of the 370 licensed feed mills handling prohibited materials, at
their most recent inspection (could have been an initial or a follow-up
inspection):
- 8 (2%) had products that were not labeled as required
- 2 (1%) did not have adequate systems to prevent co-mingling
- 3 (1%) did not adequately follow record keeping regulations
- 10 (3%) firms were found to be out of compliance (some firms
were out of compliance with more than one aspect of the rule)

FEED MILLS NOT LICENSED BY FDA

*

NUMBER OF FIRMS WHOSE INITIAL INSPECTION HAS BEEN REPORTED TO CVM
- 4,867
*

NUMBER OF FIRMS HANDLING MATERIALS PROHIBITED FOR USE IN RUMINANT
FEED - 1,224 (25% of those firms inspected/reported)
* Of the 1,224 feed mills not licensed by FDA handling prohibited
materials, at their most recent inspection (could have been an initial
or a follow-up inspection):
- 55 (4%) had products that were not labeled as required
- 28 (2%) did not have adequate systems to prevent co-mingling
- 28 (2%) did not adequately follow record keeping regulations
- 86 (7%) firms were found to be out of compliance (some firms
were out of compliance with more than one aspect of the rule)

OTHER FIRMS INSPECTED

(Examples of such firms include: ruminant feeders, on-farm mixers,
protein blenders, and distributors.)

*

NUMBER OF FIRMS WHOSE INITIAL INSPECTION HAS BEEN REPORTED TO CVM
- 4,710
*

NUMBER OF FIRMS HANDLING MATERIALS PROHIBITED FOR USE IN RUMINANT
FEED - 565 (12% of those firms inspected/reported)
* Of the 565 such firms handling prohibited materials, at their
most recent inspection (could have been an initial or a follow-up
inspection):
- 17 (3%) had products that were not labeled as required
- 2 (less than 1%) did not have adequate systems to prevent
co-mingling
- 7 (1%) did not adequately follow record keeping regulations
- 25 (4%) firms were found to be out of compliance (some firms
were out of compliance with more than one aspect of the rule)

TOTALS (as of March 11, 2002)

*

NUMBER OF FIRMS WHOSE INITIAL INSPECTION HAS BEEN REPORTED TO CVM
- 10,458
*

NUMBER OF FIRMS HANDLING MATERIALS PROHIBITED FOR USE IN RUMINANT
FEED - 2,153 (21% of those firms inspected/reported)
* Of the 2,153 firms handling prohibited materials, at their most
recent inspection (could have been an initial or a follow-up inspection):
- 77 (4%) had products that were not labeled as required
- 34 (2%) did not have adequate systems to prevent co-mingling
- 35 (2%) did not adequately follow record keeping regulations
- 113 (5%) firms were found to be out of compliance

RE-INSPECTIONS

When firms are found to be out of compliance with the feed ban rule, FDA
lists them for a re-inspection. As of March 11, 2002, reports of 2,185
re-inspections have been submitted to CVM. On re-inspection of these
2,185 firms, 32 (1%) were found still to be out of compliance with this
rule. Firms previously found to be not in compliance have corrected
problems through a variety of ways, including further training of
employees about the rule, developing systems to prevent co-mingling,
re-labeling their products properly, and adhering to record keeping
regulations. Other firms have achieved compliance by eliminating
prohibited materials from their operations.

DATABASE CHANGE

After March 11, 2002, FDA discontinued the database that was used to
compile these numbers. The Agency is starting a new database on April
15, 2002, and future updates on BSE enforcement will draw from it.

snip...

http://www.fda.gov/cvm/index/fdavet/2002/May_June.htm#Ruminant

no where did it state that they would cease to publish the
ruminant-to-rumiant feed ban violations after the above
publication. so, again, where are these now being posted
on the web, what URL???

let us look at a review of past ruminant BSE feed ban warning
letters. these are just the ones i found. most of you have
seen them in the past, but it does not hurt to remind us of
why they no longer post them to the public. if that is
the case?

USA 8/4/97 RUMINANT-TO-RUMINANT FEED BAN that never was...

'ANIMAL PROTEIN' SEARCH 9/9/02
==============================

Darling International, Inc.
5/07/02
Seattle District Office Animal Proteins Prohibited in Ruminant
Feed/Misbranded [PDF]
[HTML] All American Feed & Tractor
4/01/02
Seattle District Office Animal Proteins Prohibited in Ruminant
Feed/Adulterated [PDF]
[HTML] Tyson Foods
2/12/02
Seattle District Office Animal Proteins Prohibited in Ruminant
Feed/Misbranded [PDF]
[HTML] The Feed Bucket
12/11/01
Atlanta District Office Animal Proteins Prohibited in Ruminant
Feed/Adulterated/Misbranded [PDF]
[HTML] Finlayson Ag Center
11/08/01
Minneapolis District Office Animal Proteins Prohibited in Ruminant
Feed/Adulterated [PDF]
[HTML] Dixon Feeds, Inc.
10/24/01
Seattle District Office Animal Proteins Prohibited in Ruminant
Feed/Adulterated [PDF]
[HTML] Buckeye Feed Mills, Inc.
9/20/01
Cincinnati District Office Animal Proteins Prohibited in Ruminant
Feed/Adulterated/Misbranded [PDF]
[HTML] Wilcox Farms, Inc.
9/14/01
Seattle District Office Animal Proteins Prohibited in Ruminant Feed [PDF]
[HTML]

http://www.accessdata.fda.gov/scripts/wlcfm/full_text.cfm?full_text=animal+protein&Search=Search

now, compare search on 8/8/01...tss
===================================

'ANIMAL PROTEIN' SEARCH 8/8/01
==============================

Date: Tue, 28 Aug 2001 11:13:43 -0700
Reply-To: BSE-L
Sender: Bovine Spongiform Encephalopathy BSE-L
From: "Terry S. Singeltary Sr."
Subject: MAD COW FEED BAN WARNING LETTERS U.S.A. AUGUST 8, 2001

DEPARTMENT OF HEALTH AND HUMAN SERVICES

Food and Drug Administration

Seattle District Pacific Region 22201 23rd Drive SE Bothell, WA 98021-4421

Telephone: 426-486-8788 FAX: 426-483-4996

August 8, 2001

VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED

In reply refer to Warning Letter SEA 01-75

William W. Himmelspach, Owner 22195 S.W. 78th Tualatin, Oregon 97062

WARNING LETTER

Dear Mr. Himmelspach:

An investigation at your animal feed manufacturing operation located at
22195 S.W. 78th Tualatin, Oregon 97062, conducted by a Food and Drug
Administration investigator on July 12, 2001, found significant
deviations from the requirements set forth in Title 21, Code of Federal
Regulations, Part 589.2000 - Animal Proteins Prohibited in Ruminant
Feed. The regulation is intended to prevent the establishment and
amplification of Bovine Spongiform Encephalopathy (BSE). Such deviations
cause products being manufactured at this facility to be adulterated
within the meaning of Section 402(a)(2)(C), and 402(a)(4) of the Federal
Food, Drug and Cosmetic Act (the Act).

Our investigation found a failure to separate the receipt, processing,
and storage of the product containing prohibited material from
non-prohibited material; failure to establish a written system,
including clean-out and flushing procedures, to avoid commingling and
cross-contamination of common equipment; and failure to maintain records
sufficient to track the materials throughout the receipt, processing,
and distribution of your products.

In addition, our investigation found a failure to label your products
with the required cautionary, statement "Do Not Feed to Cattle or Other
Ruminants," Your pig feeds, containing prohibited materials, were not
labeled with the cautionary statement, and you reuse poly-tote bags for
ruminant feed and pig feed, where the bags could become contaminated
with prohibited material. The FDA suggests the statement be
distinguished by different type size or color or other means of
highlighting the statement so that it is easily noticed by a purchaser.

The above is not intended to be an all-inclusive list of deviations from
the regulations. As a manufacturer of materials intended for animal feed
use, you are responsible for assuring that your overall operation and
the products you manufacture and distribute are in compliance with

William W. Himmelspach Tualatin, Oregon Re: Warning Letter SEA 01-75 Page 2

your overall operation and the products you manufacture and distribute
are in compliance with the law. We have enclosed a copy of the FDA's
Small Entity Compliance Guide to assist you with complying with the
regulation.

You should take prompt action to correct these violations, and you
should establish a system whereby such violations do not recur. Failure
to promptly correct these violations may result in regulatory action
without further notice, such as seizure and/or injunction.

You should notify this office in writing within 15 working days of
receipt of this letter, of the steps you have taken to bring your firm
into compliance with the law. Your response should include an
explanation of each step being taken to correct the violations, and
prevent their recurrence. If corrective action cannot be completed in 15
working days, state the reason for the delay and the date by which the
corrections will be completed. Include copies of any available
documentation demonstrating that corrections have been made.

Your reply should be directed to the Food and Drug Administration,
Attention: Bruce Williamson, Compliance Officer. If you have any
questions please contact Mr. Williamson at (425) 483-4976.

Sincerely,

Charles M. Breen District Director

Enclosure; Form FDA 483 Small Entity Compliance Guide

http://www.fda.gov/foi/warning_letters/g1619d.pdf

Warning Letters Index - Search Form Results Company Name Date Issued
Issuing Office

Subject

File Adrian Elevator, Inc. 5/03/01 Minneapolis District Office Animal
Proteins Prohibited in Ruminant Feed

View File Alaska Garden and Pet Supply, Inc. 4/27/01 Seattle District
Office Animal Proteins Prohibited in Ruminant Feed

View File Bryan Enterprises 2/20/01 Cincinnati District Office Feed
Mill/Animal Proteins Prohibited in Ruminant Feed/Adulterated

View File Carrollton Farmers Exchange 7/12/01 Cincinnati District Office
Animal Proteins Prohibited in Ruminant Feed

View File Centerburg Mill and General Store, Inc 3/23/01 Cincinnati
District Office Animal Proteins Prohibited in Ruminant Feed

View File Centerburg Mill and General Store, Inc. 5/23/01 Cincinnati
District Office Animal Proteins Prohibited in Ruminant Feed

View File Central Ohio Farmers Cooperative, Inc. 5/24/01 Cincinnati
District Office Animal Protein Prohibited in Ruminant Feed

View File Champaign Landmark, Inc. 3/05/01 Cincinnati District Office
Animal Proteins Prohibited in Ruminant Feed/Misbranded

View File Countryline Co-Op, Inc. 5/14/01 Cincinnati District Office
Animal Proteins Prohibited in Ruminant Feed

View File Dorset Milling 4/16/01 Cincinnati District Office Animal
Proteins Prohibited in Ruminant Feed

View File Earl B. Olson Feed Mill 4/23/01 Minneapolis District Office
Animal Proteins Prohibited in Ruminant Feed

View File Faler Feed Store, Inc. 3/21/01 Cincinnati District Office
Animal Proteins Prohibited in Ruminant Feed

View File Farmers Mill & Elevator Company 3/30/01 Atlanta District
Office Animal Proteins Prohibited in Ruminant Feed

View File Farnam Companies, Inc. 7/20/01 Kansas City District Office
Animal Proteins Prohibited in Ruminant Feed/Adulterated

View File Greeley Elevator Company 4/04/01 Denver District Office Animal
Proteins Prohibited in Ruminant Feed

View File Hartville Elevator Company, Inc. 2/22/01 Cincinnati District
Office Feed Mill/Animal Proteins Prohibited in Ruminant Feed/Adulterated

View File Himmelspach, William W. 8/08/01 Seattle District Office Animal
Proteins Prohibited in Ruminant Feed

View File Integral Fish Foods, Inc. 6/12/01 Denver District Office
Animal Proteins Prohibited in Ruminant Feed

View File Jefferson Milling Company 4/16/01 Cincinnati District Office
Animal Proteins Prohibited in Ruminant Feed

View File Lime Creek Ag Services, Inc. 4/25/01 Minneapolis District
Office Animal Proteins Prohibited in Ruminant Feed

View File Material Resources LLC 5/04/01 Chicago District Office Animal
Proteins Prohibited in Ruminant Feed

View File Material Resources, LLC 5/04/01 Chicago District Office Animal
Protein Prohibited in Ruminant Feed

View File Medina Landmark, Inc. 3/23/01 Cincinnati District Office
Animal Proteins Prohibited in Ruminant Feed

View File Minister Farmers Cooperative Exchange, Inc. 4/10/01 Cincinnati
District Office Animal Proteins Prohibited in Ruminant Feed/Feed Mill

View File Peco Foods, Inc. 2/23/01 New Orleans District Office CGMP
Requirements for Medicated Feeds/Animal Proteins Prohibited in Ruminant Feed

View File Perry Coal and Feed Company 4/16/01 Cincinnati District Office
Animal Proteins Prohibited in Ruminant Feed

View File Rietdyk's Milling Company 3/05/01 Seattle District Office
Animal Proteins Prohibited in Ruminant Feed

View File River Valley Co-Op 3/22/01 Cincinnati District Office Animal
Proteins Prohibeted in Ruminant Feed

View File River Valley Co-Op 5/22/01 Cincinnati District Office Animal
Proteins Prohibited in Ruminant Feed

View File Round Lake Farmers Coop. 5/30/01 Minneapolis District Office
Animal Proteins Prohibited in Ruminant Feed

View File Rudy, Inc. 3/22/01 Cincinnati District Office Animal Proteins
Prohibited in Ruminant Feed

View File Rudy, Inc. 5/22/01 Cincinnati District Office Animal Proteins
Prohibited in Ruminant Feed

View File Sandy Lake Mills 4/09/01 Philadelphia District Office Animal
Proteins Prohibited in Ruminant Feed

View File Shields Feed and Supply Company 3/07/01 New Orleans District
Office Animal Proteins Prohibited in Ruminant Feed

View File Stewart's Farm Supply 3/21/01 Cincinnati District Office
Animal Proteins Prohibited in Ruminant Feed

View File Superior Feeds 6/06/01 Seattle District Office Animal Proteins
Prohibited in Ruminant Feed

View File The Scoular Company 5/30/01 Minneapolis District Office Animal
Proteins Prohibited in Ruminant Feed

View File University of Minnesota 5/10/01 Minneapolis District Office
Animal Proteins Prohibited in Ruminant Feed

View File Valley Feed Mill, Inc. 5/22/01 Cincinnati District Office
Animal Proteins Prohibited in Ruminant Feed

View File Wallowa County Grain Growers, Inc. 5/17/01 Seattle District
Office Animal Proteins Prohibited in Ruminant Feed

View File Wallowa County Grain Growers, Inc. 5/17/01 Seattle District
Office Animal Proteins Prohibited in Ruminant Feed

View File Western Reserve Farm Cooperative 3/21/01 Cincinnati District
Office Animal Protein Prohibited in Ruminant Feed

View File Yachere Feed, Inc. 4/09/01 Philadelphia District Office Animal
Proteins Prohibited in Ruminant Feed

View File Z & W Mill, Inc. 3/27/01 Denver District Office Animal
Proteins Prohibited in Ruminant Feed

View File

http://63.75.126.221/scripts/wlcfm/resultswl.cfm

(TYPE IN 'ANIMAL PROTEIN')

we must not forget the ANIMAL PROTEIN FED TO DEER/ELK.
those warning letters were stopped long ago;

Subject: MAD DEER/ELK DISEASE AND POTENTIAL SOURCES
Date: Sat, 25 May 2002 18:41:46 -0700
From: "Terry S. Singeltary Sr."
Reply-To: BSE-L
To: BSE-L

8420-20.5% Antler Developer
For Deer and Game in the wild
Guaranteed Analysis Ingredients / Products Feeding Directions

snip...

_animal protein_

http://www.surefed.com/deer.htm

BODE'S GAME FEED SUPPLEMENT #400
A RATION FOR DEER
NET WEIGHT 50 POUNDS
22.6 KG.

snip...

_animal protein_

http://www.bodefeed.com/prod7.htm

Ingredients

Grain Products, Plant Protein Products, Processed Grain By-Products,
Forage Products, Roughage Products 15%, Molasses Products,
__Animal Protein Products__,
snip...

http://www.bodefeed.com/prod6.htm
===================================

MORE ANIMAL PROTEIN PRODUCTS FOR DEER

Bode's #1 Game Pellets
A RATION FOR DEER
F3153

GUARANTEED ANALYSIS
Crude Protein (Min) 16%
Crude Fat (Min) 2.0%
snip...

Ingredients

Grain Products, Plant Protein Products, Processed Grain By-Products,
Forage Products, Roughage Products, 15% Molasses Products,
__Animal Protein Products__,
Monocalcium Phosphate, Dicalcium Phosphate, Salt,
snip...

FEEDING DIRECTIONS
Feed as Creep Feed with Normal Diet

http://www.bodefeed.com/prod8.htm

INGREDIENTS

Grain Products, Roughage Products (not more than 35%), Processed Grain
By-Products, Plant Protein Products, Forage Products,
__Animal Protein Products__,
L-Lysine, Calcium Carbonate, Salt, Monocalcium/Dicalcium
snip...

DIRECTIONS FOR USE

Deer Builder Pellets is designed to be fed to deer under range
conditions or deer that require higher levels of protein. Feed to deer
during gestation, fawning, lactation, antler growth and pre-rut, all
phases which require a higher level of nutrition. Provide adequate
amounts of good quality roughage and fresh water at all times.

http://www.profilenutrition.com/Pro...er_pellets.html

DEPARTMENT OF HEALTH & HUMAN SERVICES
PUBLIC HEALTH SERVICE
FOOD AND DRUG ADMINISTRATION

April 9, 2001 WARNING LETTER

01-PHI-12
CERTIFIED MAIL
RETURN RECEIPT REQUESTED

Brian J. Raymond, Owner
Sandy Lake Mills
26 Mill Street
P.O. Box 117
Sandy Lake, PA 16145
PHILADELPHIA DISTRICT

Tel: 215-597-4390

Dear Mr. Raymond:

Food and Drug Administration Investigator Gregory E. Beichner conducted
an inspection of your animal feed manufacturing operation, located in
Sandy Lake, Pennsylvania, on March 23, 2001, and determined that your
firm manufactures animal feeds including feeds containing prohibited
materials. The inspection found significant deviations from the
requirements set forth in Title 21, code of Federal Regulations, part
589.2000 - Animal Proteins Prohibited in Ruminant Feed. The regulation
is intended to prevent the establishment and amplification of Bovine
Spongiform Encephalopathy (BSE) . Such deviations cause products being
manufactured at this facility to be misbranded within the meaning of
Section 403(f), of the Federal Food, Drug, and Cosmetic Act (the Act).

Our investigation found failure to label your swine feed with the
required cautionary statement "Do Not Feed to cattle or other Ruminants"
The FDA suggests that the statement be distinguished by different
type-size or color or other means of highlighting the statement so that
it is easily noticed by a purchaser.

In addition, we note that you are using approximately 140 pounds of
cracked corn to flush your mixer used in the manufacture of animal
feeds containing prohibited material. This flushed material is fed to
wild game including deer, a ruminant animal. Feed material which may
potentially contain prohibited material should not be fed to ruminant
animals which may become part of the food chain.

The above is not intended to be an all-inclusive list of deviations from
the regulations. As a manufacturer of materials intended for animal
feed use, you are responsible for assuring that your overall operation
and the products you manufacture and distribute are in compliance with
the law. We have enclosed a copy of FDA's Small Entity Compliance Guide
to assist you with complying with the regulation... blah, blah, blah...

http://www.fda.gov/foi/warning_letters/g1115d.pdf
===================================================

now, what about those 'deer scents' of 100% urine',
and the prion that is found in urine, why not just
pass the prion with the urine to other deer...

Mrs. Doe Pee Doe in Estrus
Model FDE1 Mrs. Doe Pee's Doe in Estrus is made from Estrus urine
collected at the peak of the rut, blended with Fresh Doe Urine for an
extremely effective buck enticer. Use pre-rut before the does come into
heat. Use during full rut when bucks are most active. Use during
post-rut when bucks are still actively looking for does. 1 oz.

http://www.gamecalls.net/huntingproducts/deerlures.html

ELK SCENT/SPRAY BOTTLE
*
Works anytime of the year
*
100 % Cow Elk-in-Heat urine (2oz.)
*
Economical - mix with water in spray mist bottle
*
Use wind to your advantage

Product Code WP-ESB $9.95

http://www.elkinc.com/Scent.asp

prions in urine?

[PDF] A URINE TEST FOR THE IN-VIVO DIAGNOSIS OF PRION DISEASES

http://www.sigov.si/vurs/PDF/diagnoastika-bse-urin.pdf

Subject: Meat and Poultry: Better USDA Oversight and Enforcement of Safety
Date: Thu, 19 Sep 2002 14:17:59 -0700
From: "Terry S. Singeltary Sr."
Reply-To: BSE-L
To: BSE-L

3. Meat and Poultry: Better USDA Oversight and Enforcement of Safety
Rules Needed to Reduce Risk of Foodborne Illnesses. GAO-02-902, August
30.

FSIS Is Not Ensuring that Plants' HACCP Plans Meet Regulatory
Requirements

snip...

According to FSIS's food safety systems correlation reviews, inspectors
are not consistently identifying and documenting failures of plants'
HACCP plans to meet regulatory requirements. Furthermore, FSIS does
not expect its inspectors to determine whether HACCP plans are based on
sound science--the cornerstone of an effective plan. While in-depth
verification reviews examine the scientific aspects of HACCP plans, they
have been conducted in very few plants, and consumer safety officers
hired to review the scientific soundness of HACCP plans may take several
years to assess the plans at all plants. Moreover, inspectors in 55
percent of the 5,000 plants nationwide did not document any HACCP
violations during fiscal year 2001. When we brought this information to
the attention of FSIS officials, they were surprised that so many plants
had no HACCP violations for an entire year.

snip...

2. USDA believes that the title of the report is misleading. We
disagree. We believe the title accurately reflects the concerns detailed
throughout the body of the report.

snip...

http://www.gao.gov/cgi-bin/getrpt?GAO-02-902

Subject: GAO ''BLASTS'' USA FDA HALF-ASS MAD COW FEED BAN RULES (or the
lack of)
Date: Tue, 26 Feb 2002 11:29:57 -0800
From: "Terry S. Singeltary Sr."
Reply-To: BSE-L
To: BSE-L

Investigators: FDA Lax on Mad Cow
Tue Feb 26,11:37 AM ET

By PHILIP BRASHER, AP Farm Writer

WASHINGTON - The Food and Drug Administration (news - web sites ) has
failed to properly enforce its restrictions on animal feed that are
intended to keep mad-cow disease from spreading if it ever gets into the
country, congressional investigators say.

Feed mills and other firms that violate the rules are seldom punished,
and FDA has never even identified all the businesses that should be
inspected, the General Accounting Office (news - web sites) said in a
report released Tuesday.

The report also raises concerns about import controls that are supposed
to keep infected meat and other material from entering the country

"The continuing absence of (mad cow disease) in the United States today
cannot be sufficiently ensured by current federal prevention efforts,"
the report said.

The agency outlawed the feeding of mammalian meat and bone meal to
cattle, sheep and goats in 1997 and imposed a series of rules to ensure
that feed mills comply with the ban.

Animals are believed to get the brain-wasting disease, formally known as
bovine spongiform encephalopathy (news - web sites ), through eating the
brain or nervous system tissue from diseased animals. Meat and bone meal
has long been added to animal feed as a protein supplement.

The disease has never been found in the United States but has devastated
the beef industry in Europe and spread to Japan.

An FDA spokesman had no immediate comment Tuesday on the GAO report. In
a letter to the investigators, however, FDA said it is correcting
problems in its inspection system. Improvements in the system "will make
the present small risk of introduction and spread (of mad-cow disease
even smaller," the agency said.

The food industry became alarmed last year about the problems FDA was
having enforcing the rules and began requiring meat processors to
certify that the cattle were not given prohibited feed. Slaughterhouses,
in turn, started requiring similar paperwork from their cattle suppliers.

The congressional investigators said "the nature and severity of the
problem" in FDA's enforcement of the feed ban "point to insufficient
attention by FDA management."

The report also says that the Agriculture Department is testing too few
cattle for the disease. USDA plans to increase its testing from 5,000 to
12,500 cattle a year.

Sen. Richard Durbin (news ), D-Ill., who requested the GAO report along
with Senate Agriculture Committee Chairman Tom Harkin of Iowa and the
panel's ranking Republican, Richard Lugar of Indiana, plans to introduce
legislation to tighten federal regulation of animal feed and meat
processing.

Patrick Boyle, president of the American Meat Institute, said the GAO
report "misinterprets, or simply ignores the effectiveness of measures
already taken" by the government.

http://story.news.yahoo.com/news?tm...pe/us_mad_cow_3

FULL TEXT OF GOA REPORT BELOW (takes a while to load)

2. Mad Cow Disease: Improvements in the Animal Feed Ban and Other
Regulatory Areas Would Strengthen U.S. Prevention Efforts. GAO-02-183,
January 25.

http://www.gao.gov/cgi-bin/getrpt?GAO-02-183

i will patiently await a reply from FDA lurkers about this
serious matter for public awareness...

kind regards,
Terry S. Singeltary Sr., Bacliff, Texas USA
=============================================

Subject: USA BSE/TSE RUMINANT-TO-RUMINANT FEED BAN VIOLATIONS ''cover-up''
From: "Terry S. Singeltary Sr."
Date: Mon, 2 Dec 2002 11:17:40 -0600
To: BSE-L

Greetings List members,

i have tried to inquire about the USA BSE/TSE feed ban
violations with no luck via USDA/APHIS. since about april
or may of 2002, the warning letters have ceased to be posted
publicly, and at the site CVM and Ruminant feed inspections
site url, they have not been updated either. it seems to
me the new administration has taken away all rights for
the public to view these violations.

where are they now being posted ???

you can hide it, but it will not make it go away.

would/could the USDA/APHIS whom lurk on this list,
please comment?

http://www.fda.gov/cvm/efoi/InpectionListDescriptionforHP.htm

http://www.testcowsnow.com

GBR risk assessment of BSE should be changed to all TSEs.

USA GBR II should be changed to GBR III immediately!

now about those ruminant-to-ruminant feed ban violations
that have ceased to be published? why you may ask?

Subject: Re: USA ruminant-to-ruminant feed ban warning letters ???
Date: Mon, 13 Jan 2003 15:08:13 -0600
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
To: BSE-L
References: <3E075C47.3080506@wt.net> <3E21BA6C.3040900@wt.net> <3E23107A.433C64BF@airtime.co.uk>

hello Dr. Dealler,

please do not hold your breath for any USA
ruminant-to-ruminant feed ban warning letters
since May of 2002 to be released anytime soon,
this could be fatal for you;-)
i have not gotten them yet, if any exist.
but i am trying.
hopefully GW et al will not think i am one of
the terrorist, and will allow for this information
to be released (with no charge attached$$$)...

kindest regards,
terry

Steve Dealler wrote:

> This was absolutely excellent for Terry to have got this from the US
> Government...you should have tried getting this sort of thing from MAFF in the UK
> at the beginning of the nineties!
> Steve Dealler
>
> "Terry S. Singeltary Sr." wrote:
>
>
>>
>>Greetings List Members,
>>
>>as you know, i finally had to request to the FOIA
>>for the USA madcow feed ban warning letters. so i thought
>>some of you may be interested in an update on this matter.
>>
>>so here it is;
>>
>>Subject: Request to FDA via FOIA of ALL USA Ruminant-to-Ruminant Feed
>>Ban Violations Jan. 2001 to Jan. 2003
>>Date: Mon, 6 Jan 2003 08:32:43 -0600
>>From: "Terry S. Singeltary Sr."
>>Reply-To: Bovine Spongiform Encephalopathy
>>To: BSE-L
>>
>>Food and Drug Administration
>>Office of Information Resources Management
>>Division of Freedom of Information (HFI-35)
>>5600 Fishers Lane
>>Rockville, MD 20857
>>
>>Or requests may be sent via fax to: (301) 443-1726. If there are
>>problems sending a fax, call (301) 443-2414.
>>
>>1/6/03
>>
>>Request to FDA via FOIA of ALL USA Ruminant-to-Ruminant Feed Ban
>>Violations Jan. 2001 to Jan. 2003
>>
>>Greetings FDA and To Whom it may concern,
>>
>>i wish to request all ruminant-to-ruminant feed ban violations from Jan.
>>2001 to Jan. 2003. it seems none has been posted since May 2001 on the
>>FDA site. I also kindly request that all fees be wavered due to the fact
>>this is public information, public health is at risk, and this
>>will be distributed 'freely' to the public...
>>
>>thank you,
>>kind regards,
>>
>>I am sincerely,
>>
>>Terry S. Singeltary Sr.
>>P.O. Box Bacliff, Texas USA 77518
>>CJD Watch
>>http://www.fortunecity.com/healthclub/cpr/349/part1cjd.htm
>>==========================================================
>>
>>now since then, just this past Friday 1/10/03, i get this from
>>FDA;
>>
>>REPLY FROM DPH/FDA to TSS;
>>
>>PLEASE note, my request was for all R-T-R feed ban
>>violations from Jan. 2001 to Jan. 2003. BUT in the
>>reply, they posted Jan. 2002 to Jan. 2003. i called
>>and this is to be corrected. hopefully this FOIA
>>request will ignite some enthusiasm from the FDA
>>into posting to the public any R-T-R MAD COW
>>FEED BAN violations, since GW et al new policy
>>on secrecy took effect on this matter in May of 2002
>>(correcting my below 'since May 2001).
>>
>>TSS
>>
>>Department of Health & Human Services
>>
>>Food and Drug Administration
>>Rockville MD 20857
>>
>>1/7/03
>>
>>In reply refer to;
>>
>>xxxxxxx
>>
>>Dear Requester,
>>
>>The Food and Drug Administration (FDA) has received your
>>Freedom of Information Act (FOIA) request for records
>>regarding;
>>
>>RUMINANT-TO-RUMINANT FEED - BAN VIOLATIONS 1/02 - 1/03
>>
>>We will respond as soon as possible and may charge you a fee
>>for processing your request. If you have any questions
>>about your request, please call Edna G. Wilkerson,
>>Information Technician, at 301-827-6564 or write to us
>>at;
>>
>>Food and Drug Administration
>>Division of Freedom of Information
>>5600 Fishers Lance, HFI - 35
>>Rockville, MD 20857
>>
>>If you call or write, use the reference number above
>>which will help us to answer your questions more quickly...
>>===========================================================
>>now, Sunday, i read this in the Houston Chronicle 1/12/03;
>>
>>SENATOR AIMS TO UPGRADE FREEDOM OF INFORMATION
>>
>>TEXAS Sen. John Coprnyn says he wants to improve public access to
>>government records in Washington, a position that appears to put
>>him at odds with the Bush administration.
>>
>>Cornyn, a moderate Republican who sits on the Senate Judiciary
>>Committee, said he'll work on legislation in the coming weeks to
>>improve the Freedom of Information Act.
>>
>>"FOIA needs to be strenghened," he said, "We need to quicken the
>>turnaround time and create a mechanism that allows an indepentent,
>>third party to decide whether a record should be kept secret."
>>
>>Echoing sentiments he expressed while serving as Texas attorney
>>general, Cornyn added: "I believe in a system of governement
>>that allows consent of the people. And people can't consent if they
>>don't what their elected officials are doing."
>>
>>Since taking office two years ago, the Bush Administration has
>>taken steps to restrict access to governement information, an effort
>>that was accelerated in the name of national security following
>>the Sept. 11 terrorist attacks......
>>
>>Greetings again BSE-L list members,
>>
>>how would _USA_ ruminant-to-ruminant feed ban warning
>>letters have anything to do with terrorism and National
>>Security?
>>
>>you can see a list of sample USA madcow warning letters;
>>
>>http://www.vegsource.com/talk/madcow/messages/9912238.html
>>
>>FYI, please see a bit of history on this topic;
>>
>>Date: Wed, 2 Oct 2002 09:04:42 -0700
>>Reply-To: Bovine Spongiform Encephalopathy
>>Sender: Bovine Spongiform Encephalopathy
>>From: "Terry S. Singeltary Sr."
>>Subject: MAD COW FEED BAN WARNING LETTERS USA 'update' (where did
>>all Terry's MAD COW warning letters go?)
>>
>>snip...
>>
>>Food and Drug Administration Kansas City District Southwest Region 11630
>>West 60 Street P.O. Box 15905 Lenexa, Kansas 66265-4905 Telephone: (913)
>>752-2100
>>
>>July 29, 2002 CERTIFIED MAIL RETURN RECEIPT REQUESTED WARNING LETTER
>>Ref. KAN 2002-09
>>
>>Jerry Behimer, Owner Bakery Trading Company/Ingredient Exchange 401 N.
>>Lindbergh Blvd., Suite 315 St. Louis, MO 63141-7816
>>
>>Dear Mr. Behimer:
>>
>>An inspection of your animal feed premix-manufacturing operations,
>>located at 14521 2nd Ave., Ottumwa, Iowa, was conducted by an
>>Investigator from our office on June 18 & 19, 2002. During this
>>inspection, a significant deviation from the requirements set forth in
>>Title 21, Code of Federal Regulations, Part 589.2000 - Animal Proteins
>>Prohibited in Ruminant Feed was identified. The regulation is intended
>>to prevent the establishment and amplification of Bovine Spongiform
>>Encephalopathy (BSE). Under 21 C.F.R. 589.2000(g)(2), such a deviation
>>causes products being manufactured and/or distributed by your facility
>>to be deemed misbranded within the meaning of Section 403(a)(l) of the
>>Federal Food, Drug, and Cosmetic Act (the Act), and these products may
>>not be lawfully introduced, or delivered for introduction, into
>>interstate commerce.
>>
>>Our investigation found a failure to label your Powdered Cooked Beef,
>>Product No. 5013, produced during the period of 2/13/02 to approximately
>>4/18/02, with the cautionary statement "Do Not Feed to Cattle or Other
>>Ruminants," as required by 21 C.F.R. 589.2000(d). The FDA suggests the
>>statement be distinguished by different type size or color, or other
>>means of highlighting the statement so that it is easily noticed by a
>>purchaser.
>>
>>The above is not intended to be an all-inclusive list of deviations from
>>the regulations. As a manufacturer of materials intended for animal feed
>>use, you are responsible for assuring that your overall operation and
>>the products you manufacture and distribute are in compliance with the law.
>>
>>You should take prompt action to correct this violation, and you should
>>establish a system whereby such violations do not recur. Failure to
>>promptly correct these violations may result in regulatory action
>>without further notice, such as seizure and/or injunction.
>>
>>It is necessary for you to take action on this matter now. We request
>>you provide our office documentation of corrective action and final
>>disposition for Lot 030402, approximately 21 tons, which was on hand
>>during the inspection. Let this office know in writing within fifteen
>>(15) working days from the date you received this letter what steps you
>>are taking to correct the problem.
>>
>>Your reply should be sent to Nadine Nanko Johnson, Compliance Officer,
>>at the above address.
>>
>>Sincerely,
>>
>>/s/
>>
>>Charles W. Sedgwick
>>
>>District Director
>>
>>Kansas City District
>>
>>http://www.fda.gov/foi/warning_letters/g3430d.htm
>>
>>Food and Drug Administration Seattle District Pacific Region 22201 23rd
>>Drive SE Bothell, WA 98021-4421 Telephone: 425-466-6766 FAX: 426-483-4996
>>
>>May 7, 2002 CERTIFIED MAIL RETURN RECEIPT REQUESTED In reply refer to
>>Warning Letter SEA 02-46 WARNING LETTER
>>
>>Mr. Philip C. Anderson, General Manager Darling International, Inc. 2041
>>Marc Avenue Tacoma, Washington 98401
>>
>>Dear Mr. Anderson:
>>
>>An inspection of your rendering operation conducted by Investigator
>>Donald B. McKechnie, on February 22 and 26, 2002, found a significant
>>deviation from the requirements set forth in Title 21, Code of Federal
>>Regulations, Part 589.2000 - Animal Proteins Prohibited in Ruminant
>>Feed. The regulation is intended to prevent the establishment and
>>amplification of Bovine Spongiform Encephalopathy (BSE). Such deviation
>>causes products being manufactured and/or distributed by your facility
>>to be misbranded within the meaning of Section 403(f) of the Federal
>>Food, Drug, and Cosmetic Act (the Act).
>>
>>Our investigation found a failure to consistently label your meat and
>>bone meal product shipped to [redacted], with the required cautionary
>>statement "Do Not Feed to Cattle or Other Ruminants". The meat and bone
>>meal contains beef offal along with other ingredients including chicken,
>>fish, and pork. The FDA suggests the statement be distinguished by
>>different type size or color or other means of highlighting the
>>statement so that it is easily noticed by a purchaser.
>>
>>The above is not intended to be an all-inclusive list of deviations from
>>the regulations. As a manufacturer of materials intended for animal feed
>>use, you are responsible for assuring that your overall operation and
>>the products you manufacture and distribute are in compliance with the
>>law. We have enclosed a copy of the FDA?s Small Entity Compliance Guide
>>to assist you with complying with the regulation.
>>
>>You should take prompt action to correct this violation, and you should
>>establish a system whereby such violation does not recur. Failure to
>>promptly correct this violation may result in regulatory action without
>>further notice, such as seizure and/or injunction.
>>
>>You should notify this office in writing within 15 working days of
>>receipt of this letter, of the steps you have taken to bring your firm
>>into compliance with the law. Your response should include an
>>explanation of each step being taken to correct the violation, and to
>>prevent its recurrence. If corrective action cannot be completed in 15
>>working days, state the reason for the delay and the date by which the
>>corrections will be completed. Include copies of any available
>>documentation demonstrating that corrections have been made.
>>
>>Please send your reply to the Food and Drug Administration, Attention:
>>Thomas S. Piekarski, Compliance Officer, 22201 23rd Drive SE, Bothell,
>>Washington 98021. If you have questions regarding any issue in this
>>letter, please contact Mr. Piekarski at (425) 483-4975. Sincerely,
>>Charles Breen District Director
>>
>>http://www.fda.gov/foi/warning_letters/g3276d.htm
>>
>>where, oh where, did all Terry's mad cow feed ban warning letters go$
>>
>>FDA Cuts Back on Warnings
>>
>>10/01/02
>>
>>WASHINGTON -- The Food and Drug Administration has substantially cut
>>back on warnings sent to companies that run afoul of its rules, a move
>>the agency contends will result in more-effective enforcement but that
>>critics say lets violators off the hook.
>>
>>The drop results from a policy change in late February that requires the
>>FDA chief counsel's office to clear all warning letters to ensure they
>>are legally sound. Before the change, division and district offices
>>around the country issued such letters unilaterally. In the six months
>>since, the agency issued 279 warning letters, a drop of 64% from the
>>same period last year, a review of agency records shows. The FDA says
>>the chief counsel's office rejected only 6% of the 699 warning letters
>>and other citations it reviewed. At the same time, division and district
>>enforcers may be holding back letters they once would have sent.
>>
>>SEE FULL STORY
>>
>>http://online.wsj.com/
>>
>>snip...
>>
>>Date: Wed, 9 Oct 2002 13:21:00 -0700
>>Reply-To: Bovine Spongiform Encephalopathy
>>Sender: Bovine Spongiform Encephalopathy
>>From: "Terry S. Singeltary Sr."
>>Subject: 'TONNAGE' OF TAINTED FEED $ what's up with the mad cow warning
>> letters
>>
>>Greetings,
>>
>>since the FDA has apparently stopped issuing some warning letters;
>>
>>10/7/02
>>
>>Senate Questions FDA Commissioner Nominee
>>
>>In testimony today before the U.S. Senate, Dr. Mark McClellan, the Bush
>>administration nominee for Commissioner of Food and Drugs, said that
>>under his leadership, the FDA would uphold its enforcement authority to
>>ensure the safety and effectiveness of the products it regulates and to
>>ensure that accurate and truthful information is conveyed to the public.
>>
>>Sen. Edward Kennedy (D-Mass.), chairman of the Senate Health, Education,
>>Labor and Pensions (HELP) Committee, expressed concern at the start of
>>the hearing that the FDA may be backing away from its regulatory
>>authority, noting a drop in the number of Warning Letters issued by the
>>agency, rumors that the FDA may regulate certain contact lenses as
>>cosmetics rather than as devices and the agency's re-examination of its
>>policies in light of First Amendment challenges.
>>
>>Although McClellan did not comment directly on any of the specific
>>examples cited by Kennedy, the nominee said that he sees "no intent on
>>FDA's part to retreat from its mission" of protecting the public health...
>>
>>snip...
>>
>>http://www.thompson.com/fda
>>
>>maybe i was not too far off when i acting in haste on the previous
>>thread on BSE-L, see archived thread;
>>
>>Subject: USA/THOMPSON TURNS TO COMMUNISM TACTICS, FDA TURNS TO SECRECY
>>ON MAD COW FEED WARNING LETTERS Date: Mon, 9 Sep 2002 12:07:02 -0700
>>From: "Terry S. Singeltary Sr." Reply-To: BSE-L
>>
>>so, i was nosing around the FDA warning letters and other files, came
>>across these and thought since 1/2 to 1 GRAM is lethal to a cow, i
>>thought these TONNAGE in some of these violations i ran across most
>>interesting. no telling how many dead road-kill CWD infected carcasses
>>were rendered into this, along with whatever type TSE in USA cattle, and
>>we can't forget about all the scrapie infected sheep that may have been
>>added to the soup. with a combination of CWD, SCRAPIE, TME and all the
>>different variants that may have come from them over the years, what in
>>the world would you call the TSEs in USA cattle, once they test to find,
>>and then find? could be a nasty one. or maybe none at all? doubtful
>>though (just my opinion, if i still allowed one here);
>>
>>PRODUCT BioFlavor F2425, BioFlavor F21002 and BioFlavor C20058. The
>>product, packaged in 50 lb. bags, is labeled in part, " *** PALATABILITY
>>ENHANCER INTENDED FOR CAT FOOD USE AT LESS THAN 10% *** INGREDIENT
>>LISTING: *** Beef Broth *** ". Recall # V-140-2 CODE Product Codes F2425
>>107B-RB-1 107B-RB-2 149C 201D 202C 205D 210A F21002 143B 143D 146D 144B
>>144D 139D 142D 150D 151D 152C 152D 201C 205C 206C 208A 211A C20058 143D
>>144C 146C 208B RECALLING FIRM/MANUFACTURER Recalling Firm: Bioproducts,
>>Inc., Fairlawn, OH, by telephone and letter on April 5, 2002.
>>Manufacturer: Bioproducts, Inc., Aurora, MO. Firm initiated recall is
>>ongoing. REASON Animal feed product with beef protein does not contain
>>required BSE statement on labels.
>>
>>VOLUME OF PRODUCT IN COMMERCE 354,150 lbs.
>>
>>DISTRIBUTION TX, KS, MO and MI. _______________________
>>
>>PRODUCT Steamed Bonemeal in 50-lb. bags, product code C# 13581, packaged
>>under two different labels: Premium Steamed Bonemeal Manufactured by
>>Buchheit Premium Feeds, Perryville, MO, and Steamed Bonemeal
>>Manufactured for Siemer's Enterprises Inc., Teutopolis, IL. Recall #
>>V-141-2. CODE Not coded. RECALLING FIRM/MANUFACTURER Buchheit, Inc.,
>>Perryville, MO, by telephone on May 14, 2002. FDA initiated recall is
>>ongoing. REASON Label lacks BSE warning statement.
>>
>>VOLUME OF PRODUCT IN COMMERCE
>>
>>Approx. 902/50-lb. bags.
>>
>>DISTRIBUTION MO and IL.
>>
>>END OF ENFORCEMENT REPORT FOR JUNE 5, 2002
>>
>>####
>>
>>PRODUCT
>>
>>The following custom mixed animal feeds are recalled --- a)
>>[non-ruminant]: Horse Feed, Hog Feed, and 14% Pig Feed. Recall #
>>V-157-2; b) [ruminant]: Dairy Feed, Steer Feed, New Goat Feed, Cattle
>>Feed, and Beef Feed. Recall # V-158-2. CODE The product is coded only
>>with the manufacturing date and invoice numbers. All feed products
>>manufactured and shipped since July 9, 2001 are affected by this recall.
>>RECALLING FIRM/MANUFACTURER Recalling Firm: Shepard Grain Company, Inc.,
>>Urbana, OH, by telephone on January 11, 2002. Manufacturer: Shepard
>>Grain Company, Inc., W. Liberty, OH. FDA initiated recall is complete.
>>REASON Ruminant and non-ruminant animal feeds contain BSE prohibited
>>material, and are either misbranded or adulterated.
>>
>>VOLUME OF PRODUCT IN COMMERCE
>>
>>41,129 LBS (20.5 tons).
>>
>>DISTRIBUTION OH.
>>
>>END OF ENFORCEMENT REPORT FOR AUGUST 28, 2002 ####
>>
>>PRODUCT:
>>
>>Buckeye 40% Poultry Concentrate. Recall #V-016-1. CODES: The bags are
>>uncoded. Firm is recalling product manufactured since December 1998;
>>however, they are only completing field corrections on product
>>manufactured within the last six months (November 2000). MANUFACTURER:
>>Yachere Feed, Inc. Rockwood, Pennsylvania. RECALLED BY: Manufacturer, by
>>visit on 3/19/01 and 3/20/01. Firm-initiated recall complete.
>>
>>DISTRIBUTION:
>>
>>Pennsylvania.
>>
>>QUANTITY:
>>
>>Nine containers, each weighing 100 pounds.
>>
>>REASON: The animal feed contains product derived from mammalian tissues
>>and must bear the statement "Do not feed to cattle or other ruminants"
>>on the label to prevent the establishment and amplification of BSE
>>through feed. This statement does not appear on the label. ________
>>
>>PRODUCT:
>>
>>"Our Own Pig & Hog Grower" hog feed, packaged in 50 pound bags, with
>>paperboard tags sewn onto the bags. Recall #V-017-1. CODES: The bags are
>>uncoded. MANUFACTURER: The Perry Coal and Feed Company, Perry, Ohio.
>>RECALLED BY: Manufacturer, by telephone on March 22, 2001.
>>Firm-initiated recall complete.
>>
>>DISTRIBUTION:
>>
>>Ohio.
>>
>>QUANTITY:
>>
>>Approximately 350 pounds of hog feed (7/50 pound bags).
>>
>>REASON: The animal feed contains protein derived from mammalian tissues
>>and must bear the statement "Do not feed to cattle or other ruminants"
>>on the label to prevent the establishment and amplification of BSE
>>through feed. This statement does not appear on the label. ________
>>
>>PRODUCT
>>
>>Loweís 40% Hog Concentrate - swine feed for mixing grower and finisher
>>rations, in 50-pound bulk bags. Recall #V-057-0. CODE All codes between
>>August 1, 1999 and November 23, 1999. MANUFACTURER Lowe's Feed & Grain,
>>Inc., Bowling Green, Kentucky. RECALLED BY Manufacturer, by letter dated
>>November 18, 1999, and by telephone. Firm-initiated recall complete.
>>
>>DISTRIBUTION
>>
>>Ohio.
>>
>>QUANTITY
>>
>>12.46 tons were distributed.
>>
>>REASON Product contained protein derived from mammalian tissue and
>>according to regulation must bear the statement "Do not feed to cattle
>>or other ruminants" on the label. This regulation is designed to prevent
>>the establishment and amplification of BSE through feed. This statement
>>does not appear on the label. ________
>>
>>RECALLS AND FIELD CORRECTIONS: VETMED -- CLASS II
>>
>>________________________________
>>
>>RECALL NUMBER, PRODUCT AND CODE: V-353-1 through V-370-1, Chicken feed
>>products: Recall # Tag # Product V-353-1 587 B. Challenger Scratch Feed
>>V-354-1 588 B. 18% Gamebird Conditioner V-355-1 2060 B. Kickin' Chicken
>>Premium Game Cock Feed V-356-1 2066 B. Kickin' Chicken Premium Gamebird
>>16% V-357-1 586 B. Scratch Grain V-358-1 2051 B. Pit Performer 17%
>>V-359-1 575 B. Classic Yard Feed V-360-1 576 Eliminator Maintainer
>>V-361-1 578 Eliminator Conditioner V-362-1 586 Producer Scratch Grain
>>V-363-1 4587 Producer 12% Gamebird Yard Feed V-364-1 2065 Cleveland
>>Trophy Cock Feed V-365-1 80181AAA Consolidated Hen Scratch V-366-1 2051
>>B&B Maintenance 12 V-367-1 2052 B&B Conditioner 14 V-368-1 2050 B&B
>>Scratch 10 V-369-1 4590 Kingsport Original Prater Mix V-370-1 2062 PC 10
>>(unlabeled bags) ALL CODES The "B" indicates that the Burkmann Feeds
>>brand name is listed on the tag labels. The suspect products are also
>>bagged and distributed under the following private labels:
>>
>>Producer Feeds, Louisville, Kentucky Kingsport Milling, Kingsport,
>>Tennessee Consolidated Nutrition, L.C., Omaha, Nebraska B&B Feeds,
>>Knoxville, Tennessee Eagle Roller Mill Co., Inc., Shelby, North Carolina
>>Central Farm Supply of Kentucky, Inc., Louisville, Kentucky
>>
>>REASON: The chicken feed products may contain proteins derived from
>>mammalian tissues. The products are not labeled with the required BSE
>>caution statement "Do Not Feed to Cattle or Other Ruminants."
>>
>>MANUFACTURER/RECALLING FIRM: Burkmann Feeds, London, Kentucky
>>
>>RECALLED BY: On May 5, 2001, the firm mailed recall letters with
>>attached BSE sticker-labels to all customers outside the state of
>>Kentucky. The recall notices were hand- delivered to customers within
>>the state of Kentucky by Burkmann's Sales Representatives. Customers
>>were asked to complete and return a recall response form that was
>>included with each letter documenting the numbers of bags and varieties
>>of products for which the customers affixed the BSE sticker-labels. The
>>firm expanded their recall on May 10, 2001, and mailed recall letters
>>with BSE labels and response forms to the affected customers. FIRM
>>INITIATED RECALL:
>>
>>Ongoing DISTRIBUTION: KY, GA, NC, TN, VA
>>
>>QUANTITY:
>>
>>933 tons _______________________________
>>
>>RECALL NUMBER, PRODUCT AND CODE: V-377-1, Renner's brand 45% meat and
>>bone meal, packed in 100 pound bags. REASON: The product contained
>>protein material derived from bovine mammalian tissues; however, the
>>bags are not labeled with the required BSE cautionary statement.
>>MANUFACTURER/RECALLING FIRM: F. W. Renner & Sons, Inc., Canton, Ohio
>>RECALLED BY: The recalling firm contacted the consignees by telephone on
>>June 19, 2001. FIRM INITIATED RECALL: Complete
>>
>>DISTRIBUTION: OH
>>
>>QUANTITY: 2,500 lbs _______________________________
>>
>>RECALL NUMBER, PRODUCT AND CODE: V-378-1 to V-384-1, RenPro 58% (brand
>>name) swine and poultry feeds in bulk, as follows: V-378-1 - Poultry
>>Layer #215 - guaranteed analysis 15% crude protein, 3% crude fat, and
>>3.5% crude fiber. V-379-1 - Poultry Layer #216 - guaranteed analysis 16%
>>crude protein, 3% crude fat, and 3.5% crude fiber. V-380-1 - Poultry
>>Layer #217 - guaranteed analysis 17% crude protein, 3% crude fat, and
>>3.5% crude fiber. V-381-1 - Poultry Layer #218 - guaranteed analysis 18%
>>crude protein, 3% crude fat, and 3.5% crude fiber. V-382-1 - Poultry
>>Layer #219 - guaranteed analysis 19% crude protein, 3.5% crude fat, and
>>4% crude fiber. V-383-1 - Poultry Prelay #115 - guaranteed analysis 16%
>>crude protein, 3% crude fat, and 5% crude fiber. V-384-1 - Poultry
>>Developer #110 - guaranteed analysis 14% crude protein, 3% crude fat,
>>and 5.5% crude fiber. MANFACTURER: Esbenshade Mills, Mount Joy, PA
>>RECALLED BY: On 5/24/01, the manufacturer notified their customers of
>>the labeling requirement via letter. FIRM INITIATED RECALL: Complete
>>
>>DISTRIBUTION: PA
>>
>>QUANTITY: None. The product turn over is two weeks or less.
>>
>>END OF ENFORCEMENT REPORT FOR July 25, 2001.
>>
>>http://www.fda.gov/
>>
>>on second thought, i now see why they are cutting back on these warning
>>letters of the infamous 8/4/97 ruminant-to-ruminant feed ban in the USA,
>>that never was. same reason they are not testing cows in sufficient
>>numbers to find any TSEs.
>>
>>they simply don't want to know, and don't want the public to know
>>either, thus keep the gold card 'BSE FREE'.
>>
>>one more time, to all EU/SEAC members please re-evaluate the current GBR
>>of the USA, and change from GBR II to GBR III. the complete GBR
>>assessment should be changed to include _all_ TSEs...
>>
>>P.S. i wonder how deer/elk feed would be listed on FDA site? odd with
>>all the products i sent through the list on deer/elk feed with _animal
>>protein_, i have not seen any warning letters on deer/elk feed. course,
>>it could be filed with the infamous and very handy 'non-species coding
>>system' that is used on imports (i documented here many times).
>>
>>still disgusted in Bacliff, Texas USA Terry S. Singeltary Sr.
>>
>>Terry S. Singeltary Sr. wrote:
>>
>>>######## Bovine Spongiform Encephalopathy
>>>#########
>>>
>>>Greetings and Happy Holidays,
>>>
>>>hi Linda,
>>>
>>>many thanks for this reply, was just checking in to see
>>>if anything new had happened since our last correspondence.
>>>i thought i had missed something?
>>>
>>> > Unfortunately, the new database is much more complicated than
>>>
>>> > the old one, and it does not lend itself to presenting data in
>>>
>>> > a simple spreadsheet as we did in the past.
>>>
>>>how convenient;-) i had no problems with the old one...
>>>
>>> > Please be assured that CVM is working to solve this problem,
>>>
>>> > and we do plan to post this data in the future.
>>>
>>>thank you, if USDA/APHIS are lucky, i will hold my breath until
>>>that time;-)
>>>
>>>nothing personal Linda, take care, and may the New Year bring
>>>
>>>PEACE...
>>>
>>>TSS
>>>
>>>CVM HomePage wrote:
>>>
>>>
>>>>Dear Mr. Singeltary:
>>>>
>>>>As mentioned in my e-mail of December 4, FDA's Center for Veterinary
>>>>Medicine never posted the Warning Letters for ruminant feed violations on
>>>>our "BSE" page -- http://www.fda.gov/cvm/index/bse/bsetoc.html. However,
>>>>these Warning Letters have been included on the FDA "Warning Letters"
>>>>page
>>>>-- http://www.fda.gov/foi/warning.htm that is located on the FDA's
>>>>"Electronic Freedom of Information Reading Room" page. But, not as a
>>>>separate category of Warning Letters for violations of the ruminant feed
>>>>rules.
>>>>
>>>>I checked the Warning Letter page, and found that quite a few Warning
>>>>Letters have been posted since May; however, I did not find any more
>>>>recent
>>>>than May 7, 2002, regarding "Animal Proteins Prohibited in Ruminant
>>>>Feed/Misbranded" (ruminant feed rule violations.) You may wish to
>>>>file a
>>>>Freedom of Information Act (FOIA) request to determine if more recent
>>>>Warning Letters have been issued, but not posted on the FDA Home Page.
>>>>Information about filing a FOIA request may be found at:
>>>>http://www.fda.gov/opacom/backgrounders/foiahand.html
>>>>
>>>>As mentioned on the "CVM and Ruminant Feed (BSE) Inspections" site --
>>>>
>>>>"After March 11, 2002, FDA discontinued the database that was used to
>>>>compile these listings. The Agency started a new database on April 15,
>>>>2002,
>>>>and future updates on BSE enforcement and inspectional findings will draw
>>>>from it. The format of the information presented here may change, due to
>>>>design changes of the new database. This site will be updated after a
>>>>period
>>>>of time that allows for transition into the new database system."
>>>>
>>>>Unfortunately, the new database is much more complicated than the old
>>>>one,
>>>>and it does not lend itself to presenting data in a simple spreadsheet
>>>>as we
>>>>did in the past. Please be assured that CVM is working to solve this
>>>>problem, and we do plan to post this data in the future.
>>>>
>>>>We have nothing new to report at this time.
>>>>
>>>>I hope that this information is helpful.
>>>>
>>>>Sincerely yours,
>>>>
>>>>Linda A. Grassie for the FDA Home Page
>>>>
>>>>
>>>>-----Original Message-----
>>>>From: Terry S. Singeltary Sr. [mailto:flounder@wt.net]
>>>>Sent: Saturday, December 21, 2002 4:03 PM
>>>>To: CVMHomeP@cvm.fda.gov
>>>>Subject: USA ruminant-to-ruminant feed ban warning letters ???
>>>>
>>>>
>>>>Greetings,
>>>>
>>>>i have noticed the inspections and warning letters
>>>>from firms not complying with the ruminant-to-ruminant
>>>>feed ban violations has not been updated since (March 11, 2002)?
>>>>
>>>>2) Firms Currently Considered as Not in Compliance with the BSE Feed
>>>>Rule
>>>>
>>>>The following spreadsheet is a subset of Spreadsheet 1 and contains the
>>>>name, address, and firm identifier of all firms that were considered as
>>>>not being in compliance with the BSE feed regulation at their most
>>>>recent inspection, according to the BSE inspection database. Compliance
>>>>status was determined by examination of the BSE Inspection Checklist.
>>>>The dates of the inspections and the specific BSE provision violations
>>>>for each inspection are also included. The listing is organized
>>>>alphabetically first by the FDA District and then by the state in which
>>>>the inspected facility is located.
>>>>
>>>>Most Recent BSE Inspections, Firms Not in Compliance
>>>>
>>>>http://www.fda.gov/cvm/efoi/InpectionListDescriptionforHP.htm
>>>>
>>>>i would be interested to know if all firms are now complying and that no
>>>>warning letters have been issued since may of 2002, or have they just not
>>>>been posted?
>>>>
>>>>if so, how can i locate them?
>>>>
>>>>thank you,
>>>>kind regards,
>>>>terry
=======================================================

TRIPLE FIRE WALLS OF WHAT ???

NOW about those triple fire walls and imports and what
about these potential biological 'TSE/FMD SUITCASE BOMBS'.
omitting the 44 tons of MBM/GREAVES we imported from the UK;

Subject:
Re: exports from the U.K. of it's MBM to U.S.???
From:
S.J.Pearsall@esg.maff.gsi.gov.uk
Date:
Tue, 8 Feb 2000 14:03:16 +0000
To:
flounder@wt.net (Receipt Notification Requested) (Non Receipt Notification Requested)

Terry

Meat and bonemeal is not specifically classified for overseas trade purposes. The nearest equivalent is listed as "flours and meals of meat or offals (including tankage), unfit for human consumption; greaves". UK exports of this to the US are listed below:

Country Tonnes
1980
1981 12
1982
1983
1984 10
1985 2
1986
1987
1988
1989 20
1990

Data for exports between 1975 and 1979 are not readily available. These can be obtained (at a charge) from data retailers appointed by HM Customs and Excise: BTSL (Tel: 01372 463121) or Abacus (01245 252222).

Best wishes
Simon Pearsall
Overseas trade statistics Stats (C&F)C

Simon
as discussed
thanks
Julie
---
Forwarded message:
Sent: Fri Feb 04 21:47:01 2000
Received: Fri Feb 04 21:45:15 2000
=========================================

or what about these potential BSE/TSE imports;

Bovine anmls bnlss ex prcssd frozen/U.S. Imports for Consumption 1997
year to date (custom value, in thousands of dollars)
(units of quantity: kilograms)

United Kingdom 37,122 kilograms, 43 thousand dollars
Netherlands 56,260 kilograms, 413 thousand dollars
Canada 18,141,481 kilograms, 23,914 million dollars

http://mad-cow.org/~tom/sept_mid_98_news.html#offals

and if there is BSE in sheep, here is UK sheep/goat export;

http://www.vegsource.com/articles/sheep_exports.htm

BSE/TSE MADCOW SUITCASE BOMBS

USCS=UNSPECIFIED SPECIES CODING SYSTEM=ANYTHING GOES
THE USA SEALED BORDERS ARE LEAKING, AND HAVE BEEN
FOR DECADES...TSS

Date: Thu, 21 Mar 2002 08:42:56 -0800
Reply-To: Bovine Spongiform Encephalopathy
Sender: Bovine Spongiform Encephalopathy
From: "Terry S. Singeltary Sr."
Subject: USA SEALED BORDERS AND THE ''USCS'' (unspecified species coding system) MORE POTENTIAL B.S.eee

Change in Disease Status of Greece With Regard to Foot-and-Mouth

[Federal Register: March 21, 2002 (Volume 67, Number 55)]

snip...

Under Sec. 94.11, meat and other animal products of ruminants and swine, including ship stores, airplane meals, and baggage containing these meat or animal products, may not be imported into the United States except in accordance with Sec. 94.11 and the applicable requirements of the U.S. Department of Agriculture's Food Safety and Inspection Service at 9 CFR chapter III.

snip...

From an economic standpoint, the proposed rule would have little or no impact on U.S. animal stock and commodities. There are two reasons. First, the proposed rule would not remove other disease-based restrictions on the importation of ruminants or swine (and certain meat and other products from those animals) from Greece into the United States. Because bovine spongiform encephalopathy is considered to exist in Greece, the importation of ruminants and meat, meat products, and certain other products of ruminants that have been in Greece is prohibited.

snip...

http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2002_register&docid=02-6837-filed

========================

What are the U.S. imports of affected animals or animal products from the country?

Very few products that would be of risk for transmission of BSE were imported into the US from Greece during 2000 or 2001 (January - April). Due to the above mentioned import ban, no live ruminants, ruminant meat, meal made from ruminants, or other high risk products from ruminants were imported from Greece during this time period. In 2001 (January - April), 3000 kg of enzymes and prepared enzymes and 5 kg of medicants containing antibiotics for veterinary use were imported. The data do not provide a species of origin code for these products, therefore they may not contain any ruminant product.

Sources: World Trade Atlas

What is the level of passenger traffic arriving in the United States from the affected country?

Approximately 185,000 direct flights from Greece arrived to US airports in fiscal year 2000. Also, an unknown number of passengers from Greece arrived via indirect flights.

Under APHIS-PPQ's agriculture quarantine inspection monitoring, 584 air passengers from Greece were sampled for items of agricultural interest in fiscal year 2000. Of these passengers, 14 carried meat (non-pork) items that could potentially transmit pathogens that cause BSE; most passengers carried from one to two kilograms (kg) of meat, although one passenger in November 1999 carried 23 kg of meat in a suitcase. Florida, Massachusetts, and New York were the reported destinations of these passengers. None of the passengers with meat items reported plans to visit or work on a ranch or farm while in the US.

Source: US Department of Transportation, and APHIS-PPQ Agricultural Quarantine Inspection data base

http://www.aphis.usda.gov/vs/ceah/cei/bse_greece0701.htm

Greetings list members,

i just cannot accept this;

> 23 kg of meat in a suitcase (suitcase bomb...TSS)

> The data do not provide a species of origin code for these > products, therefore they may not contain any ruminant product.

what kind of statement is this?

how stupid do they think we are?

it could also very well mean that _all_ of it was ruminant based products !

Terry S. Singeltary Sr., Bacliff, Texas USA

What is the level of passenger traffic arriving in the United States from Slovenia?

There were no direct flights from Slovenia to the US in fiscal year 2000.

APHIS-PPQ’s agriculture quarantine inspection monitoring sampled 27 air passengers from Slovenia for items of agricultural interest in fiscal year 2000. One of these 27 passengers was carrying two kilograms of a meat item that could potentially harbor pathogens that cause BSE. This passenger arrived to Elizabeth, New York, in June 2000 and declared no intention to visit a farm or ranch in the US.

Source: US Department of Transportation, and APHIS-PPQ Agricultural Quarantine Inspection data base

http://www.aphis.usda.gov/vs/ceah/cei/bse_slovenia1101.htm

What is the level of passenger traffic arriving in the United States from the affected country?

A total of 45,438 passengers arrived in the US on direct flights from the Czech Republic in fiscal year 2000. It is likely that additional passengers originating in the Czech Republic traveled to the US on non-direct flights.

As part of APHIS-PPQ’s Agriculture Quarantine Inspection Monitoring, 238 air passengers from the Czech Republic were inspected for items of agricultural interest in fiscal year 2000. Of these, 10, or 4.2%, were found to be carrying a total of 17 kg of items that could potentially present a risk for BSE. None of the passengers with items reported plans to visit or work on a farm or ranch while in the US.

Source: US Department of Transportation, and APHIS-PPQ Agricultural Quarantine Inspection data base

http://www.aphis.usda.gov/vs/ceah/cei/bse_cz0601.htm

What are the US imports of affected animals or animal products from Austria?

Between 1998 and June 2001, US imports from Austria included goat meat, animal feeds, and sausage. The sausage and animals feeds were from unspecified species.

Source: World Trade Atlas

snip...

What is the level of passenger traffic arriving in the United States from Austria?

A total of 168,598 passengers on direct flights from Austria arrived at US airports in fiscal year 2000. An undetermined number of passengers from Austria arrived in the US via indirect flights.

Under APHIS-PPQ’s agricultural quarantine inspection monitoring, 565 air passengers from Austria were sampled for items of agricultural interest in fiscal year 2000. Ten (10) of these passengers, or 1.7 percent, carried a total of 23 kg meat (non-pork) items that could potentially harbor the pathogen(s) that cause BSE. None of these passengers from whom meat items were confiscated reported plans to visit or work on a ranch or farm during their visit to the US.

Source: US Dept. of Transportation; APHIS-PPQ

http://www.aphis.usda.gov/vs/ceah/cei/bse_austria1201.htm

Greetings FDA and public,

if you go to the below site, and search all BSE known countries and check out their air traffic illegal meat they have confiscated, and check out the low number checked, compared to actual passenger traffic, would not take too much for some nut to bring in FMD/TSEs into the USA as a 'suitcase bomb'.

[[Under APHIS-PPQ's agricultural quarantine inspection monitoring, 284 air passengers from Israel were sampled for items of agricultural interest in fiscal year 2001. Seven of these passengers, or 2 percent, carried a total of 11 kg of meat items that could potentially harbor the pathogen that causes BSE. None of these passengers from whom meat items were confiscated reported plans to visit or work on a ranch or farm during their visit to the U.S.]]

if they were to have questioned the terrorist that bombed the Twin Towers with jets, if they were to have questioned them at flight school in the USA, i am sure that they would have said they did not intend to visit the Twin Towers as a flying bomb either. what am i thinking, they probably did ask this? stupid me.

[[In 1999 a small amount of non-species specific meat and offal was imported and a small amount of fetal bovine serum (FBS) was also imported. FBS is considered to have a relatively low risk of transmitting BSE.]]

more of the USA infamous 'non-species coding system', wonder how many of these species are capable of carrying a TSE?

snip...

A total of 524,401 passengers arrived on direct flights to the U.S. from Israel in fiscal year 2000. This number does not include passengers who arrived in the U.S. from Israel via indirect flights.

Under APHIS-PPQ's agricultural quarantine inspection monitoring, 284 air passengers from Israel were sampled for items of agricultural interest in fiscal year 2001. Seven of these passengers, or 2 percent, carried a total of 11 kg of meat items that could potentially harbor the pathogen that causes BSE. None of these passengers from whom meat items were confiscated reported plans to visit or work on a ranch or farm during their visit to the U.S.

http://www.aphis.usda.gov/vs/ceah/cei/bse_israel0602.htm

Source: U.S. Department of Transportation and APHIS-PPQ Agricultural Quarantine Inspection data base.

What is the level of passenger traffic arriving in the United States from Japan?

Approximately 6.84 million passengers on 29,826 direct flights from Japan arrived at US airports in fiscal year 2000. An undetermined number of passengers from Japan arrived in the US via indirect flights.

Under APHIS-PPQ's agriculture quarantine inspection monitoring, 801 air passengers from Japan were sampled for items of agricultural interest in fiscal year 2000. Of these 801 passengers, 10 carried meat (non-pork) items that could potentially harbor the pathogen(s) that cause BSE; most passengers carried an average of 1.7 kilograms of meat. None of these passengers from whom meat items were confiscated reported plans to visit or work on a ranch or farm during their visit to the US.

Source: US Department of Transportation, and APHIS-PPQ Agricultural Quarantine Inspection data base

http://www.aphis.usda.gov/vs/ceah/cei/bse_japan0901.htm

What is the level of passenger traffic arriving in the United States from the affected country?

A total of 3.3 million passengers arrived in the US on direct flights from Germany in 1998, although many of these passengers would not have originated in Germany. As part of APHIS-PPQ's Agriculture Quarantine Inspection Monitoring, 8,247 air passengers from Germany were inspected for items of agricultural interest. Of these, 198, or 2.3%, were found to be carrying a total of 304 kg of items that could potentially present a risk for BSE. Thirty (30) of the passengers with items reported plans to visit or work on a farm or ranch while in the US. Reported destination states of these 30 passengers were CA, CO, DE, FL, LA, MT, OH, VA, and WY.

Source: US Department of Transportation, and APHIS-PPQ Agricultural Quarantine Inspection data base

http://www.aphis.usda.gov/vs/ceah/cei/bse_germany1200e.htm

search archives at bottom of page of each BSE Country;

http://www.aphis.usda.gov/vs/ceah/cei/iw_archive.htm

kind regards, Terry S. Singeltary Sr., Bacliff, Texas USA

more on non-species coding system and TSEs and potential
'suitcase bombs'

http://www.vegsource.com/talk/madcow/messages/9911936.html

http://www.vegsource.com/talk/madcow/messages/9911943.html
==========================================================

ANOTHER COW GOES DOWN WITH CWD IN LAB STUDIES;

Subject: Re: CWD TO CATTLE by inoculation (ok, is it three or four???)
Date: Wed, 11 Dec 2002 23:20:41 +0000
From: Steve Dealler
Reply-To: Bovine Spongiform Encephalopathy
Organization: Netscape Online member
To: BSE-L
References:

Dear Dr Miller,
I have to admit it was difficult to me to believe either....but in the end I just had to realise that it
was true.
When I investigated the age at which cattle actually were becoming infected it was shocking to find that
the majority were infected under 1 month of age (and many of them seemed to be within the first week,
although the data on this was more shakey, and the rest seemed to be infected in a decreasing slope up to
the 7th month.
The question was: just how could the cattle be infected simply so young?
What also was turning out was that I could not find any obvious sign of multipoint inoculation and it was
as if either there was a major dose arriving at one point or not at all. Again the maths on that was
difficult but would probably stand up to the logic. These figures could only be certain in the period on
either of the feed ban in the UK in 1988: but then again there was no change in the age distrubution
after some other factors are removed since that point.

For a long time we had been wondering why, during the epidemic, the age distribution of cases did not
change greatly, when the actual amount of infectivity in the total diet of the battle population may have
gone up 10,000fold. Surely, if infection was taking place at many points in an animal's life then they
would have been becoming younger when dying of disease as the epidemic progressed?..but this was not
seen.

So...when you argue that a lamb is unlikely to have been infected naturally at a single point....I think
that this is almost certainly incorrect and that they are indeed infected when exceedingly young and
probably at a single point. Also I now believe that the amount of infectivity needed to infect these
animals is likely to be very low compared with adults when given orally. (this was all published in the
British Food Journal in 2001)
Steve Dealler

"Janice M. Miller" wrote:

> ######## Bovine Spongiform Encephalopathy #########
>
> I did not mean to imply that it wouldn't be possible for an animal to
> consume that amount of material, especially over a lifetime. I was
> merely pointing out that it is unlikely a lamb would be naturally
> exposed to that amount of material at a single time point early in its
> life and therefore such a short incubation period would not be expected
> to occur under non-experimental conditions.
>
> >>> flounder@WT.NET 12/09/02 12:35PM >>>
>
>
> hello Dr. Miller,
>
> i was curious about this statement;
>
> > It was not a true natural exposure, however, because they fed
>
> > the lambs 2-5 grams of infectious brain, which is very likely a
>
> > much larger dose than would occur under natural conditions.
>
> how do you come to the conclusion that 2-5 grams is a
> 'much larger dose than would occur under natural conditions',
> considering 1/2 to 1 gram is lethal for a cow ?
>
> "FDA has determined that each animal could have consumed, at most and
> in
> total, five-and-one-half grams - approximately a quarter ounce -- of
> prohibited material. These animals weigh approximately 600 pounds."
>
> http://www.fda.gov/bbs/topics/news/2001/new00752.html
>
> if we look at these studies, we will find that
> the 5.5 grams would be more than sufficient to
> infect a cow, if the feed was tainted with TSEs...TSS
>
> please read page 4, 5 and 6 of some 53;
>
> Scientific Steering Committee
> ORAL EXPOSURE OF HUMANS TO THE BSE AGENT:
> INFECTIVE DOSE AND SPECIES BARRIER
>
> http://europa.eu.int/comm/food/fs/sc/ssc/out79_en.pdf
>
> 9 DR. BROWN: If I am not mistaken, and I can be
> 10 corrected, I think a half a gram is enough in a cow, orally;
> 11 in other words, one good dietary-supplement pill.
>
> [FULL TEXT ABOUT 600 PAGES]
> 3681t2.rtf
> http://www.fda.gov/ohrms/dockets/ac/cber01.htm
>
> thank you,
>
> kind regards,
> terry
>
> Janice M. Miller wrote:
> >
> > With scrapie it's believed that most infections occur at or
> shortly
> > after birth, either from exposure to placenta from the lamb's own
> > infected dam or from another placent of another infected ewe that is
> > lambing at the same time. There are several experiments reported,
> > however, in which older sheep from scrapie-free flocks have been put
> in
> > contact with lambing ewes from scrapie flocks and transmission has
> > occurred. In these cases the incubation period appears to be
> longer.
> > Recently we heard in England that they have been able to reproduce
> > scrapie within 6 months (an incredibly short incubation period for
> that
> > disease) by oral exposure of 2-week old lambs. It was not a true
> > natural exposure, however, because they fed the lambs 2-5 grams of
> > infectious brain, which is very likely a much larger dose than would
> > occur under natural conditions. The effect of age on incubation
> period
> > may reflect the amount of lymphoid tissue available in the
> intestinal
> > tract of lambs because they experience a significant amount of
> atrophy
> > in that tissue diromg the first year of life. I don't remember
> anyone
> > suggesting that age plays a role in either the success of
> transmissions
> > or incubation periods when sheep are inoculated initracerebrally.
> That
> > seems to depend mostly on infectious titer of the inoculum and the
> > genetics of the recipient sheep.
> > In CWD no one has found any evidence that placenta is
> infectious
> > so the source of infectivity for transmission is unknown. In the
> highly
> > contaminated wildlife research facility at Colorado they lose over
> 90%
> > of their deer by about 2 years of age so it is likely that those
> animals
> > are infected at a very young age. In the wild, however, they are
> > reporting some positive animals that are much older so while there
> might
> > be some development of resistance with age, it certainly isn't
> complete.
> > I don't know that anyone has reported doing experiments where
> CWD-free
> > deer of different ages were put into a contaminated environment to
> see
> > if the transmission rates or incubation periods would be influenced
> by
> > age.
> >
> >
> >>>>taotm@EARTHLINK.NET 11/26/02 08:24AM >>>
> >>>
> >
> > Dr. Miller,
> >
> > About a year ago there was a report of from a Colorado DoW staffer
> who
> > recalled seeing scrapie sheep in
> > pens near the sickly-looking deer at the Ft. Collins research
> facility.
> > Although there's some debate about
> > whether those sheep actually had scrapie, given the results of the
> > intercerebral tests-- "... The other
> > sheep, necropsied 35 months after inoculation, showed clinical signs
> > and histopathologic lesions that were
> > indistinguishable from scrapie..."-- has there been any attempt to
> > recreate the alleged conditions at Ft.
> > Collins? In other words, an environmental test where scrapie sheep
> > would be put in close proximity to
> > healthy deer? Clearly there's a huge questions about the mechanics
> of
> > jumping the species barrier. But is
> > it possible that this was the way the CWD prion fire was initially
> lit?
> > Farmed sheep to wild cervids?
> >
> > Also, have there been any tests looking at the age at which an
> animal
> > becomes infected? Are younger,
> > smaller animals more at risk? Does the same dose of infectious
> material
> > as given an adult affect them
> > faster or more intensely?
> >
> > thank you,
> >
> > Janet Ginsburg
> >
> > "Terry S. Singeltary Sr." wrote:
> >
> >>hello Janice,
> >>
> >>many thanks for this update.
> >>
> >> > we do not know if the CWD agent in white-tailed deer
> >> > would be equivalent to that obtained from mule deer.
> >>
> >>i was just reading some data where it states;
> >>
> >>Although few white tailed deer were available for biopsy,
> >>findings were consistent with those in mule deer and
> >>support similarity in lymphoid accumulation of PrPCWD
> >>between the species that has been observed post-mortem.
> >>However, because PrPCWD does not appear to accumulate
> >>in lymphoid tissue to the same degree in elk as deer
> >>(T.R. Spraker, unpublished data)
> >>
> >>i am confused?
> >>
> >>thank you,
> >>kind regards,
> >>
> >>terry
> >>
> >>Janice M. Miller wrote:
> >>
> >
> >>> The statement that 4 cattle have developed evidence of CWD
> >>
> > transmission
> >
> >>>following intracerebral inoculation is correct because an
> >>
> > additional
> >
> >>>animal has been found prion positive subsequent to the 2001 paper
> >>
> > that
> >
> >>>presented preliminary findings after only 2 and a half years of
> >>>observation. Following this message is a summary of the current
> >>
> > status
> >
> >>>of our CWD cross-species transmission experiments in cattle and
> >>
> > sheep.
> >
> >>>This information was prepared in anticipation of questions about
> >>
> > these
> >
> >>>studies that we expected would be raised at the recent annual
> >>
> > meeting of
> >
> >>>the U.S. Animal Health Association.
> >>> I would like to correct one statement in the newspaper
> >>
> > article
> >
> >>>that was attributed to me that is in error. I did not imply that
> >>
> > our
> >
> >>>work thus far could be extrapolated to the situation with
> >>
> > white-tailed
> >
> >>>deer and dairy cattle. While there is no indication that there
> >>
> > should
> >
> >>>be any difference in susceptibility of beef versus dairy cattle, we
> >>
> > do
> >
> >>>not know if the CWD agent in white-tailed deer would be equivalent
> >>
> > to
> >
> >>>that obtained from mule deer. For that reason Dr. Hamir is now
> >>>repeating the original experiment in cattle with brain suspension
> >>
> > from
> >
> >>>affected white-tails as inoculum.
> >>>
> >>>Experimental Transmission of Chronic Wasting Disease (CWD) to
> >>
> > Cattle
> >
> >>>and Sheep
> >>>Progress report - October 15, 2002
> >>>
> >>>Transmission of CWD (mule deer) to cattle:
> >>>
> >>>Background:
> >>>In 1997, 13 calves were inoculated intracerebrally with brain
> >>>suspension from mule deer naturally affected with CWD. During the
> >>
> > first
> >
> >>>3 years, 3 animals were euthanized 23, 24, and 28 months after
> >>>inoculation because of weight loss (2) or sudden death (1).
> >>
> > Although
> >
> >>>microscopic examination of the brains did not show classical
> >>
> > lesions of
> >
> >>>transmissible spongiform encephalopathy (TSE), a specific TSE
> >>
> > marker
> >
> >>>protein, PrPres, was detected by immunohistochemistry (IHC) and
> >>
> > western
> >
> >>>blot . Detailed information on these animals has been published
> >>>previously (A Hamir et al., J Vet Diagn Invest 13: 91-96, 2001).
> >>>
> >>>Update:
> >>>During the 3rd and 4th years of observation, 5 additional animals
> >>
> > have
> >
> >>>been euthanized because of health concerns (primarily chronic joint
> >>
> > and
> >
> >>>foot problems). Although all tests for PrPres are not complete,
> >>
> > IHC
> >
> >>>results indicate that 1 of these animals, necropsied 59 months
> >>
> > after
> >
> >>>inoculation, was positive for PrPres. This animal (# 1746) had not
> >>
> > been
> >
> >>>eating well for approximately 1 week prior to being found
> >>
> > recumbent. At
> >
> >>>necropsy, significant gross lesions consisted of an oblique
> >>
> > fracture of
> >
> >>>L1 vertebral arch with extension into the body, and moderate
> >>
> > multifocal
> >
> >>>hemorrhagic ulceration in the abomasum. Microscopic examination
> >>
> > of
> >
> >>>brain revealed a few isolated neurons with single or multiple
> >>
> > vacuoles,
> >
> >>>but neither neuronal degeneration nor gliosis was observed. IHC
> >>>revealed the presence of PrPres in sections from several areas of
> >>
> > the
> >
> >>>brain.
> >>>
> >>>Summary of findings on this case and data from previous animals:
> >>>
> >>> Necropsy Survival Disease Clinical
> >>>Histo- IHC SAF WB
> >>> No. Route date period course signs
> >>
> > pathology
> >
> >>>________________________________________________________________
> >>>
> >>>1745 i/c 8/18/99 23m 2m +
> >>>+/- + - +
> >>>
> >>>1768 i/c 9/22/99 24m 3m +
> >>>+/- + + +
> >>>
> >>>1744 i/c 1/29/00 28m 3d ±
> >>>- + + +
> >>>
> >>>1749 i/c 5/20/01 44m NA -
> >>> - - NT NT
> >>>
> >>>1748 i/c 6/27/01 45m NA -
> >>>- - NT NT
> >>>
> >>>1743 i/c 8/21/02 59m NA -
> >>>- - Pending Pending
> >>>
> >>>1741 i/c 8/22/02 59m NA -
> >>>- - Pending Pending
> >>>
> >>>1746 i/c 8/27/02 59m 7d ±
> >>>+/- + Pending Pending
> >>>
> >>>NT = not tested; IHC = immunohistochemistry for PrPres; SAF =
> >>
> > scrapie
> >
> >>>associated fibrils; NA = not applicable; WB = Western blot
> >>>(Prionics-Check); + = lesions or antigen present; - = lesions or
> >>>antigen absent; ± = signs/lesions equivocal; i/c = intracerebral;
> >>
> > m =
> >
> >>>months; d = days.
> >>>
> >>>Summary:
> >>>After 5 years of observation we have 4 CWD transmissions to cattle
> >>
> > from
> >
> >>>a group of 13 inoculates. These animals, which were necropsied 23,
> >>
> > 24,
> >
> >>>28, and 59 months after inoculation, did not show the clinical
> >>
> > signs or
> >
> >>>histopathologic lesions typical of a TSE, but PrPres was detected
> >>
> > in
> >
> >>>brain samples. Four other animals that were necropsied during the
> >>
> > 4th
> >
> >>>and 5th years of observation have not shown evidence of prion
> >>
> > disease
> >
> >>>(although not all tests are complete) and the 5 remaining cattle
> >>
> > are
> >
> >>>apparently healthy. Note that this study involved direct
> >>
> > intracerebral
> >
> >>>inoculation of cattle with the CWD agent, which is an unnatural
> >>
> > route of
> >
> >>>exposure. It is likely that transmission by a more natural route,
> >>
> > such
> >
> >>>as oral exposure, would be much more difficult to accomplish.
> >>
> > Cattle
> >
> >>>have been inoculated orally at the University of Wyoming with the
> >>
> > same
> >
> >>>inoculum used for this experiment, and 5 years into the study
> >>
> > these
> >
> >>>animals remain healthy.
> >>>
> >>>
> >>>Experimental Transmission of CWD (mule deer) to sheep
> >>>
> >>>Eight Suffolk sheep from the NADC scrapie-free flock were
> >>
> > inoculated
> >
> >>>intracerebrally with the CWD brain suspension used to inoculate
> >>
> > cattle.
> >
> >>>PRNP genotyping showed that 4 of the sheep were QQ at codon 171 and
> >>
> > the
> >
> >>>other four were QR. Two of the QQ sheep were euthanized during the
> >>
> > 3rd
> >
> >>>year of observation. At necropsy one of these animals had a
> >>
> > urethral
> >
> >>>obstruction and PrPres was not detected in brain or lymphoid
> >>
> > tissues.
> >
> >>>The other sheep, necropsied 35 months after inoculation, showed
> >>
> > clinical
> >
> >>>signs and histopathologic lesions that were indistinguishable from
> >>>scrapie. IHC tests showed typical PrPres accumulations in brain,
> >>>tonsil, and some lymph nodes. The 2 remaining QQ sheep and all 4
> >>
> > QR
> >
> >>>sheep are apparently healthy 39 months after inoculation.
> >>>
> >>>Summary:
> >>>After 3 years of observation we have 1 transmission of CWD to a 171
> >>
> > QQ
> >
> >>>sheep. This animal, which was necropsied 35 months after
> >>
> > inoculation,
> >
> >>>showed clinical signs and histopathologic lesions that were
> >>>indistinguishable from scrapie. Another QQ sheep that was
> >>
> > necropsied
> >
> >>>during the 3rd year showed no evidence of prion disease and all
> >>>remaining sheep (2 QQ and 4 QR) are apparently healthy.
> >>>
> >>>
> >>>>>>flounder@WT.NET 11/23/02 06:54PM >>>
> >>>>>>
> >>>
> >>>1: J Vet Diagn Invest 2001 Jan;13(1):91-6
> >>>
> >>>Preliminary findings on the experimental transmission of chronic
> >>>wasting
> >>>disease agent of mule deer to cattle.
> >>>
> >>>Hamir AN, Cutlip RC, Miller JM, Williams ES, Stack MJ, Miller MW,
> >>>O'Rourke KI, Chaplin MJ.
> >>>
> >>>National Animal Disease Center, ARS, USDA, Ames, IA 50010, USA.
> >>>
> >>>To determine the transmissibility of chronic wasting disease (CWD)
> >>
> > to
> >
> >>>cattle and to provide information about clinical course, lesions,
> >>
> > and
> >
> >>>suitability of currently used diagnostic procedures for detection
> >>
> > of
> >
> >>>CWD
> >>>in cattle, 13 calves were inoculated intracerebrally with brain
> >>>suspension from mule deer naturally affected with CWD. Between 24
> >>
> > and
> >
> >>>27
> >>>months postinoculation, 3 animals became recumbent and were
> >>>euthanized.
> >>>Gross necropsies revealed emaciation in 2 animals and a large
> >>>pulmonary
> >>>abscess in the third. Brains were examined for protease-resistant
> >>>prion
> >>>protein (PrP(res)) by immunohistochemistry and Western blotting
> >>
> > and
> >
> >>>for
> >>>scrapie-associated fibrils (SAFs) by negative-stain electron
> >>>microscopy.
> >>>Microscopic lesions in the brain were subtle in 2 animals and
> >>
> > absent
> >
> >>>in
> >>>the third case. However, all 3 animals were positive for PrP(res)
> >>
> > by
> >
> >>>immunohistochemistry and Western blot, and SAFs were detected in 2
> >>
> > of
> >
> >>>the animals. An uninoculated control animal euthanized during the
> >>
> > same
> >
> >>>period did not have PrP(res) in its brain. These are preliminary
> >>>observations from a currently in-progress experiment. Three years
> >>>after
> >>>the CWD challenge, the 10 remaining inoculated cattle are alive
> >>
> > and
> >
> >>>apparently healthy. These preliminary findings demonstrate that
> >>>diagnostic techniques currently used for bovine spongiform
> >>>encephalopathy (BSE) surveillance would also detect CWD in cattle
> >>>should
> >>>it occur naturally.
> http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=PubMed&list_uids=11243374&dopt=Abstract
>
> >>>Sat, Nov 23, 2002
> >>>
> >>>Scientists unsure if CWD can jump species
> >>>
> >>>By Jessica Bock
> >>>Wausau Daily Herald
> >>>jbock@wdhprint.com
> >>>
> >>>snip...
> >>>
> >>>Janice Miller, a veterinarian in charge of the experiment, said
> >>
> > she
> >
> >>>believes previous research shows it is hard for the disease to be
> >>>transmitted naturally from whitetail deer to dairy cattle.
> >>>"Our study says nothing of how it could be transmitted in natural
> >>>surroundings," she said.
> >>>
> >>>Miller has been studying the transmission of CWD from mule deer to
> >>>cattle since 1997. Since then, chronic wasting disease was
> >>
> > transmitted
> >
> >>>to four out of 13 cattle injected with brain tissue from naturally
> >>>infected mule deer, she said.
> >>>
> >>>In Wyoming, Williams has been studying cattle that were given a
> >>>concoction of diseased brain tissue orally, and five years into
> >>
> > the
> >
> >>>study the animals remain healthy, Miller said.
> >>>No one knows if chronic wasting disease could ever spread to
> >>
> > another
> >
> >>>species through natural surroundings.
> >>>
> >>>"Our experience is that it's pretty hard to predict," Miller said.
> >>>
> >>>http://www.wausaudailyherald.com/wdhlocal/277564794712612.shtml
> >>>
> >>>greetings list,
> >>>
> >>> > Since then, chronic wasting disease was
> >>>
> >>> > transmitted to four out of 13 cattle
> >>>
> >>>is this a typo by the media or has another cow gone down
> >>>with CWD since the preliminary findings were found?
> >>>
> >>>TSS
=======================================================
scrapie in USA increasing;

Subject: SCRAPIE 'USA' ANNUAL REPORT (105 newly infected flocks 2002) & CWD IN USA
Date: Tue, 10 Dec 2002 08:17:17 -0600
From: "Terry S. Singeltary Sr."
To: flounder@wt.net

Date: Mon, 9 Dec 2002 21:21:10 -0600
Reply-To: Bovine Spongiform Encephalopathy
Sender: Bovine Spongiform Encephalopathy
From: "Terry S. Singeltary Sr."
Subject: SCRAPIE 'USA' ANNUAL REPORT (105 newly infected flocks 2002) &
CWD IN USA

As of September 30, 2002, there were 45 scrapie infected and source
flocks (figure 3). There were 105 newly infected flocks, reported in
FY2002 (figure 4). In addition, 379 scrapie cases were confirmed and
reported by the National Veterinary Services Laboratories (NVSL) in FY
2002 (figure 5) and (figure 6). Five cases of scrapie in goats were
reported in FY 2002 (figure 7), the last of which was confirmed in
August 2002. New infected and source flocks numbers and the number of
these flocks released in FY 2002 are depicted in chart 4. One hundred
(100) flocks which is 67 percent of the scrapie infected and source
flocks present in FY 2002 were released or put on clean-up plans in FY2002.

Slaughter Surveillance

Slaughter Surveillance is currently in Phase II which is intended to
determine the prevalence of scrapie in the US culled sheep population.
Through September 2002 samples from 3,269 sheep were submitted to NVSL
for testing. Samples from a total of 6,795 sheep have been submitted
since the beginning of Phase II on April 1, 2002. Surveillance regions
are depicted in (figure 8).

Scrapie Testing

During FY 2002 11,751 animals have been tested for scrapie which
includes: 2,711 regular necropsy cases, 1,343 third eyelid biopsies for
the test validation project, 546 third eyelid biopsies for the
regulatory program, and approximately 7,151 animals for Phase I & II of
SOSS (chart 5). Laboratory testing has been taking 10 - 11 days on
average with a range of 3 - 34 days.

Ear Tag Orders

During FY 2002 9.9 million plastic and 6.0 million metal tags were
distributed by APHIS (chart 6).

http://www.aphis.usda.gov/vs/nahps/scrapie/annual_report/annual-report.html

NEW SCRAPIE INFECTED AND SOURCE FLOCKS

http://www.aphis.usda.gov/vs/nahps/scrapie/annual_report/figure04.gif

DISTRIBUTION OF CHRONIC WASTING DISEASE THROUGHOUT THE STATES (as of
Oct. 2002)

http://www.aphis.usda.gov/vs/nahps/cwd/cwd-distribution.html

CWD USA surveillance

http://www.aphis.usda.gov/vs/nahps/cwd/cwd-state.html

http://www.testcowsnow.com

TSS

==================================================
we must _never_ forget the work of the late Dr. Richard Marsh;

ROUND TABLE ON BSE -- WASHINGTON -- 27-28 JUNE 1989

snip...

The summary does tend to give a particular slant to the epidemiology of
BSE which is not totally sound. It is a possibility that the agent of
BSE may be in the cattle population in a number of countries already
apart from the USA and that clinical cases are occurring on rare
occasions. It is also important to off the possibility of the
relationship between BSE and certain low-temperature rendering systems.
For that reason a number of other countries apart from the USA and
France are at risk and, in particular, the Netherlands, Denmark,
Germany and Belgium. For these reasons it would be wise to move to an
international ban on the feeding of ruminant protein to ruminants.

Clearly the summary also needs to refer to the incidence of BSE in the
UK and not solely to Great Britain. No doubt this has been tidied up
in your comments on the summary conclusions. It is a pity that more of
the comments put forward by Dr. Kimberlin have not been included in the
summary since his views on page 13 are succinct and valuable...

snip...

http://www.bseinquiry.gov.uk/files/yb/1989/08/29003001.pdf

Is there a Scrapie-like disease in cattle ?

IN CONFIDENCE

R.F. MARSH

snip...

re-mink rancher 'Wisconsin' dead stock feeder using >95%
downer or dead dairy and a few horses...

http://www.bseinquiry.gov.uk/files/yb/1987/06/10004001.pdf

Part of the Proceedings of an International Roundtable on Bovine
Spongiform Encephalopathy, Bethesda, Maryland, USA, June 27-28, 1989.

The possibility of infection with BSE in the United States, as defined
by studies on the disease in Great Britain, is judged to be low on the
basis of the following: (1) meat and bonemeals imported into the United
States from Great Britain between 1980 and 1988 were used mainly in
poultry, not ruminant feed; (2) the Scrapie Eradication Program had
reduced the prevalence of scrapie in the United States compared with
that in Great Britain; and (3) little, if any, rendered animal products
are used for protein supplements in cattle feed in the United States.
However, there is some evidence that there may already be a scrapie-like
disease in cattle in the United States. This evidence comes from
epidemiologic studies on an incident of transmissible mink
encephalopathy (TME) in Stetsonville, Wis, in 1985. This mink farmer
used no commercially available animal by-product mixtures in his feed,
but instead slaughtered all animals going into the mink diet, which
included mostly (>95%) "downer" dairy cows, a few horses, but never
sheep. To examine the possibility that cattle may have been the source
of this incident of TME, two 6-week-old Holstein bull calves were
inoculated intracerebrally with mink brain from the affected farm. The
bulls developed neurologic disease 18 and 19 months after inoculation.
Both brains had spongiform degeneration at necropsy and both were
transmissible back to mink by either intracerebral (incubation period of
4 months) or oral (incubation period of 7 months) inoculation
Whereas TME has been thought to be caused by feeding scrapie-infected
sheep to mink, this theory has no conclusive evidence. Experimental oral
inoculation of mink with several different sources of sheep scrapie has
never been successful, and an incubation period of less than 12 months
has never (sic) produced by intracerebral inoculation. Transmissible
mink encephalopathy can develop naturally by infection with incubation
periods of less than 12 months.
There is reason to believe that scrapie has not been transmitted in the
United States from sheep to cattle by rendered protein concentrates as
it was in Great Britain. However, some circumstantial evidence exists
that cattle may be a source of some TME infections. It is recommended
that we increase our surveillance for a BSE-like disease in American
cattle by encouraging state diagnostic laboratories to formalin-fix
specimens of midbrain and brain stem from bovine brains submitted for
rabies testing. If results of these tests are negative, these fixed
tissues can then be examined for evidence of spongiform degeneration of
the gray matter.

-Comments on bovine spongiform encephalopathy
J Am Vet Med Assoc 197 (4): (1990)

Letter to the Editor, Journal of the American Veterinary Medical
Association, August 15, 1990
In my article, "Bovine spongiform encephalopathy in the United States"
(JAVMA, May 15, 1990, p 1677), I stated that "little, if any, rendered
animal products are used for protein supplements in cattle feed in the
United States." I have since learned that this is incorrect, because of
the recent trend of using less assimilated "by-pass" proteins in cattle
feed. A large amount of meat-and-bone meal is being fed to American
cattle, and this change in feeding practice has greatly increased the
risk of bovine spongiform encephalopathy (BSE) developing in the United
States.
Epidemiologic studies on BSE in Great Britain have indicated that the
disease originated in cattle by exposure to the heat-resistant
transmissible agent in compounded feed containing rendered animal
protein. The most likely source of infection was assumed to be
meat-and-bone meal prepared from scrapie-infected sheep, but it is also
possible that a heretofore unrecognized scrapie-like infection of cattle
could have been spread in the same manner.
Because of concern for the possible development of BSE in the United
States, the American rendering industry discontinued the processing of
fallen and sick sheep last December. In my opinion, this was a prudent
policy, but one that will not prevent the possible transmission of BSE
from cattle to cattle. As emphasized in my article, there is some
evidence that BSE-like infection may already exist in American cattle.
The current practice of feeding meat-and-bone meal to cattle solidifies
the most important means to perpetuate and amplify the disease cycle.
In Great Britain, BSE has produced a great economic and emotional
burden. We must take all reasonable measures to prevent BSE from
developing in the United States. Therefore, the practice of using animal
protein in cattle feed should be discontinued as soon as possible.
Waiting until the first case of BSE is diagnosed in the United States
will certainly be "closing the barn door after the horse is gone." With
a disease having a 3- to 6-year incubation period, thousands of animals
would be exposed before we recognize the problem and, if that happens,
we would be in for a decade of turmoil.
R. F. Marsh, DVM, PhD
Madison, Wis

TSS

Terry S. Singeltary Sr.
P.O. Box 42
Bacliff, Texas USA 77518

CJD WATCH

http://www.fortunecity.com/healthclub/cpr/349/part1cjd.htm

'MOMS AUTOPSY REPORT'

http://www.vegsource.com/talk/lyman/messages/7548.html

http://www.vegsource.com/talk/madcow/index.html
===============================================

January 13, 2003
Dockets Management Branch
Food and Drug Administration
5630 Fishers Lane
Room 1061
Rockville, MD 20852
Re: Docket No. 02N-0273 – Substances Prohibited From Use In Animal Food Or Feed;
Animal Proteins Prohibited In Ruminant Feed; Advanced Notice Of Proposed
Rulemaking
Dear Sir/Madam:
The undersigned organizations representing a coalition of the nation’s animal producers, feed and ingredient manufacturers, meat processors and animal care providers offer these comments to the above-referenced notice. Our organizations have and continue to support the
current scientifically based animal feeding regulations that restrict the use of certain animal proteins derived from mammalian tissues for use in ruminant feed. A careful analysis of the facts suggests no regulatory changes are warranted at this time.
FDA in 1997 adopted the current feed restrictions based on sound science and review of industry practices. We believe the existing FDA animal feed regulations are appropriate given the low level of risk that BSE will occur in the U.S. Our goal is not to change the regulations,
but to achieve 100 percent compliance with the existing regulations. According to FDA, compliance with the BSE feed rule (21 C.F.R. § 589.2000) has been excellent. In fact, the coalition is unaware of any other FDA rule or program even approaching a near 100 percent
compliance rate.
BSE prevention in the U.S. involves multiple programs that can best be described as a "triple firewall" strategy. This includes: (1) a ban on the importation of ruminants and ruminant products from countries with BSE; (2) a statistically sound and comprehensive animal surveillance program to continually monitor for the presence of the disease; and (3) ruminant feeding restrictions to prevent the amplification and spread of the infective agent in the unlikely event BSE occurs in our domestic cattle. The current BSE feed rule, as part of this triple firewall
strategy, is more than adequate to meet the objectives stated in the preamble to the final rule.
In fact, several scientific studies have confirmed the fundamental soundness of the government’s approach and indicated our nation’s risk is extremely low. Neither current science nor the current excellent compliance rate supports an expansion of the rule at this time. The
coalition agrees the rule needs to be reviewed from time-to-time and applauds the agency’s efforts to do so by conducting a public hearing on October 30, 2001 and publishing its Advanced Notice of Proposed Rulemaking (ANPR) on November 6, 2002. An occasional review of the
rule will serve to strengthen it, if new risks are identified or new, relevant science is brought to light. However, no new risks or science support the proposed changes set forth in the ANPR. In
fact, as the Harvard BSE Risk Assessment indicated, if BSE were to occur in the United States, the disease would not be able to sustain itself because of the current measures in place. Not only would the proposed changes have no appreciable effect on the risk of BSE occurring or proliferating in the U.S., the proposed changes would likely take away valuable resources that are needed to ensure full compliance with the current rules in place.
Rigorous enforcement of the current feed rule will result in greater risk reduction than any or all of the proposed changes discussed in the ANPR. To that end, we urge the agency to continue to educate the regulated industries about the rule, continue active surveillance, assure compliance if violations are discovered, take vigorous enforcement actions against violators and continue the agency's cooperation and support of state inspection programs.
The coalition believes FDA has been diligent in carrying out its responsibilities to reduce, as much as possible, the risk of BSE being introduced and amplified in the U.S. Our risk of BSE in domestic cattle is not zero, nor can it ever be, but our risk today is the lowest it has ever been since the disease was first recognized as a threat to the U.S. cattle population. We pledge our continuing commitment to a goal of 100 percent compliance and assuring that federal and state agencies have the necessary resources to achieve that goal.
We thank the agency for the opportunity to submit these comments and for the agency’s consideration of them. Individual trade associations will offer additional comments on issues relevant to their members.
Sincerely,
American Farm Bureau Federation
American Feed Industry Association
American Meat Institute
American Sheep Industry Association
Fats and Proteins Research Foundation
National Cattlemen's Beef Association
National Chicken Council
National Grain and Feed Association
National Institute for Animal Agriculture
National Milk Producers Federation
National Meat Association
National Pork Producers Council
National Renderers Association
National Turkey Federation
Pet Food Institute

http://www.meatami.com/Template.cfm?Section=BSE&NavMenuID=188&template=TaggedContentFile.cfm&NewsID=625

Annex

Full SRM list

The following tissues are designated as specified risk material:

the skull including the brain and eyes, the tonsils, the vertebral column(3) excluding the vertebrae of the tail, the transverse processes of the lumbar and thoracic vertebrae and the wings of the sacrum, but including dorsal root ganglia and spinal cord of bovine animals aged over 12 months, and the intestines from the duodenum to the rectum and the mesentery of bovine animals of all ages;

the skull including the brain and eyes, the tonsils and the spinal cord of ovine and caprine animals aged over 12 months or which have a permanent incisor erupted through the gum, and the spleen of ovine and caprine animals of all ages.

In addition to the specified risk material listed in (a), the following tissues must be designated as specified risk material in the United Kingdom of Great Britain and Northern Ireland and in Portugal, with the exception of the Autonomous Region of the Azores: the entire head excluding the tongue, including the brain, eyes, trigeminal ganglia and tonsils; the thymus, the spleen and the spinal cord of bovine animals aged over 6 months.

(1) HYPERLINK "http://europa.eu.int/comm/food/fs/bse/bse36_en.pdf" http://europa.eu.int/comm/food/fs/bse/bse36_en.pdfupdates at: HYPERLINK "http://europa.eu.int/comm/food/fs/bse/legislation_en.html#general framework" http://europa.eu.int/comm/food/fs/bse/legislation_en.html#general%20framework

(2)see also: HYPERLINK "http://europa.eu.int/rapid/start/cgi/guestfr.ksh?p_action.gettxt=gt&doc=IP/02/1361|0|AGED&lg=EN&display=" IP/02/1361

(3)Sweden, the United Kingdom and Portugal may derogate from the compulsory removal of vertebral column under strict conditions.

TSS

Follow Ups:

• Mateusz Karczmarek by Mateusz Karczmarek on 12/05/06 (0)
• Leonid Britvin by Leonid Britvin on 12/04/06 (0)

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