US Violates Global Standards on Preventing Mad Cow Disease Part #2

[Guest guest]

US Violates Global Standards on Preventing Mad Cow Disease Part #2

 

http://www.organicconsumers.org/madcow/greger060603.cfm

 

Conclusion

 

Since 1996, the World Health Organization has recommended that all

countries stop feeding prion infected animals to other animals, yet

the U.S. government continues to allow deer infected with chronic

wasting disease to be rendered into animal feed,[274] and the

industry continues to oppose any proposed change in the law.[275]

 

Since 1996, the World Health Organization has recommended that all

countries test their downer cattle for mad cow disease, yet the U.S.

government continues to test but a tiny fraction of this high risk

population. The beef industry calls U.S. surveillance " aggressive "

and doesn't think more testing is necessary[276]. The world's

authority on these diseases just calls it " appalling. " [277]

 

Since 1996, the World Health Organization has recommended that all

countries remove beef products containing risky organs like spinal

cord from the human food supply. The U.S. government continues to

refuse to implement such a measure, and the industry continues to

oppose it, referring to such products as nothing but " wholesome. " [278]

 

Since 1996, the World Health Organization has recommended that all

countries stop feeding risky cattle organs like brains to all

livestock. The U.S. government is considering it. The American Meat

Institute, and 14 other industry groups remain vocally opposed.[279]

 

And, Since 1996, the World Health Organization has recommended that

all countries stop feeding any remains of cows to cows, yet the U.S.

government still allows dairy farmers to feed calves gallons worth of

cow blood and fat collected at the slaughterhouse.[280] Industry

representatives continue to actively support this practice.[281]

 

In 2002, the USDA requested feedback on a number of options for

further preventive measures, including a total ban on allowing the

brains and spinal cords from downer cattle in the human food

supply.[282] The spokesperson for the American Meat Institute

explained that the meatpacking industry would take a " significant

hit " financially if the USDA enacted such a proposal.[283]

 

The American Meat Institute explained that spinal cords pose no

health risk, " because the U.S. is BSE-free. " [284] Despite grossly

inadequate surveillance for the disease, when asked if we have BSE in

U.S. cattle, the American Meat Institute in 2002 emphatically

replied, " No, BSE is a foreign animal disease. " They stressed that,

" The fact that we share no physical borders with any affected nations

has been a key means of protecting our cattle. " [285]

 

Now that mad cow disease has been discovered in North America, the

USDA should immediately enact measures to prevent human exposure by

issuing an emergency interim rule to ban products that may contain

the agent that causes mad cow disease.[286] So far, though, according

to an agency spokesperson, the USDA isn't even discussing plans to

increase testing for the disease.[287]

 

Years ago, once mad cow disease started appearing up in Europe, David

Byrne, the European Commissioner for Health and Consumer Protection,

immediately called for a comprehensive Europe-wide surveillance

program to test every cow slaughtered for human consumption over a

certain age. Commenting on the program he said, " One of the major

lessons I have learned in dealing with BSE is that the political

establishment must be fully transparent with the public on the issue.

There must be no hidden agendas. No distortions. No false assurances.

Transparency, information and open dialogue must guide our

actions. " [288] The United States could learn from Europe's experience.

 

Michael Greger, MD, is a graduate of the Cornell University School of

Agriculture and the Tufts University School of Medicine. Dr. Greger

has been publicly speaking about mad cow disease since 1993. In

1997 he was invited as an expert witness to defend Oprah Winfrey

in the infamous meat defamation trial. He has contributed to many

books and articles on the subject and continues to lecture extensively.

Dr. Greger can be contacted at 857-928-2778, or mhg1

 

Any part of this report may be reproduced subject to acknowledgment.

 

Jonathan Simms is still fighting for his life.

" Johnny's Story, " a special BBC presentation, is online at:

<http://news.bbc.co.uk/media/video/39254000/rm/_39254221_johnnysstory_vi.ram

>.

 

May 31st was Jonathan's Birthday.

 

--

Michael Greger, M.D.

mhg1

857-928-2778

 

[1] National Cattlemen's Beef Association news release. 6 December 2000.

[2] USDA Release No. 0166.03 20 May 2003.

[3] USDA Release No. 0012.03 15 January 2003.

[4] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted

by Angie Coiro.

<http://www.kqed.org/programs/programarchive.jsp?progID=RD19 & ResultStart=1 & R

esultCount=10 & type=radio>.

[5] National Cattlemen's Beef Association. FMD and BSE: What Every

Producer Should Know. April 2001.

[6] World Health Organization Consultation on Public Health Issues

Related to Bovine Spongiform Encephalopathy and the Emergence of a

New Variant of Creutzfeldt-Jakob Disease. MMWR 45(14);295-6, 303. 12

April 1996.

[7] Ibid.

[8] Ibid.

[9] American Feed Industry Organization. Feedgram. 10 December 2002.

<http://www.afia.org/Feedgram_Articles/December_10__2002/Feed_Control.html>..

[10] <http://www.niaid.nih.gov/dir/labs/lpvd/race.htm>.

[11] R Race et al. Long-term subclinical carrier state precedes

scrapie replication and adaptation in a resistant species: analogies

to human BSE/vCJD. Journal of Virology 75(21):10073-89 (2001).

[12] National Institutes of Health. NIAID News Release " Study

Examines How Prion Disease Adapts to New Species. " 17 October 2001.

[13] " CWD carriers among us? " Rocky Mountain News (Denver, CO) August 8,

2002.

[14] Navy Environmental Health Center. Chronic Wasting Disease: An

Emerging Threat?

<http://www-nehc.med.navy.mil/nepmu2/Chronic%20Wasting%20Disease%20Draft.doc

>.

[15] American Veterinary Medical Association. What you should know

about chronic wasting disease. 23 October 2002.

<http://www.avma.org/communications/cwd/cwd_faq.asp>.

[16] European Molecular Biology Organization Journal. 19(2000):4425.

[17] " CWD carriers among us? " Rocky Mountain News (Denver, CO) August 8,

2002.

[18] Ibid.

[19] DEFRA. Transmissible Spongiform Encephalopathy Agents. 7 May

1998.

<http://www.archive.official-documents.co.uk/document/doh/spongifm/part-1.ht

m>.

[20] Center for Science in the Public Interest. Docket Number

98N-0359, CFSAN Program Priorities for FY2003. 20 August 2002.

<http://www.fda.gov/ohrms/dockets/dailys/

02/Aug02/082302/80022685.pdf>.

[21] Guidance for Industry: Use of Material from Deer and Elk in

Animal Feed. 14 May 2003.

<http://www.fda.gov/cvm/guidance/dguide158.pdf>.

[22] Federal Register on August 29, 1994, 59 FR 44591.

[23] Food and Drug Administration. Bovine Spongiform Encephalopathy.

9 January 2003. <http://www.fda.gov/cber/bse/bse.htm>.

[24] European Commission Health & Consumer Protectionate-General Scientific Steering Committee Opinion on Chronic

Wasting Disease and Tissues That Might Carry a Risk for Human and

Animal Feed Chains. 7 March 2003.

[25] World Health Organization Consultation on Public Health Issues

Related to Bovine Spongiform Encephalopathy and the Emergence of a

New Variant of Creutzfeldt-Jakob Disease. MMWR 45(14);295-6, 303. 12

April 1996.

[26] USDA Release No. 0012.03 15 January 2003.

[27] USDA. Bovine Spongiform Encephalopathy (BSE) Surveillance.

<http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>.

[28] Ibid.

[29] International Office of Epizooties. International Animal Health

Code. 2002. <http://www.oie.int/eng/normes/mcode/A_00154.htm>.

[30] Bovine Spongiform Encephalopathy (BSE) Surveillance

<http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>.

[31] USDA Release No. 0012.03 15 January 2003.

[32] USDA APHIS Backgrounder on USDA's BSE Surveillance July 2001.

[33] International Office of Epizooties. International Animal Health

Code. 2002. <http://www.oie.int/eng/normes/mcode/A_00154.htm>.

[34] Ibid.

[35] Ibid.

[36] Ibid.

[37] USDA Food Safety and Inspection Service. Current Thinking on

Measures that Could be Implemented to Minimize Human Exposure to

Materials that Could Potentially Contain the Bovine Spongiform

Encephalopathy Agent. 15 January 2002.

[38] Bovine Spongiform Encephalopathy (BSE) Surveillance.

<http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>.

[39] Prusiner's estimate of one million [Mad Cow Disease in Canada.

May 23, 2003 9:00am KQED Forum hosted by Angie Coiro.

<http://www.kqed.org/programs/programarchive.jsp?progID=RD19 & ResultStart=1 & R

esultCount=10 & type=radio>]

may be closer to the truth based on comprehensive European records

showing a downer rate of 1.92%,[Report on the monitoring and testing

of bovine animals for the presence of Bovine Spongiform

Encephalopathy (BSE) in 2001. June 2002.

<http://europa.eu.int/comm/food/fs/bse/testing/bse45_en.pdf>] which

would translate to about 864,000 downers in U.S. every year.

[40] Bovine Spongiform Encephalopathy: Implications for the United

States. United States Department of Agriculture. Animal and Plant

Health Inspection Service. Fort Collins: Centers for Epidemiology and

Animal Health, 1993.

[41] A Review of USDA Slaughterhouse Records for Downed Animals (U.S.

District 65 from January, 1999 to June, 2001) Farm Sanctuary, October

2001. <http://www.nodowners.org/downedanimals.pdf>.

[42] USDA Food Safety and Inspection Service. Current Thinking on

Measures that Could be Implemented to Minimize Human Exposure to

Materials that Could Potentially Contain the Bovine Spongiform

Encephalopathy Agent. 15 January 2002.

[43] Report on the monitoring and testing of bovine animals for the

presence of Bovine Spongiform Encephalopathy (BSE) in 2001. June

2002. <http://europa.eu.int/comm/food/fs/bse/testing/bse45_en.pdf>.

[44] A population of mink in Wisconsin that almost exclusively ate

downer cows was decimated by a transmissible milk encephalopathy. See

[Marsh RF, Bessen RA, Lehmann S, Hartsough GR. Epidemiological and

experimental studies on a new incident of transmissible mink

encephalopathy. Journal of General Virology 72(1991):589-594] for one

of the original papers describing this incident. For a full

discussion, read Mad Cow USA by Rampton and Stauber, available free

online at <http://www.prwatch.org/books/madcow.html>.

[45] International Office of Epizooties. International Animal Health

Code. 2002. <http://www.oie.int/eng/normes/mcode/A_00154.htm>.

[46] Even assuming 195,000 downers a year and that every single of

the tests in the surveillance program's history was performed on

downer cattle, (48,000 in 13 years)/(195,000 x 13 years) is less than

2%.

[47] General Accounting Office. GAO Report to Congressional

Requesters. January 2002 Mad Cow Disease: Improvements in the Animal

Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention

Efforts. GAO-02-183. <http://www.gao.gov/new.items/d02183.pdf>.

[48] USDA Food Safety and Inspection Service. Current Thinking on

Measures that Could be Implemented to Minimize Human Exposure to

Materials that Could Potentially Contain the Bovine Spongiform

Encephalopathy Agent. 15 January 2002.

[49] Food and Drug Administration 2000 CFR Title 21, Volume 6,

Chapter 1, Part 589.

<http://www.access.gpo.gov/nara/cfr/waisidx_00/21cfr589_00.html>.

[50] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted

by Angie Coiro.

<http://www.kqed.org/programs/programarchive.jsp?progID=RD19 & ResultStart=1 & R

esultCount=10 & type=radio>.

[51] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted

by Angie Coiro.

<http://www.kqed.org/programs/programarchive.jsp?progID=RD19 & ResultStart=1 & R

esultCount=10 & type=radio>.

[52] Older cattle are targeted in part, " because the diagnostic tests

for BSE that are available today are not likely to detect the BSE

agent in the brain tissue of cattle under 24 months of age even if

the animals were infected with BSE. " [uSDA Food Safety and Inspection

Service. Current Thinking on Measures that Could be Implemented to

Minimize Human Exposure to Materials that Could Potentially Contain

the Bovine Spongiform Encephalopathy Agent. 15 January 2002].

[53] European Commission press release IP/01/827.Brussels, 12 June 2001.

[54] USDA Food Safety and Inspection Service. Current Thinking on

Measures that Could be Implemented to Minimize Human Exposure to

Materials that Could Potentially Contain the Bovine Spongiform

Encephalopathy Agent. 15 January 2002.

[55] The U.S. adult cattle population is approximately 45 million

[bovine Spongiform Encephalopathy (BSE) Surveillance

<http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>]

compared to a 40.6 million adult cattle in Europe

[<http://europa.eu.int/comm/food/fs/bse/testing/bse_01-03_en.pdf>].

[56] <http://europa.eu.int/comm/food/fs/bse/testing/bse_01-03_en.pdf>.

[57] France tests 75,000 cattle a week

[<http://europa.eu.int/comm/food/fs/bse/testing/bse_01-03_en.pdf>]

compared to our 48,000 in the entire 13 year history of the U.S.

testing program [uSDA. Bovine Spongiform Encephalopathy (BSE)

Surveillance

<http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>].

[58] In 2001 (the latest annual report available), Europe tested

8,516,227 out of 40.4 million adult cattle

[<http://europa.eu.int/comm/food/fs/bse/testing/bse45_en.pdf>]. In

the same year the U.S. tested 4,870[General Accounting Office. GAO

Report to Congressional Requesters. January 2002 MAD COW DISEASE:

Improvements in the Animal Feed Ban and Other Regulatory Areas Would

Strengthen U.S. Prevention Efforts. GAO-02-183.

<http://www.gao.gov/new.items/d02183.pdf>] out of 45 million adult

cattle [bovine Spongiform Encephalopathy (BSE) Surveillance

<http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>] for

a rate 1,948 times greater.

[59] The Independent (London) 29 May 2003.

[60] European Commission Scientific Steering Committee. Outcome of

Discussions.

<http://europa.eu.int/comm/food/fs/sc/ssc/outcome_en.html>.

[61] European Commission Scientific Steering Committee. Report on the

Assessment of the Geographical BSE - Risk of Austria (July 2000).

<http://europa.eu.int/comm/food/fs/sc/ssc/out259_en.pdf>.

[62] European Commission Scientific Steering Committee. Report on the

Assessment of the Geographical BSE - Risk of USA (July 2000).

<http://europa.eu.int/comm/food/fs/sc/ssc/out137_en.pdf>.

[63] USDA. Bovine Spongiform Encephalopathy, Austria. USDA Impact

Worksheet, 18 December 2001.

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

[64] " Austria declared BSE free " CNN. 17 January 2001.

<http://edition.cnn.com/2001/WORLD/europe/01/17/madcow.austria/.

[65] USDA. Bovine Spongiform Encephalopathy, Austria. USDA Impact

Worksheet, 18 December 2001.

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

[66] " Critics say U.S. needs to do more to protect against mad cow. "

The Journal News (New York) 29 May 2003.

[67] Ibid.

[68] Ibid.

[69] The New York Times Magazine. 11 May 2003.

[70] " Critics say U.S. needs to do more to protect against mad cow. "

The Journal News (New York) 29 May 2003.

[71] Ibid.

[72] General Accounting Office. GAO Report to Congressional

Requesters. January 2002 Mad Cow Disease: Improvements in the Animal

Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention

Efforts. GAO-02-183. <http://www.gao.gov/new.items/d02183.pdf>.

[73] Walker, K.D., et al. " Comparison of Bovine Spongiform

Encephalopathy Risk Factors in the United States and Great Britain. "

Journal of the American Veterinary Medical Association 199 (1991):

1554-1561.

[74] Estimates range from 76%[uSDA: Animal Disposition Reporting

System. 1998] to between 81% and 83%[European Commission Report on

the assessment of the Geographical BSE-risk of the USA

<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000]

to 88%[bovine Spongiform Encephalopathy (BSE) Surveillance

<http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>].

[75] European Commission Report on the assessment of the Geographical

BSE-risk of the USA

<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.

[76] " Dangerous Food. " Oprah Winfrey Show. Harpo Productions. 16

April 1996. Burrelle's Information Services. Livingston, NJ.

[77] European Commission Report on the assessment of the Geographical

BSE-risk of the USA

<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.

[78] USDA Food Safety and Inspection Service. Current Thinking on

Measures that Could be Implemented to Minimize Human Exposure to

Materials that Could Potentially Contain the Bovine Spongiform

Encephalopathy Agent. 15 January 2002.

[79] USDA. Bovine Spongiform Encephalopathy, Austria. USDA Impact

Worksheet, 18 December 2001.

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

[80] " Austria declared BSE free. " CNN. 17 January 2001.

[81] European Commission Scientific Steering Committee. Report on the

Assessment of the Geographical BSE - Risk of Austria (July 2000).

[82] USDA. Bovine Spongiform Encephalopathy, Austria. USDA Impact

Worksheet, 18 December 2001.

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

[83] Public Citizen. Letter to the FDA and USDA RE: BSE April 12, 2001.

[84] European Commission Report on the assessment of the Geographical

BSE-risk of Canada. July 2000.

<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf>.

[85] " Mad-cow disease also probably present in US. " Agence

France-Presse (Paris) 29 May 2003.

[86] The Associated Press 21 May 2003.

[87] The New York Times 21 May 2003.

[88] Denver Post 26 May 2003.

[89] The Independent (London) 29 May 2003.

[90] " Mad-cow disease also probably present in US " Agence

France-Presse (Paris) 29 May 2003.

[91] " Critics say U.S. needs to do more to protect against mad cow. "

The Journal News (New York) 29 May 2003.

[92] World Health Organization Consultation on Public Health Issues

Related to Bovine Spongiform Encephalopathy and the Emergence of a

New Variant of Creutzfeldt-Jakob Disease. MMWR 45(14);295-6, 303. 12

April 1996.

[93] Regulation (EC)No 999/2001 of the European Parliament and of the

Council of 22 May 2001 laying down rules for the prevention, control

and eradication of certain transmissible spongiform encephalopathies.

[94] Harvard Center for Risk Analysis. Risk Analysis of Transmissible

Spongiform Encephalopathies in Cattle and the Potential for Entry of

the Etiologic Agent(s) Into the U.S. Food Supply . 2001.

<http://www.hcra.harvard.edu/pdf>/madcow_report.pdf>.

[95] Federal Register: April 13, 1998 (Volume 63, Number 70).

<http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/96-027P.htm>.

[96] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE

Headquarters, Paris, 11-14 June 2001.

[97] USDA. Focus On Hot Dogs. June 2002.

<http://www.fsis.usda.gov/OA/pubs/focushotdog.htm>.

[98] Center for Science in the Public Interest. Letter to the

Secretary of Agriculture. January 7, 1997.

<http://www.cspinet.org/reports/madcomnt.htm>.

[99] Federal Register: April 13, 1998 (Volume 63, Number 70).

<http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/96-027P.htm>.

[100] USDA. Focus On Hot Dogs. June 2002.

<http://www.fsis.usda.gov/OA/pubs/focushotdog.htm>.

[101] Center for Science in the Public Interest. Nutrition Health

Letter. June, 2001

[102] USDA. Focus On Hot Dogs. June 2002.

<http://www.fsis.usda.gov/OA/pubs/focushotdog.htm>.

[103] USDA. Focus On Hot Dogs. June 2002.

<http://www.fsis.usda.gov/OA/pubs/focushotdog.htm>.

[104] Center for Science in the Public Interest. Nutrition Health

Letter. June, 2001.

[105] Center for Science in the Public Interest. Letter to the

Secretary of Agriculture. January 7, 1997.

<http://www.cspinet.org/reports/madcomnt.htm>.

[106] Sparks Companies. Advanced Meat Recovery Systems -An Economic

Analysis of Proposed USDA Regulations. July 1999.

[107] Center for Science in the Public Interest. Nutrition Health

Letter. June, 2001.

[108] American Meat Institute Fact Sheet. Meat Derived by Advanced

Meat Recovery. October 2002.

www.amif.org/FactSheetAdvancedMeatRecovery.pdf>.

[109] USDA. Analysis of 2002 FSIS Bovine AMR Products Survey Results.

February 2003. <http://www.fsis.usda.gov/OA/topics/AMRAnalysis.pdf>.

[110] Government Actions to Prevent Bovine Spongiform Encephalopathy

in the United States. November 2001.

[111] Federal Register: April 13, 1998 (Volume 63, Number 70)

<http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/96-027P.htm>.

[112] USDA Meat and Poultry Labeling Terms. January 2001.

<http://www.fsis.usda.gov/OA/pubs/lablterm.htm>.

[113] Sparks Companies. Advanced Meat Recovery Systems--An Economic

Analysis of Proposed USDA Regulations. July 1999.

[114] Ibid.

[115] American Meat Institute Fact Sheet. Meat Derived by Advanced

Meat Recovery. October 2002.

[116] Sparks Companies. Advanced Meat Recovery Systems--An Economic

Analysis of Proposed USDA Regulations. July 1999.

[117] B.P. Demos and R.W. Mandigo, " Chemistry and Composition of

Mechanically Recovered Beef Neck Bone Lean, " Journal Series, Nebraska

Agricultural Research Division, Paper No. 10997, p. 64-65.

[118] Center for Science in the Public Interest. Nutrition Health

Letter. June, 2001

[119] Testimony of Peter Lurie, MD, MPH Deputy Director Public

Citizen's Health Research Group Before the Consumer Affairs, Foreign

Commerce and Tourism Subcommittee Senate Commerce, Science and

Transportation Committee. 4 April 2001.

[120] Ibid.

[121] Testimony of Caroline Smith DeWaal Director of Food Safety

before the Senate Committee on Commerce, Science and Transportation

Hearing on " Mad Cow Disease: Are Our Precautions Adequate? " 4 April

2001. Washington, D.C.

[122] National Cattlemen's Beef Association. Presence of Central

Nervous System (CNS) Tissue In Advanced Meat Recovery (AMR) Products.

April 2001.

[123] Ibid.

[124] USDA. Revised Directive for Advanced Meat Recovery Systems.

December 2002. <http://www.fsis.usda.gov/OA/background/amrdirec.htm>.

[125] USDA. Analysis of 2002 FSIS Bovine AMR Products Survey Results.

February 2003. <http://www.fsis.usda.gov/OA/topics/AMRAnalysis.pdf>.

[126] Ibid.

[127] Inter-American institute of Cooperation for Agriculture.

Argentine Scientific Advisory Committee On BSE Following A Meeting On

Transmissible Spongiform Encephalopathies. Review of the current

status of the obscure points in TSE by Ray Bradley. 9 August 1999.

[128] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE

Headquarters, Paris, 11-14 June 2001.

[129] Center for Science in the Public Interest. Nutrition Health

Letter. June, 2001.

[130] August 10, 2001 Center for Science in the Public Interest News

Release.

[131] Ibid.

[132] " FDA changes in feed restriction won't reduce BSE risk,

industry groups say by Dan Murphy on 1/15/03 for www.meatingplace.com.

[133] Ibid.

[134] Ibid.

[135] Ibid.

[136] Sun Herald 7 August 2001.

[137] Sparks Companies. Advanced Meat Recovery Systems -An Economic

Analysis of Proposed USDA Regulations. July 1999.

[138] Ibid.

[139] European Commission press release ip/00/423 .Brussels, 3 May 2000.

[140] " FDA changes in feed restriction won't reduce BSE risk,

industry groups say by Dan Murphy on 1/15/03 for www.meatingplace.com.

[141] Center for Science in the Public Interest. Letter to the

Secretary of Agriculture. January 7, 1997.

<http://www.cspinet.org/reports/madcomnt.htm>.

[142] Testimony of Caroline Smith DeWaal Director of Food Safety

before the Senate Committee on Commerce, Science and Transportation

Hearing on " Mad Cow Disease: Are Our Precautions Adequate? " 4 April

2001. Washington, D.C. and USDA. Analysis of 2002 FSIS Bovine AMR

Products Survey Results. February 2003.

<http://www.fsis.usda.gov/OA/topics/AMRAnalysis.pdf> as above.

[143] Center for Science in the Public Interest. Letter to the

Secretary of Agriculture. January 7, 1997.

<http://www.cspinet.org/reports/madcomnt.htm>.

[144] August 10, 2001 Center for Science in the Public Interest News

Release.

[145] Ibid.

[146] August 10, 2001 Center for Science in the Public Interest News

Release.

[147] Public Citizen. Letter to the FDA and USDA RE: BSE April 12, 2001.

[148] Federal Register: April 13, 1998 (Volume 63, Number 70).

<http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/96-027P.htm>.

[149] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE

Headquarters, Paris, 11-14 June 2001.

[150] Center for Science in the Public Interest. Nutrition Health

Letter. June, 2001.

[151] Ibid.

[152] Ibid.

[153] Harvard Center for Risk Analysis. Risk Analysis of

Transmissible Spongiform Encephalopathies in Cattle and the Potential

for Entry of the Etiologic Agent(s) Into the U.S. Food Supply . 2001.

<http://www.hcra.harvard.edu/pdf>/madcow_report.pdf>.

[154] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE

Headquarters, Paris, 11-14 June 2001.

[155] USDA Food Safety and Inspection Service. Current Thinking on

Measures that Could be Implemented to Minimize Human Exposure to

Materials that Could Potentially Contain the Bovine Spongiform

Encephalopathy Agent. 15 January 2002.

[156] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE

Headquarters, Paris, 11-14 June 2001.

[157] Reuters 29 August 19996.

[158] Reuters 29 August 1996.

[159] Lancet Vol 348 August 31, 1996.

[160] Ibid.

[161] Lancet Vol 348 August 31, 1996.

[162] European Commission Health & Consumer Protectionate-General Scientific Opinion on Stunning Methods and BSE

Risks. January 2002.

[163] Transfusion, Vol. 41, No. 11, 1325, November 2001.

[164] European Commission Health & Consumer Protectionate-General Scientific Opinion on Stunning Methods and BSE

Risks. January 2002.

[165] Transfusion, Vol. 41, No. 11, 1325, November 2001.

[166] Testimony of Peter Lurie, MD, MPH Deputy Director Public

Citizen's Health Research Group Before the Consumer Affairs, Foreign

Commerce and Tourism Subcommittee Senate Commerce, Science and

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[167] Regulation (EC)No 999/2001 of the European Parliament and of

the Council. Laying down rules for the prevention, control and

eradication of certain transmissible spongiform encephalopathies. 22

May 2001.

[168] European Commission Health & Consumer Protectionate-General Scientific Opinion on Stunning Methods and BSE

Risks. January 2002.

[169] European Commission Scientific Report on Stunning Methods And

BSE Risks (The Risk of Dissemination of Brain Particles Into the

Blood And Carcass When Applying Certain Stunning Methods. December

2001).

[170] Berliner und Münchener Tierärztliche Wochenschrift 2002

Jan-Feb; 115(1-2): 1-5.

[171] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE

Headquarters, Paris, 11-14 June 2001.

[172] European Commission Health & Consumer Protectionate-General. Scientific Steering Committee Opinion on the

Safety of Ruminant Blood with Respect to Risks. 14 April 2000.

[173] European Commission Scientific Report On Stunning Methods and

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2001).

[174] Applied and Environmental Microbiology. 2002 Feb; 68(2): 791-8.

[175] Letters to the Editor. The Lancet Vol 348 September 14, 1996.

[176] European Commission Health & Consumer Protectionate-General. Scientific Steering Committee Opinion on the

Safety of Ruminant Blood with Respect to Risks. 14 April 2000.

[177] Letters to the Editor. The Lancet Vol 348 September 14, 1996.

[178] National Cattlemen's Beef Association news release. 21 May

2003.

<http://www.beef.org/dsp/dsp_content.cfm?locationId=45 & contentTypeId=2 & conte

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[179] Proceedings of the National Academy of Sciences. 2002 Mar

19;99(6):3812-7.

[180] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum

hosted by Angie Coiro.

<http://www.kqed.org/programs/programarchive.jsp?progID=RD19 & ResultStart=1 & R

esultCount=10 & type=radio>.

[181] European Molecular Biology Organization Reports 4, 5 (2003), 530.

[182] AMI Fact Sheet Bovine Spongiform Encephalopathy. November 2002.

[183] E. A. Asante et al. European Molecular Biology Oorganization

Joutnal. 21, 6358-6366; 2002.

[184] " Prion data suggest BSE link to sporadic CJD. " Nature 420, 450 (2002)..

[185] World Health Organization. Variant Creutzfeldt-Jakob Disease.

Fact sheet No. 180. Revised November 2002.

[186] Mahendra, B. Dementia Lancaster: MTP Press Limited, 1987: 174.

[187] Wade, J. P. H., et al. " The Clinical Diagnosis of Alzheimer's

Disease. " Archives of Neurology 44 (1987): 24-29.

[188] Boller, F., O. L. Lopez, and J. Moossy. " Diagnosis of

Dementia. " Neurology 38 (1989): 76-79.

[189] Manuelidis, Elias E. and Laura Manuelidis. " Suggested Links

between Different Types of Dementias: Creutzfeldt-Jakob Disease,

Alzheimer Disease, and Retroviral CNS Infections. " Alzheimer Disease

and Associated Disorders 2 (1989): 100-109.

[190] Teixeira, F., et al. " Clinico-Pathological Correlation in

Dementias. " _Journal of Psychiatry and Neuroscience 20 (1995):

276-282.

[191] Centers for Disease Control. Deaths/Mortality.

<http://www.cdc.gov/nchs/fastats/deaths.htm>.

[192] Alzheimer's Association. Statistics about Alzheimer's Disease.

1 February 2003. <http://www.alz.org/AboutAD/Statistics.htm>.

[193] National Cattlemen's Beef Association. BSE Questions and

Answers. June 2003.

<http://www.bseinfo.org/dsp/dsp_locationContent.cfm?locationId=1267>.

[194] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE

Headquarters, Paris, 11-14 June 2001.

[195] European Commission memo/03/94. Brussels, 30 April 2003.

[196] National Renderers Association. North American Rendering: A

Source Of Essential, High-Quality Products.

[197] Canadian Food Inspection Agency, Regulations: Food for

Ruminants, Livestock and Poultry (Part XIV), " Prohibited Materials " .

[198] Food and Drug Administration 2000 CFR Title 21, Volume 6,

Chapter 1, Part 589.

<http://www.access.gpo.gov/nara/cfr/waisidx_00/21cfr589_00.html>.

[199] Dan Murphy. American Meat Institute Spokesperson. Quoted in The

Journal News (New York) 29 May 2003.

[200] Docket No. 01-068-1] RIN 0579-AB43. Federal Register (Volume

68(2003):2704-2711.

[201] European Commission Report on the assessment of the

Geographical BSE-risk of Canada

<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.

[202] European Commission Report on the assessment of the

Geographical BSE-risk of the USA

<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.

[203] European Commission Report on the assessment of the

Geographical BSE-risk of Canada

<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.

[204] European Commission Report on the assessment of the

Geographical BSE-risk of the USA

<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.

[205] European Commission Report on the assessment of the

Geographical BSE-risk of Canada

<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.

[206] European Commission Report on the assessment of the

Geographical BSE-risk of the USA

<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.

[207] And the FDA numbers [FDA Center for Veterinary Medicine News

Release 10 January 2001] are underestimates [General Accounting

Office. GAO Report to Congressional Requesters. January 2002 Mad Cow

Disease: Improvements in the Animal Feed Ban and Other Regulatory

Areas Would Strengthen U.S. Prevention Efforts. GAO-02-183.

<http://www.gao.gov/new.items/d02183.pdf>].

[208] USDA Food Safety and Inspection Service. Current Thinking on

Measures that Could be Implemented to Minimize Human Exposure to

Materials that Could Potentially Contain the Bovine Spongiform

Encephalopathy Agent. 15 January 2002.

[209] Kirchheimer, Gabe. Bovine Bioterrorism: The Perfect Pathogen.

In Everything You Know Is Wrong. The Disinformation Company. 2002.

[210] U.K. Bans Use of Meat and Bone Meal in Fertilizer. " Reuters

Financial Report 19 April 1996.

[211] FDA Warning Letter. 6 May 2003.

<http://www.fda.gov/foi/warning_letters/g4000d.htm>.

[212] " Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum

hosted by Angie Coiro.

<http://www.kqed.org/programs/programarchive.jsp?progID=RD19 & ResultStart=1 & R

esultCount=10 & type=radio>.

[213] Public Citizen. Letter to the FDA and USDA RE: BSE. 21 April

2001.

<http://www.citizen.org/cmep/foodsafety/gsfc/articles.cfm?ID=1562>.

[214] Food and Drug Administration Sec. 685.100 Recycled Animal Waste

(CPG 7126.34).

[215] Mississippi State University Cooperative Extension Service.

Broiler Litter as a Feed or Fertilizer in Livestock Operations. 1998.

[216] US News & World Report Sept. 1, 1997.

[217] Utilization Of Poultry Litter as Feed for Beef Cattle.

<http://www.fda.gov/ohrms/dockets/dailys/01/Nov01/110501/ts00014.doc>.

[218] Fontenot, J. P. Recycling animal wastes by feeding to enhance

environmental quality. 1991. The Professional Animal Scientist 7:l.

[219] Joseph P. Fontenot. Department of Animal And Poultry Sciences.

Virginia Polytechnic Institute. Feeding Poultry Wastes To Cattle. 18

September 1996.

[220] Mississippi State University Extension Service. Poultry

Nutrient Management Through Livestock Feedstuffs. 2000.

[221] Joseph P. Fontenot. Department of Animal And Poultry Sciences.

Virginia Polytechnic Institute. Feeding Poultry Wastes To Cattle. 18

September 1996.

[222] Fontenot, J. P., K. E. Webb, Jr., B. W. Harmon, R. E. Tucker,

and W. E. C. Moore. 1971. Studies of processing, nutritional value

and palatability of broiler litter for ruminants. Proc. Int. Symp on

Livestock Wastes, ASAE, St. Joseph, MI, p. 301.

[223] University of Florida Cooperative Extension. Broiler Litter,

Part 2: Feeding to ruminants. August 1997.

[224] Joseph P. Fontenot. Department of Animal And Poultry Sciences.

Virginia Polytechnic Institute. Feeding Poultry Wastes To Cattle. 18

September 1996.

[225] FDA. Guidance For Industry.Questions And Answers. BSE Feed

Regulation 21 Code of Federal Regulations (CFR) 589.2000.

[226] Mississippi State University Cooperative Extension Service.

Broiler Litter as a Feed or Fertilizer in Livestock Operations. 199.

[227] Feeding Poultry Litter to Beef Cattle. Agricultural publication

G2077 - New February 15, 2001.

[228] Ibid.

[229] Mississippi State University Cooperative Extension Service.

Broiler Litter as a Feed or Fertilizer in Livestock Operations. 1998.

[230] Alabama Cooperative Extension Service. US Policy Of Feeding

'Broiler Litter' (Chicken Sh**) To Beef Cattle 19 February 2001.

[231] Becky Mills. Alabama Cries 'Foul.' Beef, Jan 1, 1998.

[232] Beef magazine. More on poultry litter. 1 March 1998.

[233] Becky Mills. Alabama Cries 'Foul.' Beef, Jan 1, 1998.

[234] Joseph P. Fontenot. Utilization of Poultry Litter as Feed for

Beef Cattle. Presented at FDA Public Hearing, Kansas City, MO,

October 30, 2001, on animal feeding regulation " Animal Proteins

Prohibited in Ruminant Feed " --Code of Federal Regulations, Title 21,

Part 589.2000.

[235] Alabama Cooperative Extension Service. US Policy Of Feeding

'Broiler Litter' (Chicken Sh**) To Beef Cattle 19 February 2001.

[236] Hot Spring Spa of North County. Frequently Asked Questions.

<http://www.spasandtubs.com/Finnleo/mostfrequentsauna_qa.html>.

[237] Brown, Paul, et al. " Resistance of Scrapie Infectivity to Steam

Autoclaving after Formaldehyde Fixation and Limited Survival after

Ashing at 360oC. " Journal of Infectious Diseases 161 (1990): 467-472.

[238] Bentor, Yinon. Chemical Element.com - Lead. Jun. 3, 2003.

<http://www.chemicalelements.com/elements/pb.html>.

[239] 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. Petition

Re: Docket No. 02N-0273. 13 January 2003.

[240] Becky Mills. Alabama Cries 'Foul.' Beef, Jan 1, 1998.

[241] FDA, Center for Veterinary Medicine, Office of Management and

Communications. Update On Ruminant Feed (BSE) Enforcement Activities.

January 10, 2001.

[242] Evans, Eddie. " Agency to Ban Some Feeds to Block Mad-Cow

Disease. " Reuters World Report 13 May 1996.

[243] " AVMA Casts Doubt on Spread of BSE Through Sheep Offal. " Food

Chemical News 28 November 1994: 42-45.

[244] European Commission Report on the assessment of the

Geographical BSE-risk of the USA

<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.

[245] " BSE/Scrapie Group Share Research, Debate Feed Bans. " Food

Chemical News 5 July 1993: 57-59.

[246] " Dangerous Food. " Oprah Winfrey Show. Harpo Productions. 16

April 1996. Burrelle's Information Services. Livingston, NJ.

[247] World Health Organization Consultation on Public Health Issues

Related to Bovine Spongiform Encephalopathy and the Emergence of a

New Variant of Creutzfeldt-Jakob Disease. MMWR 45(14);295-6, 303. 12

April 1996.

[248] USDA Release No. 0012.03 15 January 2003.

[249] USDA Dairy Herd Management Practices Focusing on Preweaned

Heifers N129.0793. July 1993.

<http://cofcs66.aphis.usda.gov/vs/ceah/cahm/Dairy_Cattle/ndhep/dr91des1.pdf>

...

[250] Ibid and Cornell Animal Science Department. A Guide To Calf

Milk Replacers: Types Use and Quality.

<http://www.ansci.cornell.edu/cgi-bin/db2www/

getdoc.d2w/query?doc=72>.

[251] Spongiform Encephalopathy Advisory Committee Draft Minutes of

the 74th meeting held on 13th June 2002 at DEFRA.

[252] Ibid.

[253] Japan Today 24 August 2002.

[254] USDA Dairy Herd Management Practices Focusing on Preweaned

Heifers N129.0793. July 1993.

<http://cofcs66.aphis.usda.gov/vs/ceah/cahm/Dairy_Cattle/ndhep/dr91des1.pdf>

...

[255] Dr. Jim Quigley. " Red blood cell protein in calf milk

replacers. " <http://www.calfnotes.com/pdf>files/CN049.pdf> .

[256] Dr. Jim Quigley. " Red blood cell protein in calf milk

replacers. " <http://www.calfnotes.com/pdf>files/CN049.pdf> .

[257] Ibid.

[258] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum

hosted by Angie Coiro.

<http://www.kqed.org/programs/programarchive.jsp?progID=RD19 & ResultStart=1 & R

esultCount=10 & type=radio>.

[259] Paul Brown. Summary of Research Findings on TSE Infectivity in

Blood. Annex 1. European Commission Health & Consumer Protectionate-General Scientific Steering Committee Opinion on the

Implications of the Recent Papers an Transmission of BSE by Blood. 13

September 2002.

<http://europa.eu.int/comm/food/fs/bse/scientific_advice08_en.html>.

[260] Hunter,N., Foster, J., Chong,A., McCutcheon, S., Parnham, D.,

Eaton, S., MacKenzie, C., and Houston, F., 2002. Transmission of

prion diseases by blood transfusion. Journal of General Virology

(2002), 83: Published ahead of print (16 July 2002).

[261] European Commission Scientific Report on Stunning Methods and

BSE Risks (The Risk of Dissemination of Brain Particles into the

Blood and Carcass when Applying Certain Stunning Methods. December

2001).

[262] European Commission Health & Consumer Protection Directorate-

General Scientific Steering Committee Opinion an the Implications af

the Recent Papers on Transmission of BSE by Blood. 13 September 2002.

<http://europa.eu.int/comm/food/fs/bse/scientific_advice08_en.html>.

[263] European Commission Scientific Report on Stunning Methods and

BSE Risks (The Risk of Dissemination of Brain Particles into the

Blood and Carcass when Applying Certain Stunning Methods. December

2001).

[264] European Commission Health & Consumer Protection Directorate-

General Scientific Steering Committee Opinion an the Implications af

the Recent Papers on Transmission of BSE by Blood. 13 September 2002.

<http://europa.eu.int/comm/food/fs/bse/scientific_advice08_en.html>.

[265] Milk replacer is up to 15% red blood cell protein [Dr. Jim

Quigley. " Red blood cell protein in calf milk replacers. "

<http://www.calfnotes.com/pdf>files/CN049.pdf> ] and calves drink up

to 5 quarts per day [uSDA Dairy Herd Management Practices Focusing on

Preweaned Heifers N129.0793. July 1993.

<http://cofcs66.aphis.usda.gov/vs/ceah/cahm/Dairy_Cattle/ndhep/dr91des1.pdf>

].

[266] APC Overview. 2002.

<http://functionalproteins.com/overview/index.html>.

[267] APC. The Basic Science Behind Spray-Dried Plasma and Serum

Proteins. <http://www.functionalproteins.com/functional_prots/

images/thebasicscience.pdf>.

[268] American Protein Corporation. The Basic Science Behind

Spray-Dried Plasma and Serum Proteins.

[269] National Renderers Association. Rendered Animal Products for

Swine. <http://www.renderers.org/links/swine.htm>.

[270] Feed Management October 2001.

[271] North American Spray Dried Blood and Plasma Producers

statement. June 22, 2001.

[272] National Renderers Association. Rendered Animal Products for

Poultry. <http://www.renderers.org/Poultry/index.htm>.

[273] American Feed Industry Organization. Feedgram. 23 December

2002.

<http://www.afia.org/Feedgram_Articles/December_23_2002/FeedBag.html>.

[274] Guidance for Industry: Use of Material from Deer and Elk in

Animal Feed. 14 May 2003.

<http://www.fda.gov/cvm/guidance/dguide158.pdf>.

[275] American Feed Industry Organization. Feedgram. 30 April 2002.

<http://www.afia.org/Feedgram_Articles/April_30__2002/CWD.html>.

[276] " Critics say U.S. needs to do more to protect against mad cow. "

The Journal News (New York) 29 May 2003.

[277] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum

hosted by Angie Coiro.

<http://www.kqed.org/programs/programarchive.jsp?progID=RD19 & ResultStart=1 & R

esultCount=10 & type=radio>.

[278] Referring to mechanically separated meat [American Meat

Institute Fact Sheet. Meat Derived by Advanced Meat Recovery. October

2002. www.amif.org/FactSheetAdvancedMeatRecovery.pdf>].

[279] " FDA changes in feed restriction won't reduce BSE risk,

industry groups say. " by Dan Murphy on 1/15/03 for

www.meatingplace.com.

[280] Based on average 7.9 week weaning period [uSDA Dairy Herd

Management Practices Focusing on Preweaned Heifers N129.0793. July

1993.

<http://cofcs66.aphis.usda.gov/vs/ceah/cahm/Dairy_Cattle/ndhep/dr91des1.pdf>

].

[281] Testimony of Richard Sellers, Vice President for Feed Control &

Nutrition, American Feed Industry Association, before the U.S. Senate

Subcommittee on Consumer Affairs. 4 April 2001 Washington, DC.

[282] USDA Food Safety and Inspection Service. Current Thinking on

Measures that Could be Implemented to Minimize Human Exposure to

Materials that Could Potentially Contain the Bovine Spongiform

Encephalopathy Agent. 15 January 2002.

[283] US Meat Groups Oppose BSE Rules. January 21, 2002 Farms.com.

[284] American Meat Institute Fact Sheet. Meat Derived by Advanced

Meat Recovery. October 2002.

[285] AMI Fact Sheet Bovine Spongiform Encephalopathy. November 2002.

[286] USDA Food Safety and Inspection Service. Current Thinking on

Measures that Could be Implemented to Minimize Human Exposure to

Materials that Could Potentially Contain the Bovine Spongiform

Encephalopathy Agent. 15 January 2002.

[287] The Journal News (New York) 29 May 2003.

[288] European Commission press release IP/00/1289. Brussels, 13 November

2000.

--

Michael Greger, M.D.

mhg1

857-928-2778

 

 

 

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