OH..thats makes sense..not...Meat industry againt banning rendering spinal columns

[Guest guest]

like animals less then 30 months couldn't have mad cow er something...

 

 

NGFA Suggests FDA Consider Banning Brain, Spinal Cord of Certain Cattle as Part

of Systems-Based Approach to BSE Prevention

 

 

Washington, DC--The National Grain and Feed Association (NGFA) said it would be

" prudent and preferable " for the Food and Drug Administration (FDA) to

await the results of the U.S. government's expanded inspection of the U.S.

cattle

herd before making substantive changes to the agency's existing animal feed

rules

that are designed to prevent the establishment or spread of bovine spongiform

encephalopathy

(BSE).

 

 

However, the NGFA said that if the agency decides to proceed before such

surveillance

data are available, it would be advisable for FDA to propose the removal of

brain

and spinal cord of cattle 30 months or older from all animal food and feed as

the

" centerpiece " of a systems-based approach - instead of pursuing its plan

to implement a ban on all so-called " specified risk materials " (SRMs).

 

 

The NGFA said a full SRM removal at this stage would represent a " Draconian "

approach that " could force a dramatic restructuring of an entire industry sector

and impose adverse economic and environmental impacts that ultimately may prove

to be unwarranted. " The U.S. Department of Agriculture is in the midst of an

enhanced surveillance program in which approximately 268,000 cattle are expected

to be tested for BSE by the end of 2005 to better determine the prevalence of

BSE

if it exists in the native U.S. herd.

 

 

USDA's surveillance is designed to enable the department to detect BSE even if

it

exists in only five cattle in the entire U.S. cattle herd.

 

 

To date, the only two cases of BSE detected in North America have occurred in

Canadian-born

cattle born before both countries implemented their BSE-prevention feed rules in

1997.

 

 

In a comprehensive 25-page statement submitted to FDA, the NGFA said it believed

that a ban on brain and spinal cord from cattle 30 months or older, coupled with

compliance with FDA's existing BSE-prevention feed rule and the removal of

certain

dead stock from the feed chain would provide protection that is equivalent to a

full SRM ban in protecting animal health.

 

 

The NGFA cited scientific evidence that the brain and spinal cord of cattle 30

months

or older carry upwards of 90 percent of total infectivity in cattle nearing the

clinical onset of the disease.

 

 

In an advance notice of proposed rulemaking published July 14, FDA said it had

" tentatively

concluded " to propose later this year a ban in all animal food and feed of

the use of all SRMs, as well as dead and non-ambulatory ( " downer " ) cattle,

as a way to " adequately control " the risk of potential cross-contamination

of these materials in ruminant feed.

 

 

FDA said it was planning to define as SRMs the same list of materials banned

earlier

this year in human food by USDA's Food Safety and Inspection Service.

 

 

Those materials include the skull, brain, trigeminal ganglia, eyes, vertebral

column,

spinal cord and dorsal root ganglia (nerve endings attached to the spinal cord)

of all cattle 30 months or older, as well as the small intestines and tonsils of

cattle of all ages.

 

 

If FDA decides to proceed with changes to its BSE-prevention feed rules before

USDA's

surveillance is completed, the NGFA said, " proposing a ban on brain and spinal

cord of cattle 30 months or older would more justified and appropriate than a

full

SRM ban based upon the North American experience, in which BSE-prevention

firewalls

were implemented decades before the first case was diagnosed and the existing

BSE-prevention

feed regulations enjoy unprecedented compliance exceeding 99 percent. "

 

 

The NGFA also cited several scientific studies - including the landmark analyses

conducted by the Harvard Center for Risk Analysis - that have found the risk of

BSE in the United States to be extremely low. The NGFA urged that FDA contract

with

the Harvard Center for Risk Analysis to quantify the additional BSE

risk-mitigation

that would result from a " policy menu whose centerpiece " is a ban on brain

and spinal cord from cattle 30 months or older, combined with the existing

BSE-prevention

feed rules and the level of compliance with those regulations that far exceeds

what

Harvard projected in its original 2001 study.

 

 

FDA officials have stated publicly that compliance with its BSE-prevention feed

rule has been " exceptional, " exceeding the levels achieved for any other

FDA regulation.

 

 

The NGFA also stressed that human health already has been protected by actions

previously

implemented by USDA and FDA.

 

 

Those actions include a ban on all SRMs from human food, dietary supplements and

cosmetics, as well as prohibitions on certain slaughter-stunning practices.

 

 

" We do not minimize the importance of taking prudent and responsible regulatory

action when it comes to preventing the establishment or spread of BSE in the

United

States to protect animal health, " the NGFA said.

 

 

" But those who argue it is urgent for FDA to amend its BSE-prevention feed

rule to protect human health are at best misguided, misled and wrong.

 

 

" Human health already has been protected. " Further, the NGFA said that

waiting for the results of USDA's cattle inspection program would be consistent

with the approach recommended by an international review team of scientific

experts

that investigated the two North American cases of BSE.

 

 

That team's report stated that removal of SRMs from human food was a " reasonable

temporary compromise " if the U.S. implemented enhanced surveillance to determine

the prevalence of BSE in the U.S. cattle herd.

 

 

The NGFA also reiterated its support for the continued use of animal proteins -

including ruminant-derived material - as safe, nutritious and wholesome feed

ingredients

for species for which they are legally approved, and as an environmentally and

economically

sound practice.

 

 

Concerning other aspects of FDA's rulemaking, the NGFA recommended that FDA not

require feed mills that manufacture feed for multiple species, including

ruminants,

to use dedicated plants, equipment, production lines and transportation if they

handle mammalian-based feed ingredients prohibited from being fed to cattle or

other

ruminants.

 

 

While the NGFA recommends dedicated facilities as a voluntary best-management

practice

for feed mills, it noted that it is impractical for some facilities, which have

chosen instead to use the clean-out procedures authorized by FDA under its 1997

BSE-prevention feed rule.

 

 

But the NGFA said FDA should consider requiring dedicated equipment for

rendering

establishments that currently process animals from multiple species, including

ruminants,

and which also manufacture and distribute feed ingredients for ruminants.

 

 

" It is this sector of the industry - the 'top of the pyramid' - where the

potential

for cross contamination and potential adverse consequences for down-stream users

is greatest, " the NGFA said.

 

 

Using FDA's BSE inspection database, the NGFA estimated that of 148 rendering

firms

that process material from multiple species, including ruminants, 53 also

manufacture

and distribute feed ingredients for ruminants.

 

 

FDA's database does not report the volume of meat-and-bone meal produced by

those

53 firms.

 

 

In addition, the NGFA strongly opposed banning all mammalian and avian

meat-and-bone

meal from ruminant feed, noting there was no scientific justification for doing

so.

 

 

Likewise, the association said it was not aware of any scientific evidence that

would justify banning bovine blood and blood products from ruminant feed.

 

 

The NGFA also reiterated its support of strong, government-based inspection and

enforcement of FDA's existing BSE-prevention feed rule, which since 1997 has

prohibited

the feeding of certain mammalian material to cattle and other ruminants.

 

 

In this regard, the NGFA said it does not support the U.S. government requiring

the use of - or relying in lieu of government oversight upon - non-governmental,

third-party certification of regulated facilities or feed products for

compliance

with the BSE-prevention feed rule.

 

 

Further, the NGFA recommended that FDA consider requiring establishments that

utilize

mammalian material prohibited from being fed to cattle or other ruminants - and

which also manufacture ruminant feed or feed ruminant animals - to register with

the agency.

 

 

But the NGFA stressed that such registrations should be considered only if doing

so would enhance the agency's trace-forward inspections, in which FDA and state

feed control agencies focus inspection resources on those facilities that

actually

use prohibited mammalian material as a feed ingredient and also manufacture feed

for ruminant animals.

 

http://grainnet.com/info/articles.html?type=bn & ID=23394

[Guest guest]

I note in The Vegan magazine that there is a new cow-brain disease!

They give a link www.hpa.org.uk I have not looked at this link yet.

 

Jo

 

, fraggle <EBbrewpunx@e...> wrote:

> like animals less then 30 months couldn't have mad cow er

something...

>

>

> NGFA Suggests FDA Consider Banning Brain, Spinal Cord of Certain

Cattle as Part

> of Systems-Based Approach to BSE Prevention

>

>

> Washington, DC--The National Grain and Feed Association (NGFA) said

it would be

> " prudent and preferable " for the Food and Drug Administration (FDA)

to

> await the results of the U.S. government's expanded inspection of

the U.S. cattle

> herd before making substantive changes to the agency's existing

animal feed rules

> that are designed to prevent the establishment or spread of bovine

spongiform encephalopathy

> (BSE).

>

>

> However, the NGFA said that if the agency decides to proceed before

such surveillance

> data are available, it would be advisable for FDA to propose the

removal of brain

> and spinal cord of cattle 30 months or older from all animal food

and feed as the

> " centerpiece " of a systems-based approach - instead of pursuing its

plan

> to implement a ban on all so-called " specified risk materials "

(SRMs).

>

>

> The NGFA said a full SRM removal at this stage would represent

a " Draconian "

> approach that " could force a dramatic restructuring of an entire

industry sector

> and impose adverse economic and environmental impacts that

ultimately may prove

> to be unwarranted. " The U.S. Department of Agriculture is in the

midst of an

> enhanced surveillance program in which approximately 268,000 cattle

are expected

> to be tested for BSE by the end of 2005 to better determine the

prevalence of BSE

> if it exists in the native U.S. herd.

>

>

> USDA's surveillance is designed to enable the department to detect

BSE even if it

> exists in only five cattle in the entire U.S. cattle herd.

>

>

> To date, the only two cases of BSE detected in North America have

occurred in Canadian-born

> cattle born before both countries implemented their BSE-prevention

feed rules in

> 1997.

>

>

> In a comprehensive 25-page statement submitted to FDA, the NGFA

said it believed

> that a ban on brain and spinal cord from cattle 30 months or older,

coupled with

> compliance with FDA's existing BSE-prevention feed rule and the

removal of certain

> dead stock from the feed chain would provide protection that is

equivalent to a

> full SRM ban in protecting animal health.

>

>

> The NGFA cited scientific evidence that the brain and spinal cord

of cattle 30 months

> or older carry upwards of 90 percent of total infectivity in cattle

nearing the

> clinical onset of the disease.

>

>

> In an advance notice of proposed rulemaking published July 14, FDA

said it had " tentatively

> concluded " to propose later this year a ban in all animal food and

feed of

> the use of all SRMs, as well as dead and non-ambulatory ( " downer " )

cattle,

> as a way to " adequately control " the risk of potential cross-

contamination

> of these materials in ruminant feed.

>

>

> FDA said it was planning to define as SRMs the same list of

materials banned earlier

> this year in human food by USDA's Food Safety and Inspection

Service.

>

>

> Those materials include the skull, brain, trigeminal ganglia, eyes,

vertebral column,

> spinal cord and dorsal root ganglia (nerve endings attached to the

spinal cord)

> of all cattle 30 months or older, as well as the small intestines

and tonsils of

> cattle of all ages.

>

>

> If FDA decides to proceed with changes to its BSE-prevention feed

rules before USDA's

> surveillance is completed, the NGFA said, " proposing a ban on brain

and spinal

> cord of cattle 30 months or older would more justified and

appropriate than a full

> SRM ban based upon the North American experience, in which BSE-

prevention firewalls

> were implemented decades before the first case was diagnosed and

the existing BSE-prevention

> feed regulations enjoy unprecedented compliance exceeding 99

percent. "

>

>

> The NGFA also cited several scientific studies - including the

landmark analyses

> conducted by the Harvard Center for Risk Analysis - that have found

the risk of

> BSE in the United States to be extremely low. The NGFA urged that

FDA contract with

> the Harvard Center for Risk Analysis to quantify the additional BSE

risk-mitigation

> that would result from a " policy menu whose centerpiece " is a ban

on brain

> and spinal cord from cattle 30 months or older, combined with the

existing BSE-prevention

> feed rules and the level of compliance with those regulations that

far exceeds what

> Harvard projected in its original 2001 study.

>

>

> FDA officials have stated publicly that compliance with its BSE-

prevention feed

> rule has been " exceptional, " exceeding the levels achieved for any

other

> FDA regulation.

>

>

> The NGFA also stressed that human health already has been protected

by actions previously

> implemented by USDA and FDA.

>

>

> Those actions include a ban on all SRMs from human food, dietary

supplements and

> cosmetics, as well as prohibitions on certain slaughter-stunning

practices.

>

>

> " We do not minimize the importance of taking prudent and

responsible regulatory

> action when it comes to preventing the establishment or spread of

BSE in the United

> States to protect animal health, " the NGFA said.

>

>

> " But those who argue it is urgent for FDA to amend its BSE-

prevention feed

> rule to protect human health are at best misguided, misled and

wrong.

>

>

> " Human health already has been protected. " Further, the NGFA said

that

> waiting for the results of USDA's cattle inspection program would

be consistent

> with the approach recommended by an international review team of

scientific experts

> that investigated the two North American cases of BSE.

>

>

> That team's report stated that removal of SRMs from human food was

a " reasonable

> temporary compromise " if the U.S. implemented enhanced surveillance

to determine

> the prevalence of BSE in the U.S. cattle herd.

>

>

> The NGFA also reiterated its support for the continued use of

animal proteins -

> including ruminant-derived material - as safe, nutritious and

wholesome feed ingredients

> for species for which they are legally approved, and as an

environmentally and economically

> sound practice.

>

>

> Concerning other aspects of FDA's rulemaking, the NGFA recommended

that FDA not

> require feed mills that manufacture feed for multiple species,

including ruminants,

> to use dedicated plants, equipment, production lines and

transportation if they

> handle mammalian-based feed ingredients prohibited from being fed

to cattle or other

> ruminants.

>

>

> While the NGFA recommends dedicated facilities as a voluntary best-

management practice

> for feed mills, it noted that it is impractical for some

facilities, which have

> chosen instead to use the clean-out procedures authorized by FDA

under its 1997

> BSE-prevention feed rule.

>

>

> But the NGFA said FDA should consider requiring dedicated equipment

for rendering

> establishments that currently process animals from multiple

species, including ruminants,

> and which also manufacture and distribute feed ingredients for

ruminants.

>

>

> " It is this sector of the industry - the 'top of the pyramid' -

where the potential

> for cross contamination and potential adverse consequences for down-

stream users

> is greatest, " the NGFA said.

>

>

> Using FDA's BSE inspection database, the NGFA estimated that of 148

rendering firms

> that process material from multiple species, including ruminants,

53 also manufacture

> and distribute feed ingredients for ruminants.

>

>

> FDA's database does not report the volume of meat-and-bone meal

produced by those

> 53 firms.

>

>

> In addition, the NGFA strongly opposed banning all mammalian and

avian meat-and-bone

> meal from ruminant feed, noting there was no scientific

justification for doing

> so.

>

>

> Likewise, the association said it was not aware of any scientific

evidence that

> would justify banning bovine blood and blood products from ruminant

feed.

>

>

> The NGFA also reiterated its support of strong, government-based

inspection and

> enforcement of FDA's existing BSE-prevention feed rule, which since

1997 has prohibited

> the feeding of certain mammalian material to cattle and other

ruminants.

>

>

> In this regard, the NGFA said it does not support the U.S.

government requiring

> the use of - or relying in lieu of government oversight upon - non-

governmental,

> third-party certification of regulated facilities or feed products

for compliance

> with the BSE-prevention feed rule.

>

>

> Further, the NGFA recommended that FDA consider requiring

establishments that utilize

> mammalian material prohibited from being fed to cattle or other

ruminants - and

> which also manufacture ruminant feed or feed ruminant animals - to

register with

> the agency.

>

>

> But the NGFA stressed that such registrations should be considered

only if doing

> so would enhance the agency's trace-forward inspections, in which

FDA and state

> feed control agencies focus inspection resources on those

facilities that actually

> use prohibited mammalian material as a feed ingredient and also

manufacture feed

> for ruminant animals.

>

> http://grainnet.com/info/articles.html?type=bn & ID=23394