In vivo prion protein intestinal uptake in fish
1: APMIS. 2008 Mar;116(3):173-80.
In vivo prion protein intestinal uptake in fish.
Dalla Valle AZ, Iriti M, Faoro F, Berti C, Ciappellano S.
Department of Food Science and Microbiology (DISTAM), Section of Human Nutrition, University of Milan, Milan, Italy.
Intestinal uptake of abnormal prion protein (PrP(Sc)), the pathological agent involved in transmissible spongiform encephalopathies (TSEs), has been investigated in rainbow trout (Oncorhynchus mykiss). Experimental procedures were conducted in vivo by immunohistological PrP(Sc) localization in intestine and pyloric caeca after forced feeding of infected material. Results indicate that PrP(Sc) was absorbed by the intestinal mucosa and that it persisted in the fish gastrointestinal tract for up to 3 days in pyloric caeca and for up to 7 days in the distal intestine. It did not remain longer than 15 days in the fish intestine; furthermore, it did not cross the intestinal barrier.
PMID: 18377582 [PubMed - in process]
http://www.ncbi.nlm.nih.gov/pubmed/18377582?ordinalpos=1&itool=EntrezSystem2.PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVDocSum
> Results indicate that PrP(Sc) was absorbed by the intestinal mucosa and that it persisted
> in the fish gastrointestinal tract for up to 3 days in pyloric caeca and for up to 7 days in the
> distal intestine.
> It did not remain longer than 15 days in the fish intestine;
WOULD this not be a potential risk factor for transmission of the PrPSc agent to cattle and other species via fish by-products and or fish feed ???
vCJD in the USA * BSE in U.S.
15 November 1999
snip...
Our feeding and rendering practices have mirrored that of the U.K. for years, some say it was worse. Everything from the downer cattle, to those scrapie infected sheep, to any roadkill, including the city police horse and the circus elephant went to the renders for feed and other products for consumption. Then they only implemented a partial feed ban on Aug. 4, 1997, but pigs, chickens, dogs, and cats, and humans were exempt from that ban. So they can still feed pigs and chickens those potentially TSE tainted by-products, and then they can still feed those by-products back to the cows.
***I believe it was Dr. Joe Gibbs, that said, the prion protein, can survive the digestinal track. So you have stopped nothing.
It was proven in Oprah Winfrey's trial, that Cactus Cattle feeders, sent neurologically ill cattle, some with encephalopathy stamped on the dead slips, were picked up and sent to the renders, along with sheep carcasses. Speaking of autopsies, I have a stack of them, from CJD victims. You would be surprised of the number of them, who ate cow brains, elk brains, deer brains, or hog brains.
snip...
full text ;
http://www.bmj.com/cgi/eletters/319/7220/1312/b#5406
Subject: CANADA BSE FACT SHEET FOR FISH BY-PRODUCT RENDERERS UPDATE
Date: June 5, 2007 at 1:16 pm PST
FACT SHEET FOR FISH BY-PRODUCT RENDERERS
Overview
On July 12, 2007, a series of amendments to the Feeds Regulations, 1983, and the Health of Animals Regulations will come into effect, to further protect animal health and accelerate the eradication of bovine spongiform encephalopathy (BSE) in Canada. Since BSE was first reported in Canada in 2003, Canada’s trading partners have demanded additional assurances and certification of animal products, by-products, and feeds containing these ingredients. In addition to banning the use of certain cattle tissues in animal feed, pet food and fertilizers, the regulatory amendments will also introduce new controls on animal product renderers. It is noteworthy that many of our trading partners consider fish by-products to be an animal product.
For the purposes of this fact sheet, fish by-product renderers are defined as those who receive inedible offal, fish or fish by-products from fish processing plants or other sources and render it to produce fish meal or fish oil products.
New requirements for fish by-product renderers
As a result of the regulatory amendments described above, the following requirements will apply to all fish by-product rendering facilities as of July 12, 2007:
All rendering facilities (including those processing fish by-products) must obtain and operate under a permit issued by the Canadian Food Inspection Agency (CFIA), and be subject to routine inspection by the CFIA;
Rendering facilities that import fish by-products will be required to obtain a Health of Animals import permit;
Rendering facilities that export fish by-products (including fish meal and fish oil) will be required to obtain a CFIA export certification; and
Fish by-product renderers are required to keep production and distribution records for 10 years.
One of the benefits of these amendments will be enhanced traceability of fish meal and fish oil from both domestic and import sources through the feed system. Fish meal and fish oil have a broad range of applications in animal feeds and fertilizers. Identifying the locations and origin of primary ingredients, such as fish meal and fish oil, allows the CFIA to more effectively direct its resources to monitoring and sampling activities related to the safety of these products. Sampling and testing these ingredients directly, rather than the finished feed products, provides a more accurate picture of the safety of the ingredients.
CFIA fish by-product rendering survey
To prepare for the new regulatory requirements, the CFIA is undertaking a survey of fish by-product renderers across Canada. At some time in the next few months, if you are a fish by-product renderer, you will be contacted by someone from the CFIA, who will make arrangements to inspect your facility. The primary purpose of the survey is to collect information on how many fish rendering facilities operate separately from other renderers, and the types and quantities of products they produce. The CFIA needs this information to plan for inspections and the preparation and issuance of fish rendering permits. It is important to note that all information collected will be considered confidential.
Conducting the survey will allow CFIA Feed Program inspectors to inform renderers about the inspection process and answer questions. Inspectors will also take the opportunity to discuss the additional requirements for importing and exporting fish meal and fish oil that will apply when the regulatory amendments come into effect.
If you are a fish by-product renderer, you are encouraged to discuss the requirements of the rendering permit program with the CFIA inspector performing the survey, and arrange to undergo a preliminary inspection. At the time of the survey, the inspector will leave a copy of the application for a Rendering Plant permit with the facility manager and answer any questions.
Rendering Plant Operating Permits
Rendering permits are issued for a period of one year, normally beginning on April 1st and ending on March 31st. There are no fees for a permit. Permit issuance is subject to an inspection of the rendering facility showing that it is in full compliance with the regulations. Once a fish by-product renderer has been identified, and a preliminary inspection completed, a temporary rendering permit will be issued to them. Any necessary modifications must be completed, and the facilities must be in full compliance with regulatory requirements, when the amended regulations enter into force on July 12, 2007.
BY JULY 12, 2007, ALL FISH BY-PRODUCT RENDERERS MUST HAVE A CFIA RENDERING PERMIT TO CONTINUE OPERATING.
For more information, please contact a CFIA Feed Program Specialist in your area at the appropriate telephone number:
Atlantic Area: 902-426-1410
Québec Area: 514-283-3815 (ext. 377)
Ontario Area: 519-826-2910
Western Area: 204-983-7441
http://www.inspection.gc.ca/english/anima/heasan/disemala/bseesb/enhren/fispoie.shtml
Feed Ban Enhancement
Questions and Answers
http://www.inspection.gc.ca/english/anima/feebet/rumin/enhqueste.shtml
SEE EXAMPLE OF TONNAGE OF FEED FOR FISH AT ONE MILL
Mr. Dwayne Holifield, B.S., manager of the research farm led the tour of the Delta Western Feed Mill in Indianola, MS. Delta Western Research Center has several tenth-acre ponds. The ponds are used for research projects involving nutrition and field trials of therapeutic products. The research center also has a second mill used to produce smaller lots of experimental catfish feeds. The research unit works extensively with NWAC. The main mill produces about 230,000 tons of catfish feed annually representing thirty percent of the 825,000 tons of catfish sold annually. Railroad lines bring grain products used in the feed directly to the mill. Three large warehouses store ground corn, wheat middlings and soybean meal that are pumped directly into the mill as needed. The mill has doubled its finished-feed storage capacity over the last two years to a capacity of 5,000 tons. The mill operates two 8 - 10 hour shifts depending on the time of year. The storage area is filled completely by the end of the second shift and emptied by mid-morning the next day. The feed is delivered to farms in large tanker type trucks. Each truck has a capacity of 20 tons and can be completely filled in 2 1/2 minutes.
http://www.fda.gov/cvm/Sep_Oct01.htm#2378
What we know about the herd of origin What we know about the herd of origin
Owner was former catfish farmer who moved Owner was former catfish farmer who moved
to Alberta in 2001 to Alberta in 2001
Owner inexperienced in cattle production Owner inexperienced in cattle production
Cow was part of 80 cow herd assembled Cow was part of 80 cow herd assembled
from multiple sources from multiple sources
No identification saved from index case No identification saved from index case
Source of index case not recorded
http://www.vet.ohio-state.edu/assets/courses/vm510/EpidemiologyOfBSE.pdf
The rancher, Marwyn Peaster, a former Mississippi catfish farmer who had married an area woman and started farming in the area, had taken off. He was upset that the TV crew had shown up his land.
http://www.sportsshooter.com/news/950
Dr. Detwiler: Canada based that question because the herd that that animal came from was in Saskatchewan, in an area with CWD. That was one of the questions they faced right off the bat: is this BSE or is this some kind of transmission from CWD-infected elk in the area? Not only the histological lesions were classic BSE lesions, but clinically it's very difficult because if you miss the other behavioral changes, which this owner did. It was someone who had been a catfish farmer. He missed the early signs. The animal presented to slaughter as a down animal, non-responsive. Clinically it looked like just a down cow, but they did send that on to the United Kingdom and they did do some comparison glycoform patterns. Those haven’t been validated, but at least on preliminary work, it looked like classical BSE.
http://bse-atypical.blogspot.com/
QUESTION - was this farmer feeding catfish feed to his cattle ???
Feeding Farmed Fish
snip...
Farming animals has suffered from the recent crises of Mad Cow Disease as well as the disastrous consequences of the accidental or fraudulent contamination of feeds with dioxins and other undesirable products. These events have accentuated the general suspicion of consumers and brought the necessary application of new and more complex laws, being more restrictive and therefore imposing more costs for the producers.
Aquaculture does and must carry the image of food security in respect of the consumer. But it must continue constantly to battle against hearsay and unfounded criticism.
Since aquaculture started in Europe, aquaculture feeds contain neither antibiotics (except in the case of authorized therapeutic treatment), nor hormones, nor growth enhancers or additives that could have existed in other areas of animal production. The traceability of the products used at all stages of the production process up to the consumer's purchase is, without doubt, the best answer to give confidence.
The European Union imports products from third countries that do not always respect the same sanitary restrictions, a position which leads to food production costs that are considerably lower than in the Member States (without referring to social costs and ecological considerations). One can assert that the fish feeds produced in the EU are 10% more expensive, at an equivalent nutritive content, than elsewhere, in particular since the withdrawal of protein-rich terrestrial animal by-products (from abattoirs).
We must therefore pay attention to this discrepancy which exists and is growing in Europe and well as with other regions of the world. The trade of seafood and aquaculture products is international and the identification [labelling] of products at the level of the consumer's purchase is another point which has not been completely resolved, in spite of the wishes of all of the professionals of the feed and aquaculture production sectors of the EU as well as the new rules for labelling and identification that have been law since the 1st January 2002.
The new European legislation that is being elaborated for the use of animal by-products must follow the Directive 90/667/CEE that establishes «the veterinary rules for the disposal and processing of animal waste, for its placing on the market and for the prevention of pathogens in feedstuffs of animal or fish origin» . This new legislation classes animal by-products as a function of their potential risks and defines their conditions of destruction or use, where only products that are qualified as being of 'low risk' can be used for animal feeds by those establishments that have been approved for such an activity.
Unfortunately, the fish meals and oils that are derived from the fisheries dedicated to this activity have been assimilated with the by-products of terrestrial animals and are thus considered as being waste materials at the same level as the waste products obtained from abattoirs or kitchen waste. In addition to the fact that these fisheries are managed by quotas and are wholly natural products of very high food quality, this simplified and negative classification is a source of very serious confusion.
In particular, the rather negative image that has been given to these natural products will complicate any information and communication action of the international aquaculture community. This question merits all of our attention when we look to increase the importance of the products of fisheries and aquaculture.
snip...see full text ;
http://www.feap.info/production/feeds/sabautcipa_en.asp
Fish farming under threat?
The possibility of a disease crossing the species barrier hangs like a Damocles sword over a number of farming sectors, including fish farming. ‘All farmed fish are fed feed with a 40% to 55% protein content. This can include animal protein and, hence, potentially pathogenic prion proteins,’ explains Theodoros Sklaviadis of the University of Thessaloniki (GR).
In 1997, Carla Bolis, a researcher at the University of Milan (IT), discovered a normal prion protein, previously believed to exist only in mammals, in the brain of salmon. This means it is important to determine the risk of TSE in fish, as the programme coordinated by Sklaviadis is seeking to do. This work focuses on two areas. The first is a systematic search in the genomes of trout, sea bass and bream for the coding sequences of the prion protein in order to analyse homologies with mammal genes. The second involves feeding these fish food containing BSE and scrapie prions, to see whether it is possible to start an infection. ‘Given the incubation period of the disease, the results will not be available for several years,’ Sklaviadis warns. Patience is called for if we want to ensure that Europe’s fish farmers never experience a “mad fish” crisis.
http://ec.europa.eu/research/rtdinfo/39/01/article_302_en.html
see where USA still feeds fish banned mad cow feed. ...tss
Archive Number 20060809.2235
Published Date 09-AUG-2006
Subject PRO/AH/EDR> BSE, bovine - USA (02): feed recall
BSE, BOVINE - USA (02): FEED RECALL
*********************************************
A ProMED-mail post
ProMED-mail is a program of the
International Society for Infectious Diseases
[1]
Date: Wed, 9 Aug 2006 22:26:49 +0100
From: "Mary Marshall"
Source: Cattle Network 8 Aug 2006 [edited]
Huge Feed Recall Due To Mammalian Protein
---------------------------------------------
The Food and Drug Administration announced 2 recalls, one for 27 million
pounds of feed produced in Michigan and the other an unknown amount of feed
produced in Kentucky. Both were suspected of being adulterated with ruminant
or mammalian protein, including ruminant meat and bone meal in the 2nd
recall.
Vita Plus Corp., Gagetown, Michigan, has recalled 27 694 240 pounds of dairy
feed produced between February of 2005 and 16 Jun 2006, because it is
believed it was contaminated with mammalian protein. The feed was
distributed in Michigan and the recall is complete.
Burkmann Feeds LLC, Glasgow, Kentucky, has recalled an unknown amount of custom
feed because it contains an ingredient called Pro-Lak, which may contain
ruminant-derived meat and bone meal. The Burkmann feed was distributed in
Kentucky.
[By Pete Hisey on Tuesday, August 08, 2006 ]
--
Mary Marshall
*****
[2]
Date: 7 Aug 2006
From: Terry Singeltary
Source: FDA [weekly] Enforcement Report, 2 Aug 2006 [edited]
(1) PRODUCT: Animal and fish feeds Recall # V-112-6
CODE: Product manufactured from 1 Feb 2005 to 6 Jun 2006
RECALLING FIRM/MANUFACTURER: Alabama Farmers Cooperative, Inc.,
Decatur, Alabama, by telephone, fax, email and visit on 9 Jun 2006.
FDA initiated recall is complete.
REASON: Animal and fish feeds which were possibly contaminated with
ruminant-based protein not labeled as "Do not feed to ruminants."
VOLUME OF PRODUCT IN COMMERCE: 125 tons
DISTRIBUTION: Alabama and Florida
(2) PRODUCT: Bulk custom dairy feeds manufactured from concentrates,
Recall # V-113-6
CODE: All dairy feeds produced between 1 Feb 2005 and 16 Jun 2006 and
containing H. J. Baker recalled feed products.
RECALLING FIRM/MANUFACTURER: Vita Plus Corp., Gagetown, Michigan, by
visit beginning on 21 Jun 2006. Firm initiated recall is complete.
REASON: The feed was manufactured from materials that may have been
contaminated with mammalian protein.
VOLUME OF PRODUCT IN COMMERCE: 27 694 240 lbs
DISTRIBUTION: Michigan
(3) PRODUCT: Bulk custom made dairy feed, Recall # V-114-6
CODE: None
RECALLING FIRM/MANUFACTURER: Burkmann Feeds LLC, Glasgow, Kentucky,
by letter on 14 Jul 2006. Firm initiated recall is ongoing.
REASON: Custom made feeds contain ingredient called Pro-Lak, which
may contain ruminant derived meat and bone meal.
VOLUME OF PRODUCT IN COMMERCE: Unknown
DISTRIBUTION: Kentucky
--
Terry Singeltary
[A codified rule indicates that no mammalian material is to be
included in feed for ruminants. When it is found that such a
situation has occurred, then a recall is issued. Several years ago, a
similar situation happened in Gonzales, Texas, and the herd was
depopulated. The difference must be that the regulatory authorities
do not know where all the herds are that have consumed the feed. - Mod.TG]
[see also:
BSE, bovine - USA: feed recall 20060621.1718]
..................................................tg/msp/jw
************************************************************
Subject: MAD COW FDA FEED WARNING LETTER NO. 2007-NOL-01 October 26, 2006 H.J. Baker & Bro., Inc.
Date: November 7, 2006 at 9:08 am PST
Food and Drug Administration
New Orleans District
404 BNA Drive, Building 200, Suite 500
Nashville, TN 37217
Telephone: 615-366-7801
Facsimile: 615-366-7802
October 26, 2006
WARNING LETTER NO. 2007-NOL-01
FEDERAL EXPRESS
OVERNIGHT DELIVERY
Mr. Christopher V. B. Smith
Corporate President, CEO
H. J. Baker & Bro., Inc.
228 Saugatuck Avenue
Westport, Connecticut 06880
Dear Mr. Smith:
On June 6, 8, 12-15, and 23, 2006, a U.S . Food and Drug Administration (FDA) investigator inspected your animal feed protein supplement manufacturing facility, located at 603 Railroad Avenue, Albertville, Alabama. The inspection revealed significant deviations from the requirements set forth in Title 21, Code ofFederal Regulations, Part 589.2000 (21 CFR 589.2000), Animal Proteins Prohibited in Ruminant Feed. This regulation is intended to prevent the establishment and amplification of Bovine Spongiform Encephalopathy (BSE). You failed to follow the requirements of this regulation, resulting in products being manufactured and distributed by your facility because they are adulterated within the meaning of Section 402(a)(4) [21 USC 342(a)(4)] of the Federal Food, Drug, and Cosmetic Act (the Act) and misbranded within the meaning of Section 403(a)(1) [21 USC 343(a)(1)] of the Act.
Our investigation determined adulteration resulted from the failure of your firm to establish and implement measures sufficient to prevent commingling or cross-contamination . The adulterated feed was subsequently misbranded because it was not properly labeled. Specifically, we found :
" Your firm failed to establish and use cleanout procedures or other means to prevent carry-over of products which contain or may contain protein derived from mammalian tissues into animal protein or feeds which may be used for ruminants, as required by 21 CFR 589.2000(e)(1)(iii)(B) .
Specifically, you failed to establish and use such measures for a screw auger installed in February 2005 . This auger is used to convey both prohibited and non-prohibited material to bulk storage bins.
In addition, you failed to follow the cleanout procedure your firm had developed for the receiving systems. Your feed is, therefore, adulterated under Section 402(a)(4) [21 USC 342(a)(4)] of the Act.
" You failed to label all products which contained or may have contained prohibited materials with the BSE cautionary statement, "Do not feed to cattle or other ruminants," as required by 21 CFR 589.2000(e)(1)(i) . Such products are misbranded under Section 403(3) [21 USC 343(a)(1)] of the Act. These misbranded products include the three Pro-Pak products mentioned below, as well as Page 2 - H. J . Baker & Bro., Inc., Albertville, Alabama Warning Letter No. 2007-NOL-O 1 those bulk loads of individual feed ingredients processed through this common screw auger and distributed between the time it was installed in February 2005, and June 9, 2006 .
This letter is not intended to serve as an all-inclusive list of violations at your facility. As a
manufacturer of materials intended for animal feed use, you are responsible for ensuring your overall operation and the products you manufacture and distribute are in compliance with the law. You should take prompt action to correct these violations, and you should establish a system whereby violations do not recur. Failure to promptly correct these violations may result in regulatory action, such as seizure and/or injunction,
without further notice.
We acknowledge your June 16, 2006, voluntary recall of three products you manufactured from February 2005 to June 2006. The three products recalled were: Pro-Lak Protein Concentrate for
Lactating Dairy Animals;
Pro-Amino II for PreFresh and Lactating Cows;
***and, Pro-Pak Marine & Animal Protein Concentrate for Use in Animal Feed. Recall effectiveness checks and other measures
will determine the merit of this recall . We recognize you now label all products with the required BSE cautionary statement and we also acknowledge your intent, given verbally to New Orleans District management of the FDA, to discontinue the production of supplements which do not contain prohibited
materials. In your written response to this letter, please confirm in writing you have taken these steps.
snip...
http://www.fda.gov/foi/warning_letters/g6104d.pdf
Subject: MAD COW FEED RECALLS ENFORCEMENT REPORT FOR AUGUST 9, 2006 KY, LA,
MS, AL, GA, AND TN 11,000+ TONS
Date: August 16, 2006 at 9:19 am PST
RECALLS AND FIELD CORRECTIONS: VETERINARY MEDICINE - CLASS II
______________________________
snip...
______________________________
PRODUCT
*** a) Tucker Milling, LLC Tm 32% Sinking Fish Grower, #2680-Pellet,
50 lb. bags, Recall # V-121-6;
b) Tucker Milling, LLC #31120, Game Bird Breeder Pellet,
50 lb. bags, Recall # V-122-6;
c) Tucker Milling, LLC #31232 Game Bird Grower,
50 lb. bags, Recall # V-123-6;
d) Tucker Milling, LLC 31227-Crumble, Game Bird Starter, BMD
Medicated, 50 lb bags, Recall # V-124-6;
e) Tucker Milling, LLC #31120, Game Bird Breeder, 50 lb bags,
Recall # V-125-6;
f) Tucker Milling, LLC #30230, 30 % Turkey Starter, 50 lb bags,
Recall # V-126-6;
g) Tucker Milling, LLC #30116, TM Broiler Finisher,
50 lb bags, Recall # V-127-6
CODE
All products manufactured from 02/01/2005 until 06/20/2006
RECALLING FIRM/MANUFACTURER
Recalling Firm: Tucker Milling LLC, Guntersville, AL, by telephone and visit
on June 20, 2006, and by letter on June 23, 2006.
Manufacturer: H. J. Baker and Brothers Inc., Stamford, CT. Firm initiated
recall is ongoing.
REASON
Poultry and fish feeds which were possibly contaminated with ruminant based
protein were not labeled as "Do not feed to ruminants".
VOLUME OF PRODUCT IN COMMERCE
7,541-50 lb bags
DISTRIBUTION
AL, GA, MS, and TN
END OF ENFORCEMENT REPORT FOR AUGUST 9, 2006
###
http://www.fda.gov/bbs/topics/ENFORCE/2006/ENF00964.html
Subject: MAD COW FEED RECALL AL AND FL VOLUME OF PRODUCT IN COMMERCE 125
TONS Products manufactured from 02/01/2005 until 06/06/2006
Date: August 6, 2006 at 6:16 pm PST
PRODUCT
*** a) CO-OP 32% Sinking Catfish, Recall # V-100-6;
b) Performance Sheep Pell W/Decox/A/N, medicated,
net wt. 50 lbs, Recall # V-101-6;
c) Pro 40% Swine Conc Meal -- 50 lb, Recall # V-102-6;
*** d) CO-OP 32% Sinking Catfish Food Medicated,
Recall # V-103-6;
e) "Big Jim's" BBB Deer Ration, Big Buck Blend,
Recall # V-104-6;
f) CO-OP 40% Hog Supplement Medicated Pelleted,
Tylosin 100 grams/ton, 50 lb. bag, Recall # V-105-6;
g) Pig Starter Pell II, 18% W/MCDX Medicated 282020,
Carbadox -- 0.0055%, Recall # V-106-6;
h) CO-OP STARTER-GROWER CRUMBLES, Complete
Feed for Chickens from Hatch to 20 Weeks, Medicated,
Bacitracin Methylene Disalicylate, 25 and 50 Lbs,
Recall # V-107-6;
i) CO-OP LAYING PELLETS, Complete Feed for Laying
Chickens, Recall # 108-6;
j) CO-OP LAYING CRUMBLES, Recall # V-109-6;
k) CO-OP QUAIL FLIGHT CONDITIONER MEDICATED,
net wt 50 Lbs, Recall # V-110-6;
l) CO-OP QUAIL STARTER MEDICATED, Net Wt. 50 Lbs,
Recall # V-111-6;
m) CO-OP QUAIL GROWER MEDICATED, 50 Lbs,
Recall # V-112-6
CODE
Product manufactured from 02/01/2005 until 06/06/2006
RECALLING FIRM/MANUFACTURER
Alabama Farmers Cooperative, Inc., Decatur, AL, by telephone, fax, email and
visit on June 9, 2006. FDA initiated recall is complete.
REASON
Animal and fish feeds which were possibly contaminated with ruminant based
protein not labeled as "Do not feed to ruminants".
VOLUME OF PRODUCT IN COMMERCE
125 tons
DISTRIBUTION
AL and FL
END OF ENFORCEMENT REPORT FOR AUGUST 2, 2006
###
http://www.fda.gov/bbs/topics/enforce/2006/ENF00963.html
MAD COW FEED RECALL USA EQUALS 10,878.06 TONS NATIONWIDE
Sun Jul 16, 2006 09:22
71.248.128.67
RECALLS AND FIELD CORRECTIONS: VETERINARY MEDICINE -- CLASS II
______________________________
PRODUCT
a) PRO-LAK, bulk weight, Protein Concentrate for Lactating Dairy Animals,
Recall # V-079-6;
b) ProAmino II, FOR PREFRESH AND LACTATING COWS, net weight 50lb (22.6 kg),
Recall # V-080-6;
*** c) PRO-PAK, MARINE & ANIMAL PROTEIN CONCENTRATE FOR USE IN ANIMAL
FEED, Recall # V-081-6;
d) Feather Meal, Recall # V-082-6
CODE
a) Bulk
b) None
c) Bulk
d) Bulk
RECALLING FIRM/MANUFACTURER
H. J. Baker & Bro., Inc., Albertville, AL, by telephone on June 15, 2006 and
by press release on June 16, 2006. Firm initiated recall is ongoing.
REASON
Possible contamination of animal feeds with ruminent derived meat and bone
meal.
VOLUME OF PRODUCT IN COMMERCE
10,878.06 tons
DISTRIBUTION
Nationwide
END OF ENFORCEMENT REPORT FOR July 12, 2006
###
http://www.fda.gov/bbs/topics/enforce/2006/ENF00960.html
Mr. Sturm was found to hold animals on his farm under conditions that are so inadequate that diseased animals and/or medicated animals bearing potentially harmful drug residues are likely to enter the food supply. In addition, he failed to use the drug, Albon, containing sulfadimethoxine, in conformance with the labeling.
A warning letter was issued to the following firms for violations related to 21 CFR Part 589.2000—Animal Proteins Prohibited in Ruminant Feed. This regulation is intended to prevent the establishment and amplification of Bovine Spongiform Encephalopathy (BSE).
*** • Scott Nelson, Owner, Integra Fish Foods, Inc., Grand Junction, CO
• Bruce A. Burgett, General Manager, The Carrollton Farmers Exchange, Carrollton, OH
Violations included failure to label feeds that contain, or may contain, prohibited materials with the required cautionary statement "Do Not Feed to Cattle or Other Ruminants," insufficient customer records to track the distribution of products, and lack of written procedures for cleaning or flushing equipment after mixing feeds containing prohibited material.
http://www.fda.gov/cvm/Sep_Oct01.htm
look at the table and you'll see that as little as 1 mg (or 0.001 gm) caused 7% (1 of 14) of the cows to come down with BSE;
Risk of oral infection with bovine spongiform encephalopathy agent in primates
Corinne Ida Lasmézas, Emmanuel Comoy, Stephen Hawkins, Christian Herzog, Franck Mouthon, Timm Konold, Frédéric Auvré, Evelyne Correia, Nathalie Lescoutra-Etchegaray, Nicole Salès, Gerald Wells, Paul Brown, Jean-Philippe Deslys
Summary
The uncertain extent of human exposure to bovine spongiform encephalopathy (BSE)--which can lead to variant Creutzfeldt-Jakob disease (vCJD)--is compounded by incomplete knowledge about the efficiency of oral infection and the magnitude of any bovine-to-human biological barrier to transmission. We therefore investigated oral transmission of BSE to non-human primates. We gave two macaques a 5 g oral dose of brain homogenate from a BSE-infected cow. One macaque developed vCJD-like neurological disease 60 months after exposure, whereas the other remained free of disease at 76 months. On the basis of these findings and data from other studies, we made a preliminary estimate of the food exposure risk for man, which provides additional assurance that existing public health measures can prevent transmission of BSE to man.
snip...
BSE bovine brain inoculum
100 g 10 g 5 g 1 g 100 mg 10 mg 1 mg 0·1 mg 0·01 mg
Primate (oral route)* 1/2 (50%)
Cattle (oral route)* 10/10 (100%) 7/9 (78%) 7/10 (70%) 3/15 (20%) 1/15 (7%) 1/15 (7%)
RIII mice (ic ip route)* 17/18 (94%) 15/17 (88%) 1/14 (7%)
PrPres biochemical detection
The comparison is made on the basis of calibration of the bovine inoculum used in our study with primates against a bovine brain inoculum with a similar PrPres concentration that was inoculated into mice and cattle.8 *Data are number of animals positive/number of animals surviving at the time of clinical onset of disease in the first positive animal (%). The accuracy of bioassays is generally judged to be about plus or minus 1 log. icip= intracerebral and intraperitoneal.
Table 1: Comparison of transmission rates in primates and cattle infected orally with similar BSE brain inocula
Published online January 27, 2005
http://www.thelancet.com/journal/journal.isa
It is clear that the designing scientists must also have shared Mr Bradley's surprise
at the results because all the dose levels right down to 1 gram triggered infection.
http://www.bseinquiry.gov.uk/files/ws/s145d.pdf
6. It also appears to me that Mr Bradley's answer (that it would take less than say 100 grams) was probably given with the benefit of hindsight; particularly if one considers that later in the same answer Mr Bradley expresses his surprise that it could take as little of 1 gram of brain to cause BSE by the oral route within the same species. This information did not become available until the "attack rate"
experiment had been completed in 1995/96. This was a titration experiment designed to ascertain the infective dose. A range of dosages was used to ensure that the actual result was within both a lower and an upper limit within the study and the designing scientists would not have expected all the dose levels to trigger infection. The dose ranges chosen by the most informed scientists at that time ranged from 1 gram to three times one hundred grams. It is clear that the designing scientists must have also shared Mr Bradley's surprise at the results because all the dose levels right down to 1 gram triggered infection.
http://www.bseinquiry.gov.uk/files/ws/s147f.pdf
PDF] Guidance for Industry 69File Format: PDF/Adobe Acrobat - View as HTML The Food and Drug Administration (FDA) has prepared this guide in accordance ... If a feed intended for ruminants contains animal protein, the protein can ... www.fda.gov/cvm/Guidance/guidance69.pdf - Similar pages - Note this
http://www.fda.gov/cvm/Guidance/guidance69.pdf
[PDF] Guidance for Industry 70File Format: PDF/Adobe Acrobat - View as HTML If a feed is intended for ruminants contains animal protein, the protein can ... with On-Farm Feed Mixing Operations,” FDA Guidance for Industry 69. ... www.fda.gov/cvm/Guidance/guidance70.pdf - Similar pages - Note this
WHAT IS THE PURPOSE AND SCOPE OF THIS REGULATION?
This regulation is designed to prevent the establishment and amplification of Bovine Spongiform Encephalopathy (BSE), sometimes referred to as “Mad Cow Disease,” through animal feed. The regulation prohibits the use of certain proteins derived from mammalian tissue in feeding ruminant animals. An example is meat and bone meal derived from cattle. However, certain products are exempt from this regulation.
# The following protein products derived from mammals are exempt.:
Blood and blood products P Gelatin Milk products (milk and milk proteins) Pure porcine (pork) or pure equine (horse) protein products Inspected meat products, such as plate waste, which have been cooked and offered for human food and further heat processed for animal feed
# The following nonmammalian protein products are exempt:
Poultry
***Marine (fish) ***
Vegetable
# The following products are also exempt because they are not protein or tissue:
Grease Fat Amino acids
Tallow Oil
Dicalcium phosphate
We refer to the exempted products throughout this guide as “nonprohibited material.” We refer to all mammalian protein that is not exempted as “prohibited material.”
Prohibited material and/or feeds containing prohibited material cannot be fed to ruminant animals. “Ruminant animals” are any animals with a four-chambered stomach including cattle, sheep, goats, buffalo, elk, and deer.
http://www.fda.gov/cvm/Guidance/guidance70.pdf
[PPT] Detection of Ruminant MBM Prohibited ProteinFile Format: Microsoft Powerpoint - View as HTML Detection of Ruminant MBM Prohibited Protein. Development of an assay to address the needs of the feed industry. Ensure consumer confidence in FDA ... aafco.org/Portals/0/public/Frank_Klein.ppt - Similar pages - Note this
http://aafco.org/Portals/0/public/Frank_Klein.ppt
[PDF] M A M M A L I A N P R O T E I N F E E D I N G B A N Feeders of ...File Format: PDF/Adobe Acrobat - View as HTML ruminant and non-ruminant feeds. If this isn't possible,. you must properly and thoroughly clean .... prohibited animal protein products:. www.fda.gov/cvm ... aafco.org/Portals/0/Public/BSE_aafco_brochure.pdf - Similar pages - Note this
Protein products derived from non-mammalian sources are exempt:
•Poultry; marine (fish); vegetable
The following products are also exempt because they are not protein or tissue:
•Fats and oils, including grease and tallow; amino acids; dicalcium phosphate Exempted animal protein products Mammalian protein products that are exempt from the feed ban are non-prohibited proteins.
•Blood and blood products; milk products (milk and milk proteins); pure porcine (pork) or pure equine (horse) protein products; inspected meat products (such as plate waste) which have been cooked and offered for human consump - tion and further heat processed for animal feed; gelatin.
http://aafco.org/Portals/0/Public/BSE_aafco_brochure.pdf
AND THE CIRCLE OF GREED IS COMPLETE $$$
Using Byproducts to Feed Dairy Cattle Donna M. Amaral-Phillips and R.W. Hemken
Various byproducts from feed processing industries are available for dairy farmers to incorporate into diets fed to dairy cows and replacement heifers. Using these feeds offers at least two benefits:
• may decrease the feed costs depending on prices of byproducts and grains.
• helps dispose of these byproducts in an ecologically sound manner.
Table 1. Nutrient composition of selected byproducts and cereal grains on a dry matter basis.
Dry Matter (%) Dry Matter Basis Crude Protein (%)
Blood meal, ring dried 92 95.5 1.06 0.30 0.30
snip...
Fish meal, anchovy 92 71.2 1.01 4.06 2.69
Fish meal, menhaden 92 68.5 1.06 5.34 3.05
snip...
Feather meal 93 92 0.98 0.33 0.50
Non-ruminant Meat meal 94 57.6 1.01 8.86 4.20 Non-Ruminant Meat and Bone Meal 92 54 0.74 10.60 4.73
snip...
Tallow 99 ------ 2.06 ------ ------
snip...
Blood Meal
1. Byproduct of the rendering industry.
2. Made from clean, fresh animal blood exclusive of the urine, hair, stomach contents, etc.
3. Flash drying process produces a more uniform product with a higher lysine content.
4. Due to potential palatability problems, best used in total mixed rations (TMR). Needs to be added slowly over a two-week period. Palatability problems may be encountered if added to grain mixes fed in the parlor or through a computer feeder.
5. Limit intake to 0.5-1.0 lbs/cow/day in total mixed rations.
Fish Meal
1. Made from clean, dried, ground, and undecomposed fish.
2. Rich in essential amino acids. The amino acid profile may be similar to that required for the synthesis of milk protein.
3. Due to potential palatability problems, best used in total mixed rations. Needs to be added slowly over a two-week period. Problems may be encountered if added to grain mixes fed in the parlor or through a computer feeder.
Hydrolyzed Feather Meal
1. Byproduct from the pressure treatment of clean, undecomposed feathers from slaughtered poultry.
2. Low in lysine and methionine which are believed to control milk production. However, this product is high in cysteine which may substitute for methionine in milk production.
3. Due to potential palatability problems, best used in total mixed rations. Needs to be added slowly over a two-week period. Problems may be encountered if added to grain mixes fed in the parlor or through a computer feeder.
4. Limit intake to 0.3 lbs/cow/day in total mixed rations.
Non-Ruminant Meat Meal
1. A rendered product from the carcasses of swine or poultry excluding blood, hair, hoof, hide trimmings, feces, and stomach. Similar to meat and bone meal except no minimum phosphorus concentration required.
2. Due to potential palatability problems, best used in total mixed rations. Needs to be added slowly over a two-week period. Problems may be encountered if added to grain mixes fed in the parlor or through a computer feeder.
3. Limit intake to 1.5-2.5 lbs/cow/day in total mixed rations.
4. Do not feed ruminant derived meat and bone meal back to ruminants.
Non-Ruminant Meat and Bone Meal
1. A rendered product from the carcass of swine or poultry excluding blood, hair, hoof, hide trimmings, feces, and stomach. It contains a minimum of 4% phosphorus with a calcium content that does not exceed 2.2 times the phosphorus concentration.
2. Due to potential palatability problems, best used in total mixed rations. Needs to be added slowly over a two-week period. Palatability problems may be encountered if added to grain mixes fed in the parlor or through a computer feeder.
3. Limit intake to 1.5-2.5 lbs/cow/day in total mixed rations.
4. Do not feed ruminant derived meat and bone meal back to ruminants.
Tallow
1. Derived primarily from rendered beef fat but may include other animal fats.
2. Requires special handling equipment because at room temperature it is a solid or semi-solid. To be mixed within feed, it must be heated so that it can be melted.
3. Nine different grades of tallow are sold. Good quality (fancy bleachable) tallow should be used for the most consistent animal response.
4. Limit to 1 lb/1200 lb cow/day.
http://www.uky.edu/Ag/AnimalSciences/dairy/extension/nut00158.pdf
STRICTLY PRIVATE AND CONFIDENTIAL 25, AUGUST 1995
snip...
To minimise the risk of farmers' claims for compensation from feed compounders.
To minimise the potential damage to compound feed markets through adverse publicity.
To maximise freedom of action for feed compounders, notably by maintaining the availability of meat and bone meal as a raw material in animal feeds, and ensuring time is available to make any changes which may be required.
snip...
THE FUTURE
4..........
MAFF remains under pressure in Brussels and is not skilled at handling potentially explosive issues.
5. Tests _may_ show that ruminant feeds have been sold which contain illegal traces of ruminant protein. More likely, a few positive test results will turn up but proof that a particular feed mill knowingly supplied it to a particular farm will be difficult if not impossible.
6. The threat remains real and it will be some years before feed compounders are free of it. The longer we can avoid any direct linkage between feed milling _practices_ and actual BSE cases, the more likely it is that serious damage can be avoided. ...
SEE full text ;
http://www.bseinquiry.gov.uk/files/yb/1995/08/24002001.pdf
like i said, and endless cycle of greed, i.e. FOR PROFIT ONLY $$$
USDA CERTIFIED DEAD STOCK DOWNER COW SCHOOL LUNCH PROGRAM LIST OF SCHOOLS AFFECTED STATE BY STATE (dead stock downers i.e. non-ambulatory, the most high risk for mad cow disease)
http://downercattle.blogspot.com/
TSS
In vivo prion protein intestinal uptake in fish.
Dalla Valle AZ, Iriti M, Faoro F, Berti C, Ciappellano S.
Department of Food Science and Microbiology (DISTAM), Section of Human Nutrition, University of Milan, Milan, Italy.
Intestinal uptake of abnormal prion protein (PrP(Sc)), the pathological agent involved in transmissible spongiform encephalopathies (TSEs), has been investigated in rainbow trout (Oncorhynchus mykiss). Experimental procedures were conducted in vivo by immunohistological PrP(Sc) localization in intestine and pyloric caeca after forced feeding of infected material. Results indicate that PrP(Sc) was absorbed by the intestinal mucosa and that it persisted in the fish gastrointestinal tract for up to 3 days in pyloric caeca and for up to 7 days in the distal intestine. It did not remain longer than 15 days in the fish intestine; furthermore, it did not cross the intestinal barrier.
PMID: 18377582 [PubMed - in process]
http://www.ncbi.nlm.nih.gov/pubmed/18377582?ordinalpos=1&itool=EntrezSystem2.PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_RVDocSum
> Results indicate that PrP(Sc) was absorbed by the intestinal mucosa and that it persisted
> in the fish gastrointestinal tract for up to 3 days in pyloric caeca and for up to 7 days in the
> distal intestine.
> It did not remain longer than 15 days in the fish intestine;
WOULD this not be a potential risk factor for transmission of the PrPSc agent to cattle and other species via fish by-products and or fish feed ???
vCJD in the USA * BSE in U.S.
15 November 1999
snip...
Our feeding and rendering practices have mirrored that of the U.K. for years, some say it was worse. Everything from the downer cattle, to those scrapie infected sheep, to any roadkill, including the city police horse and the circus elephant went to the renders for feed and other products for consumption. Then they only implemented a partial feed ban on Aug. 4, 1997, but pigs, chickens, dogs, and cats, and humans were exempt from that ban. So they can still feed pigs and chickens those potentially TSE tainted by-products, and then they can still feed those by-products back to the cows.
***I believe it was Dr. Joe Gibbs, that said, the prion protein, can survive the digestinal track. So you have stopped nothing.
It was proven in Oprah Winfrey's trial, that Cactus Cattle feeders, sent neurologically ill cattle, some with encephalopathy stamped on the dead slips, were picked up and sent to the renders, along with sheep carcasses. Speaking of autopsies, I have a stack of them, from CJD victims. You would be surprised of the number of them, who ate cow brains, elk brains, deer brains, or hog brains.
snip...
full text ;
http://www.bmj.com/cgi/eletters/319/7220/1312/b#5406
Subject: CANADA BSE FACT SHEET FOR FISH BY-PRODUCT RENDERERS UPDATE
Date: June 5, 2007 at 1:16 pm PST
FACT SHEET FOR FISH BY-PRODUCT RENDERERS
Overview
On July 12, 2007, a series of amendments to the Feeds Regulations, 1983, and the Health of Animals Regulations will come into effect, to further protect animal health and accelerate the eradication of bovine spongiform encephalopathy (BSE) in Canada. Since BSE was first reported in Canada in 2003, Canada’s trading partners have demanded additional assurances and certification of animal products, by-products, and feeds containing these ingredients. In addition to banning the use of certain cattle tissues in animal feed, pet food and fertilizers, the regulatory amendments will also introduce new controls on animal product renderers. It is noteworthy that many of our trading partners consider fish by-products to be an animal product.
For the purposes of this fact sheet, fish by-product renderers are defined as those who receive inedible offal, fish or fish by-products from fish processing plants or other sources and render it to produce fish meal or fish oil products.
New requirements for fish by-product renderers
As a result of the regulatory amendments described above, the following requirements will apply to all fish by-product rendering facilities as of July 12, 2007:
All rendering facilities (including those processing fish by-products) must obtain and operate under a permit issued by the Canadian Food Inspection Agency (CFIA), and be subject to routine inspection by the CFIA;
Rendering facilities that import fish by-products will be required to obtain a Health of Animals import permit;
Rendering facilities that export fish by-products (including fish meal and fish oil) will be required to obtain a CFIA export certification; and
Fish by-product renderers are required to keep production and distribution records for 10 years.
One of the benefits of these amendments will be enhanced traceability of fish meal and fish oil from both domestic and import sources through the feed system. Fish meal and fish oil have a broad range of applications in animal feeds and fertilizers. Identifying the locations and origin of primary ingredients, such as fish meal and fish oil, allows the CFIA to more effectively direct its resources to monitoring and sampling activities related to the safety of these products. Sampling and testing these ingredients directly, rather than the finished feed products, provides a more accurate picture of the safety of the ingredients.
CFIA fish by-product rendering survey
To prepare for the new regulatory requirements, the CFIA is undertaking a survey of fish by-product renderers across Canada. At some time in the next few months, if you are a fish by-product renderer, you will be contacted by someone from the CFIA, who will make arrangements to inspect your facility. The primary purpose of the survey is to collect information on how many fish rendering facilities operate separately from other renderers, and the types and quantities of products they produce. The CFIA needs this information to plan for inspections and the preparation and issuance of fish rendering permits. It is important to note that all information collected will be considered confidential.
Conducting the survey will allow CFIA Feed Program inspectors to inform renderers about the inspection process and answer questions. Inspectors will also take the opportunity to discuss the additional requirements for importing and exporting fish meal and fish oil that will apply when the regulatory amendments come into effect.
If you are a fish by-product renderer, you are encouraged to discuss the requirements of the rendering permit program with the CFIA inspector performing the survey, and arrange to undergo a preliminary inspection. At the time of the survey, the inspector will leave a copy of the application for a Rendering Plant permit with the facility manager and answer any questions.
Rendering Plant Operating Permits
Rendering permits are issued for a period of one year, normally beginning on April 1st and ending on March 31st. There are no fees for a permit. Permit issuance is subject to an inspection of the rendering facility showing that it is in full compliance with the regulations. Once a fish by-product renderer has been identified, and a preliminary inspection completed, a temporary rendering permit will be issued to them. Any necessary modifications must be completed, and the facilities must be in full compliance with regulatory requirements, when the amended regulations enter into force on July 12, 2007.
BY JULY 12, 2007, ALL FISH BY-PRODUCT RENDERERS MUST HAVE A CFIA RENDERING PERMIT TO CONTINUE OPERATING.
For more information, please contact a CFIA Feed Program Specialist in your area at the appropriate telephone number:
Atlantic Area: 902-426-1410
Québec Area: 514-283-3815 (ext. 377)
Ontario Area: 519-826-2910
Western Area: 204-983-7441
http://www.inspection.gc.ca/english/anima/heasan/disemala/bseesb/enhren/fispoie.shtml
Feed Ban Enhancement
Questions and Answers
http://www.inspection.gc.ca/english/anima/feebet/rumin/enhqueste.shtml
SEE EXAMPLE OF TONNAGE OF FEED FOR FISH AT ONE MILL
Mr. Dwayne Holifield, B.S., manager of the research farm led the tour of the Delta Western Feed Mill in Indianola, MS. Delta Western Research Center has several tenth-acre ponds. The ponds are used for research projects involving nutrition and field trials of therapeutic products. The research center also has a second mill used to produce smaller lots of experimental catfish feeds. The research unit works extensively with NWAC. The main mill produces about 230,000 tons of catfish feed annually representing thirty percent of the 825,000 tons of catfish sold annually. Railroad lines bring grain products used in the feed directly to the mill. Three large warehouses store ground corn, wheat middlings and soybean meal that are pumped directly into the mill as needed. The mill has doubled its finished-feed storage capacity over the last two years to a capacity of 5,000 tons. The mill operates two 8 - 10 hour shifts depending on the time of year. The storage area is filled completely by the end of the second shift and emptied by mid-morning the next day. The feed is delivered to farms in large tanker type trucks. Each truck has a capacity of 20 tons and can be completely filled in 2 1/2 minutes.
http://www.fda.gov/cvm/Sep_Oct01.htm#2378
What we know about the herd of origin What we know about the herd of origin
Owner was former catfish farmer who moved Owner was former catfish farmer who moved
to Alberta in 2001 to Alberta in 2001
Owner inexperienced in cattle production Owner inexperienced in cattle production
Cow was part of 80 cow herd assembled Cow was part of 80 cow herd assembled
from multiple sources from multiple sources
No identification saved from index case No identification saved from index case
Source of index case not recorded
http://www.vet.ohio-state.edu/assets/courses/vm510/EpidemiologyOfBSE.pdf
The rancher, Marwyn Peaster, a former Mississippi catfish farmer who had married an area woman and started farming in the area, had taken off. He was upset that the TV crew had shown up his land.
http://www.sportsshooter.com/news/950
Dr. Detwiler: Canada based that question because the herd that that animal came from was in Saskatchewan, in an area with CWD. That was one of the questions they faced right off the bat: is this BSE or is this some kind of transmission from CWD-infected elk in the area? Not only the histological lesions were classic BSE lesions, but clinically it's very difficult because if you miss the other behavioral changes, which this owner did. It was someone who had been a catfish farmer. He missed the early signs. The animal presented to slaughter as a down animal, non-responsive. Clinically it looked like just a down cow, but they did send that on to the United Kingdom and they did do some comparison glycoform patterns. Those haven’t been validated, but at least on preliminary work, it looked like classical BSE.
http://bse-atypical.blogspot.com/
QUESTION - was this farmer feeding catfish feed to his cattle ???
Feeding Farmed Fish
snip...
Farming animals has suffered from the recent crises of Mad Cow Disease as well as the disastrous consequences of the accidental or fraudulent contamination of feeds with dioxins and other undesirable products. These events have accentuated the general suspicion of consumers and brought the necessary application of new and more complex laws, being more restrictive and therefore imposing more costs for the producers.
Aquaculture does and must carry the image of food security in respect of the consumer. But it must continue constantly to battle against hearsay and unfounded criticism.
Since aquaculture started in Europe, aquaculture feeds contain neither antibiotics (except in the case of authorized therapeutic treatment), nor hormones, nor growth enhancers or additives that could have existed in other areas of animal production. The traceability of the products used at all stages of the production process up to the consumer's purchase is, without doubt, the best answer to give confidence.
The European Union imports products from third countries that do not always respect the same sanitary restrictions, a position which leads to food production costs that are considerably lower than in the Member States (without referring to social costs and ecological considerations). One can assert that the fish feeds produced in the EU are 10% more expensive, at an equivalent nutritive content, than elsewhere, in particular since the withdrawal of protein-rich terrestrial animal by-products (from abattoirs).
We must therefore pay attention to this discrepancy which exists and is growing in Europe and well as with other regions of the world. The trade of seafood and aquaculture products is international and the identification [labelling] of products at the level of the consumer's purchase is another point which has not been completely resolved, in spite of the wishes of all of the professionals of the feed and aquaculture production sectors of the EU as well as the new rules for labelling and identification that have been law since the 1st January 2002.
The new European legislation that is being elaborated for the use of animal by-products must follow the Directive 90/667/CEE that establishes «the veterinary rules for the disposal and processing of animal waste, for its placing on the market and for the prevention of pathogens in feedstuffs of animal or fish origin» . This new legislation classes animal by-products as a function of their potential risks and defines their conditions of destruction or use, where only products that are qualified as being of 'low risk' can be used for animal feeds by those establishments that have been approved for such an activity.
Unfortunately, the fish meals and oils that are derived from the fisheries dedicated to this activity have been assimilated with the by-products of terrestrial animals and are thus considered as being waste materials at the same level as the waste products obtained from abattoirs or kitchen waste. In addition to the fact that these fisheries are managed by quotas and are wholly natural products of very high food quality, this simplified and negative classification is a source of very serious confusion.
In particular, the rather negative image that has been given to these natural products will complicate any information and communication action of the international aquaculture community. This question merits all of our attention when we look to increase the importance of the products of fisheries and aquaculture.
snip...see full text ;
http://www.feap.info/production/feeds/sabautcipa_en.asp
Fish farming under threat?
The possibility of a disease crossing the species barrier hangs like a Damocles sword over a number of farming sectors, including fish farming. ‘All farmed fish are fed feed with a 40% to 55% protein content. This can include animal protein and, hence, potentially pathogenic prion proteins,’ explains Theodoros Sklaviadis of the University of Thessaloniki (GR).
In 1997, Carla Bolis, a researcher at the University of Milan (IT), discovered a normal prion protein, previously believed to exist only in mammals, in the brain of salmon. This means it is important to determine the risk of TSE in fish, as the programme coordinated by Sklaviadis is seeking to do. This work focuses on two areas. The first is a systematic search in the genomes of trout, sea bass and bream for the coding sequences of the prion protein in order to analyse homologies with mammal genes. The second involves feeding these fish food containing BSE and scrapie prions, to see whether it is possible to start an infection. ‘Given the incubation period of the disease, the results will not be available for several years,’ Sklaviadis warns. Patience is called for if we want to ensure that Europe’s fish farmers never experience a “mad fish” crisis.
http://ec.europa.eu/research/rtdinfo/39/01/article_302_en.html
see where USA still feeds fish banned mad cow feed. ...tss
Archive Number 20060809.2235
Published Date 09-AUG-2006
Subject PRO/AH/EDR> BSE, bovine - USA (02): feed recall
BSE, BOVINE - USA (02): FEED RECALL
*********************************************
A ProMED-mail post
ProMED-mail is a program of the
International Society for Infectious Diseases
[1]
Date: Wed, 9 Aug 2006 22:26:49 +0100
From: "Mary Marshall"
Source: Cattle Network 8 Aug 2006 [edited]
Huge Feed Recall Due To Mammalian Protein
---------------------------------------------
The Food and Drug Administration announced 2 recalls, one for 27 million
pounds of feed produced in Michigan and the other an unknown amount of feed
produced in Kentucky. Both were suspected of being adulterated with ruminant
or mammalian protein, including ruminant meat and bone meal in the 2nd
recall.
Vita Plus Corp., Gagetown, Michigan, has recalled 27 694 240 pounds of dairy
feed produced between February of 2005 and 16 Jun 2006, because it is
believed it was contaminated with mammalian protein. The feed was
distributed in Michigan and the recall is complete.
Burkmann Feeds LLC, Glasgow, Kentucky, has recalled an unknown amount of custom
feed because it contains an ingredient called Pro-Lak, which may contain
ruminant-derived meat and bone meal. The Burkmann feed was distributed in
Kentucky.
[By Pete Hisey on Tuesday, August 08, 2006 ]
--
Mary Marshall
*****
[2]
Date: 7 Aug 2006
From: Terry Singeltary
Source: FDA [weekly] Enforcement Report, 2 Aug 2006 [edited]
(1) PRODUCT: Animal and fish feeds Recall # V-112-6
CODE: Product manufactured from 1 Feb 2005 to 6 Jun 2006
RECALLING FIRM/MANUFACTURER: Alabama Farmers Cooperative, Inc.,
Decatur, Alabama, by telephone, fax, email and visit on 9 Jun 2006.
FDA initiated recall is complete.
REASON: Animal and fish feeds which were possibly contaminated with
ruminant-based protein not labeled as "Do not feed to ruminants."
VOLUME OF PRODUCT IN COMMERCE: 125 tons
DISTRIBUTION: Alabama and Florida
(2) PRODUCT: Bulk custom dairy feeds manufactured from concentrates,
Recall # V-113-6
CODE: All dairy feeds produced between 1 Feb 2005 and 16 Jun 2006 and
containing H. J. Baker recalled feed products.
RECALLING FIRM/MANUFACTURER: Vita Plus Corp., Gagetown, Michigan, by
visit beginning on 21 Jun 2006. Firm initiated recall is complete.
REASON: The feed was manufactured from materials that may have been
contaminated with mammalian protein.
VOLUME OF PRODUCT IN COMMERCE: 27 694 240 lbs
DISTRIBUTION: Michigan
(3) PRODUCT: Bulk custom made dairy feed, Recall # V-114-6
CODE: None
RECALLING FIRM/MANUFACTURER: Burkmann Feeds LLC, Glasgow, Kentucky,
by letter on 14 Jul 2006. Firm initiated recall is ongoing.
REASON: Custom made feeds contain ingredient called Pro-Lak, which
may contain ruminant derived meat and bone meal.
VOLUME OF PRODUCT IN COMMERCE: Unknown
DISTRIBUTION: Kentucky
--
Terry Singeltary
[A codified rule indicates that no mammalian material is to be
included in feed for ruminants. When it is found that such a
situation has occurred, then a recall is issued. Several years ago, a
similar situation happened in Gonzales, Texas, and the herd was
depopulated. The difference must be that the regulatory authorities
do not know where all the herds are that have consumed the feed. - Mod.TG]
[see also:
BSE, bovine - USA: feed recall 20060621.1718]
..................................................tg/msp/jw
************************************************************
Subject: MAD COW FDA FEED WARNING LETTER NO. 2007-NOL-01 October 26, 2006 H.J. Baker & Bro., Inc.
Date: November 7, 2006 at 9:08 am PST
Food and Drug Administration
New Orleans District
404 BNA Drive, Building 200, Suite 500
Nashville, TN 37217
Telephone: 615-366-7801
Facsimile: 615-366-7802
October 26, 2006
WARNING LETTER NO. 2007-NOL-01
FEDERAL EXPRESS
OVERNIGHT DELIVERY
Mr. Christopher V. B. Smith
Corporate President, CEO
H. J. Baker & Bro., Inc.
228 Saugatuck Avenue
Westport, Connecticut 06880
Dear Mr. Smith:
On June 6, 8, 12-15, and 23, 2006, a U.S . Food and Drug Administration (FDA) investigator inspected your animal feed protein supplement manufacturing facility, located at 603 Railroad Avenue, Albertville, Alabama. The inspection revealed significant deviations from the requirements set forth in Title 21, Code ofFederal Regulations, Part 589.2000 (21 CFR 589.2000), Animal Proteins Prohibited in Ruminant Feed. This regulation is intended to prevent the establishment and amplification of Bovine Spongiform Encephalopathy (BSE). You failed to follow the requirements of this regulation, resulting in products being manufactured and distributed by your facility because they are adulterated within the meaning of Section 402(a)(4) [21 USC 342(a)(4)] of the Federal Food, Drug, and Cosmetic Act (the Act) and misbranded within the meaning of Section 403(a)(1) [21 USC 343(a)(1)] of the Act.
Our investigation determined adulteration resulted from the failure of your firm to establish and implement measures sufficient to prevent commingling or cross-contamination . The adulterated feed was subsequently misbranded because it was not properly labeled. Specifically, we found :
" Your firm failed to establish and use cleanout procedures or other means to prevent carry-over of products which contain or may contain protein derived from mammalian tissues into animal protein or feeds which may be used for ruminants, as required by 21 CFR 589.2000(e)(1)(iii)(B) .
Specifically, you failed to establish and use such measures for a screw auger installed in February 2005 . This auger is used to convey both prohibited and non-prohibited material to bulk storage bins.
In addition, you failed to follow the cleanout procedure your firm had developed for the receiving systems. Your feed is, therefore, adulterated under Section 402(a)(4) [21 USC 342(a)(4)] of the Act.
" You failed to label all products which contained or may have contained prohibited materials with the BSE cautionary statement, "Do not feed to cattle or other ruminants," as required by 21 CFR 589.2000(e)(1)(i) . Such products are misbranded under Section 403(3) [21 USC 343(a)(1)] of the Act. These misbranded products include the three Pro-Pak products mentioned below, as well as Page 2 - H. J . Baker & Bro., Inc., Albertville, Alabama Warning Letter No. 2007-NOL-O 1 those bulk loads of individual feed ingredients processed through this common screw auger and distributed between the time it was installed in February 2005, and June 9, 2006 .
This letter is not intended to serve as an all-inclusive list of violations at your facility. As a
manufacturer of materials intended for animal feed use, you are responsible for ensuring your overall operation and the products you manufacture and distribute are in compliance with the law. You should take prompt action to correct these violations, and you should establish a system whereby violations do not recur. Failure to promptly correct these violations may result in regulatory action, such as seizure and/or injunction,
without further notice.
We acknowledge your June 16, 2006, voluntary recall of three products you manufactured from February 2005 to June 2006. The three products recalled were: Pro-Lak Protein Concentrate for
Lactating Dairy Animals;
Pro-Amino II for PreFresh and Lactating Cows;
***and, Pro-Pak Marine & Animal Protein Concentrate for Use in Animal Feed. Recall effectiveness checks and other measures
will determine the merit of this recall . We recognize you now label all products with the required BSE cautionary statement and we also acknowledge your intent, given verbally to New Orleans District management of the FDA, to discontinue the production of supplements which do not contain prohibited
materials. In your written response to this letter, please confirm in writing you have taken these steps.
snip...
http://www.fda.gov/foi/warning_letters/g6104d.pdf
Subject: MAD COW FEED RECALLS ENFORCEMENT REPORT FOR AUGUST 9, 2006 KY, LA,
MS, AL, GA, AND TN 11,000+ TONS
Date: August 16, 2006 at 9:19 am PST
RECALLS AND FIELD CORRECTIONS: VETERINARY MEDICINE - CLASS II
______________________________
snip...
______________________________
PRODUCT
*** a) Tucker Milling, LLC Tm 32% Sinking Fish Grower, #2680-Pellet,
50 lb. bags, Recall # V-121-6;
b) Tucker Milling, LLC #31120, Game Bird Breeder Pellet,
50 lb. bags, Recall # V-122-6;
c) Tucker Milling, LLC #31232 Game Bird Grower,
50 lb. bags, Recall # V-123-6;
d) Tucker Milling, LLC 31227-Crumble, Game Bird Starter, BMD
Medicated, 50 lb bags, Recall # V-124-6;
e) Tucker Milling, LLC #31120, Game Bird Breeder, 50 lb bags,
Recall # V-125-6;
f) Tucker Milling, LLC #30230, 30 % Turkey Starter, 50 lb bags,
Recall # V-126-6;
g) Tucker Milling, LLC #30116, TM Broiler Finisher,
50 lb bags, Recall # V-127-6
CODE
All products manufactured from 02/01/2005 until 06/20/2006
RECALLING FIRM/MANUFACTURER
Recalling Firm: Tucker Milling LLC, Guntersville, AL, by telephone and visit
on June 20, 2006, and by letter on June 23, 2006.
Manufacturer: H. J. Baker and Brothers Inc., Stamford, CT. Firm initiated
recall is ongoing.
REASON
Poultry and fish feeds which were possibly contaminated with ruminant based
protein were not labeled as "Do not feed to ruminants".
VOLUME OF PRODUCT IN COMMERCE
7,541-50 lb bags
DISTRIBUTION
AL, GA, MS, and TN
END OF ENFORCEMENT REPORT FOR AUGUST 9, 2006
###
http://www.fda.gov/bbs/topics/ENFORCE/2006/ENF00964.html
Subject: MAD COW FEED RECALL AL AND FL VOLUME OF PRODUCT IN COMMERCE 125
TONS Products manufactured from 02/01/2005 until 06/06/2006
Date: August 6, 2006 at 6:16 pm PST
PRODUCT
*** a) CO-OP 32% Sinking Catfish, Recall # V-100-6;
b) Performance Sheep Pell W/Decox/A/N, medicated,
net wt. 50 lbs, Recall # V-101-6;
c) Pro 40% Swine Conc Meal -- 50 lb, Recall # V-102-6;
*** d) CO-OP 32% Sinking Catfish Food Medicated,
Recall # V-103-6;
e) "Big Jim's" BBB Deer Ration, Big Buck Blend,
Recall # V-104-6;
f) CO-OP 40% Hog Supplement Medicated Pelleted,
Tylosin 100 grams/ton, 50 lb. bag, Recall # V-105-6;
g) Pig Starter Pell II, 18% W/MCDX Medicated 282020,
Carbadox -- 0.0055%, Recall # V-106-6;
h) CO-OP STARTER-GROWER CRUMBLES, Complete
Feed for Chickens from Hatch to 20 Weeks, Medicated,
Bacitracin Methylene Disalicylate, 25 and 50 Lbs,
Recall # V-107-6;
i) CO-OP LAYING PELLETS, Complete Feed for Laying
Chickens, Recall # 108-6;
j) CO-OP LAYING CRUMBLES, Recall # V-109-6;
k) CO-OP QUAIL FLIGHT CONDITIONER MEDICATED,
net wt 50 Lbs, Recall # V-110-6;
l) CO-OP QUAIL STARTER MEDICATED, Net Wt. 50 Lbs,
Recall # V-111-6;
m) CO-OP QUAIL GROWER MEDICATED, 50 Lbs,
Recall # V-112-6
CODE
Product manufactured from 02/01/2005 until 06/06/2006
RECALLING FIRM/MANUFACTURER
Alabama Farmers Cooperative, Inc., Decatur, AL, by telephone, fax, email and
visit on June 9, 2006. FDA initiated recall is complete.
REASON
Animal and fish feeds which were possibly contaminated with ruminant based
protein not labeled as "Do not feed to ruminants".
VOLUME OF PRODUCT IN COMMERCE
125 tons
DISTRIBUTION
AL and FL
END OF ENFORCEMENT REPORT FOR AUGUST 2, 2006
###
http://www.fda.gov/bbs/topics/enforce/2006/ENF00963.html
MAD COW FEED RECALL USA EQUALS 10,878.06 TONS NATIONWIDE
Sun Jul 16, 2006 09:22
71.248.128.67
RECALLS AND FIELD CORRECTIONS: VETERINARY MEDICINE -- CLASS II
______________________________
PRODUCT
a) PRO-LAK, bulk weight, Protein Concentrate for Lactating Dairy Animals,
Recall # V-079-6;
b) ProAmino II, FOR PREFRESH AND LACTATING COWS, net weight 50lb (22.6 kg),
Recall # V-080-6;
*** c) PRO-PAK, MARINE & ANIMAL PROTEIN CONCENTRATE FOR USE IN ANIMAL
FEED, Recall # V-081-6;
d) Feather Meal, Recall # V-082-6
CODE
a) Bulk
b) None
c) Bulk
d) Bulk
RECALLING FIRM/MANUFACTURER
H. J. Baker & Bro., Inc., Albertville, AL, by telephone on June 15, 2006 and
by press release on June 16, 2006. Firm initiated recall is ongoing.
REASON
Possible contamination of animal feeds with ruminent derived meat and bone
meal.
VOLUME OF PRODUCT IN COMMERCE
10,878.06 tons
DISTRIBUTION
Nationwide
END OF ENFORCEMENT REPORT FOR July 12, 2006
###
http://www.fda.gov/bbs/topics/enforce/2006/ENF00960.html
Mr. Sturm was found to hold animals on his farm under conditions that are so inadequate that diseased animals and/or medicated animals bearing potentially harmful drug residues are likely to enter the food supply. In addition, he failed to use the drug, Albon, containing sulfadimethoxine, in conformance with the labeling.
A warning letter was issued to the following firms for violations related to 21 CFR Part 589.2000—Animal Proteins Prohibited in Ruminant Feed. This regulation is intended to prevent the establishment and amplification of Bovine Spongiform Encephalopathy (BSE).
*** • Scott Nelson, Owner, Integra Fish Foods, Inc., Grand Junction, CO
• Bruce A. Burgett, General Manager, The Carrollton Farmers Exchange, Carrollton, OH
Violations included failure to label feeds that contain, or may contain, prohibited materials with the required cautionary statement "Do Not Feed to Cattle or Other Ruminants," insufficient customer records to track the distribution of products, and lack of written procedures for cleaning or flushing equipment after mixing feeds containing prohibited material.
http://www.fda.gov/cvm/Sep_Oct01.htm
look at the table and you'll see that as little as 1 mg (or 0.001 gm) caused 7% (1 of 14) of the cows to come down with BSE;
Risk of oral infection with bovine spongiform encephalopathy agent in primates
Corinne Ida Lasmézas, Emmanuel Comoy, Stephen Hawkins, Christian Herzog, Franck Mouthon, Timm Konold, Frédéric Auvré, Evelyne Correia, Nathalie Lescoutra-Etchegaray, Nicole Salès, Gerald Wells, Paul Brown, Jean-Philippe Deslys
Summary
The uncertain extent of human exposure to bovine spongiform encephalopathy (BSE)--which can lead to variant Creutzfeldt-Jakob disease (vCJD)--is compounded by incomplete knowledge about the efficiency of oral infection and the magnitude of any bovine-to-human biological barrier to transmission. We therefore investigated oral transmission of BSE to non-human primates. We gave two macaques a 5 g oral dose of brain homogenate from a BSE-infected cow. One macaque developed vCJD-like neurological disease 60 months after exposure, whereas the other remained free of disease at 76 months. On the basis of these findings and data from other studies, we made a preliminary estimate of the food exposure risk for man, which provides additional assurance that existing public health measures can prevent transmission of BSE to man.
snip...
BSE bovine brain inoculum
100 g 10 g 5 g 1 g 100 mg 10 mg 1 mg 0·1 mg 0·01 mg
Primate (oral route)* 1/2 (50%)
Cattle (oral route)* 10/10 (100%) 7/9 (78%) 7/10 (70%) 3/15 (20%) 1/15 (7%) 1/15 (7%)
RIII mice (ic ip route)* 17/18 (94%) 15/17 (88%) 1/14 (7%)
PrPres biochemical detection
The comparison is made on the basis of calibration of the bovine inoculum used in our study with primates against a bovine brain inoculum with a similar PrPres concentration that was inoculated into mice and cattle.8 *Data are number of animals positive/number of animals surviving at the time of clinical onset of disease in the first positive animal (%). The accuracy of bioassays is generally judged to be about plus or minus 1 log. icip= intracerebral and intraperitoneal.
Table 1: Comparison of transmission rates in primates and cattle infected orally with similar BSE brain inocula
Published online January 27, 2005
http://www.thelancet.com/journal/journal.isa
It is clear that the designing scientists must also have shared Mr Bradley's surprise
at the results because all the dose levels right down to 1 gram triggered infection.
http://www.bseinquiry.gov.uk/files/ws/s145d.pdf
6. It also appears to me that Mr Bradley's answer (that it would take less than say 100 grams) was probably given with the benefit of hindsight; particularly if one considers that later in the same answer Mr Bradley expresses his surprise that it could take as little of 1 gram of brain to cause BSE by the oral route within the same species. This information did not become available until the "attack rate"
experiment had been completed in 1995/96. This was a titration experiment designed to ascertain the infective dose. A range of dosages was used to ensure that the actual result was within both a lower and an upper limit within the study and the designing scientists would not have expected all the dose levels to trigger infection. The dose ranges chosen by the most informed scientists at that time ranged from 1 gram to three times one hundred grams. It is clear that the designing scientists must have also shared Mr Bradley's surprise at the results because all the dose levels right down to 1 gram triggered infection.
http://www.bseinquiry.gov.uk/files/ws/s147f.pdf
PDF] Guidance for Industry 69File Format: PDF/Adobe Acrobat - View as HTML The Food and Drug Administration (FDA) has prepared this guide in accordance ... If a feed intended for ruminants contains animal protein, the protein can ... www.fda.gov/cvm/Guidance/guidance69.pdf - Similar pages - Note this
http://www.fda.gov/cvm/Guidance/guidance69.pdf
[PDF] Guidance for Industry 70File Format: PDF/Adobe Acrobat - View as HTML If a feed is intended for ruminants contains animal protein, the protein can ... with On-Farm Feed Mixing Operations,” FDA Guidance for Industry 69. ... www.fda.gov/cvm/Guidance/guidance70.pdf - Similar pages - Note this
WHAT IS THE PURPOSE AND SCOPE OF THIS REGULATION?
This regulation is designed to prevent the establishment and amplification of Bovine Spongiform Encephalopathy (BSE), sometimes referred to as “Mad Cow Disease,” through animal feed. The regulation prohibits the use of certain proteins derived from mammalian tissue in feeding ruminant animals. An example is meat and bone meal derived from cattle. However, certain products are exempt from this regulation.
# The following protein products derived from mammals are exempt.:
Blood and blood products P Gelatin Milk products (milk and milk proteins) Pure porcine (pork) or pure equine (horse) protein products Inspected meat products, such as plate waste, which have been cooked and offered for human food and further heat processed for animal feed
# The following nonmammalian protein products are exempt:
Poultry
***Marine (fish) ***
Vegetable
# The following products are also exempt because they are not protein or tissue:
Grease Fat Amino acids
Tallow Oil
Dicalcium phosphate
We refer to the exempted products throughout this guide as “nonprohibited material.” We refer to all mammalian protein that is not exempted as “prohibited material.”
Prohibited material and/or feeds containing prohibited material cannot be fed to ruminant animals. “Ruminant animals” are any animals with a four-chambered stomach including cattle, sheep, goats, buffalo, elk, and deer.
http://www.fda.gov/cvm/Guidance/guidance70.pdf
[PPT] Detection of Ruminant MBM Prohibited ProteinFile Format: Microsoft Powerpoint - View as HTML Detection of Ruminant MBM Prohibited Protein. Development of an assay to address the needs of the feed industry. Ensure consumer confidence in FDA ... aafco.org/Portals/0/public/Frank_Klein.ppt - Similar pages - Note this
http://aafco.org/Portals/0/public/Frank_Klein.ppt
[PDF] M A M M A L I A N P R O T E I N F E E D I N G B A N Feeders of ...File Format: PDF/Adobe Acrobat - View as HTML ruminant and non-ruminant feeds. If this isn't possible,. you must properly and thoroughly clean .... prohibited animal protein products:. www.fda.gov/cvm ... aafco.org/Portals/0/Public/BSE_aafco_brochure.pdf - Similar pages - Note this
Protein products derived from non-mammalian sources are exempt:
•Poultry; marine (fish); vegetable
The following products are also exempt because they are not protein or tissue:
•Fats and oils, including grease and tallow; amino acids; dicalcium phosphate Exempted animal protein products Mammalian protein products that are exempt from the feed ban are non-prohibited proteins.
•Blood and blood products; milk products (milk and milk proteins); pure porcine (pork) or pure equine (horse) protein products; inspected meat products (such as plate waste) which have been cooked and offered for human consump - tion and further heat processed for animal feed; gelatin.
http://aafco.org/Portals/0/Public/BSE_aafco_brochure.pdf
AND THE CIRCLE OF GREED IS COMPLETE $$$
Using Byproducts to Feed Dairy Cattle Donna M. Amaral-Phillips and R.W. Hemken
Various byproducts from feed processing industries are available for dairy farmers to incorporate into diets fed to dairy cows and replacement heifers. Using these feeds offers at least two benefits:
• may decrease the feed costs depending on prices of byproducts and grains.
• helps dispose of these byproducts in an ecologically sound manner.
Table 1. Nutrient composition of selected byproducts and cereal grains on a dry matter basis.
Dry Matter (%) Dry Matter Basis Crude Protein (%)
Blood meal, ring dried 92 95.5 1.06 0.30 0.30
snip...
Fish meal, anchovy 92 71.2 1.01 4.06 2.69
Fish meal, menhaden 92 68.5 1.06 5.34 3.05
snip...
Feather meal 93 92 0.98 0.33 0.50
Non-ruminant Meat meal 94 57.6 1.01 8.86 4.20 Non-Ruminant Meat and Bone Meal 92 54 0.74 10.60 4.73
snip...
Tallow 99 ------ 2.06 ------ ------
snip...
Blood Meal
1. Byproduct of the rendering industry.
2. Made from clean, fresh animal blood exclusive of the urine, hair, stomach contents, etc.
3. Flash drying process produces a more uniform product with a higher lysine content.
4. Due to potential palatability problems, best used in total mixed rations (TMR). Needs to be added slowly over a two-week period. Palatability problems may be encountered if added to grain mixes fed in the parlor or through a computer feeder.
5. Limit intake to 0.5-1.0 lbs/cow/day in total mixed rations.
Fish Meal
1. Made from clean, dried, ground, and undecomposed fish.
2. Rich in essential amino acids. The amino acid profile may be similar to that required for the synthesis of milk protein.
3. Due to potential palatability problems, best used in total mixed rations. Needs to be added slowly over a two-week period. Problems may be encountered if added to grain mixes fed in the parlor or through a computer feeder.
Hydrolyzed Feather Meal
1. Byproduct from the pressure treatment of clean, undecomposed feathers from slaughtered poultry.
2. Low in lysine and methionine which are believed to control milk production. However, this product is high in cysteine which may substitute for methionine in milk production.
3. Due to potential palatability problems, best used in total mixed rations. Needs to be added slowly over a two-week period. Problems may be encountered if added to grain mixes fed in the parlor or through a computer feeder.
4. Limit intake to 0.3 lbs/cow/day in total mixed rations.
Non-Ruminant Meat Meal
1. A rendered product from the carcasses of swine or poultry excluding blood, hair, hoof, hide trimmings, feces, and stomach. Similar to meat and bone meal except no minimum phosphorus concentration required.
2. Due to potential palatability problems, best used in total mixed rations. Needs to be added slowly over a two-week period. Problems may be encountered if added to grain mixes fed in the parlor or through a computer feeder.
3. Limit intake to 1.5-2.5 lbs/cow/day in total mixed rations.
4. Do not feed ruminant derived meat and bone meal back to ruminants.
Non-Ruminant Meat and Bone Meal
1. A rendered product from the carcass of swine or poultry excluding blood, hair, hoof, hide trimmings, feces, and stomach. It contains a minimum of 4% phosphorus with a calcium content that does not exceed 2.2 times the phosphorus concentration.
2. Due to potential palatability problems, best used in total mixed rations. Needs to be added slowly over a two-week period. Palatability problems may be encountered if added to grain mixes fed in the parlor or through a computer feeder.
3. Limit intake to 1.5-2.5 lbs/cow/day in total mixed rations.
4. Do not feed ruminant derived meat and bone meal back to ruminants.
Tallow
1. Derived primarily from rendered beef fat but may include other animal fats.
2. Requires special handling equipment because at room temperature it is a solid or semi-solid. To be mixed within feed, it must be heated so that it can be melted.
3. Nine different grades of tallow are sold. Good quality (fancy bleachable) tallow should be used for the most consistent animal response.
4. Limit to 1 lb/1200 lb cow/day.
http://www.uky.edu/Ag/AnimalSciences/dairy/extension/nut00158.pdf
STRICTLY PRIVATE AND CONFIDENTIAL 25, AUGUST 1995
snip...
To minimise the risk of farmers' claims for compensation from feed compounders.
To minimise the potential damage to compound feed markets through adverse publicity.
To maximise freedom of action for feed compounders, notably by maintaining the availability of meat and bone meal as a raw material in animal feeds, and ensuring time is available to make any changes which may be required.
snip...
THE FUTURE
4..........
MAFF remains under pressure in Brussels and is not skilled at handling potentially explosive issues.
5. Tests _may_ show that ruminant feeds have been sold which contain illegal traces of ruminant protein. More likely, a few positive test results will turn up but proof that a particular feed mill knowingly supplied it to a particular farm will be difficult if not impossible.
6. The threat remains real and it will be some years before feed compounders are free of it. The longer we can avoid any direct linkage between feed milling _practices_ and actual BSE cases, the more likely it is that serious damage can be avoided. ...
SEE full text ;
http://www.bseinquiry.gov.uk/files/yb/1995/08/24002001.pdf
like i said, and endless cycle of greed, i.e. FOR PROFIT ONLY $$$
USDA CERTIFIED DEAD STOCK DOWNER COW SCHOOL LUNCH PROGRAM LIST OF SCHOOLS AFFECTED STATE BY STATE (dead stock downers i.e. non-ambulatory, the most high risk for mad cow disease)
http://downercattle.blogspot.com/
TSS
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