October 27, 2009
Honourable Minister Gerry Ritz
Minister of Agriculture and Agri-Food Canada 930 Carling Ave Ottawa, ON K1A 0C5
Dear Minister Ritz,
We, as representatives of beef and dairy cattle and beef processing industry organizations, have appreciated the opportunity to speak with you several times with respect to the cost disadvantage of slaughtering cattle in Canada. The primary cause of this disadvantage is the cost of removing and disposing of specified risk materials (SRMs). A survey of Canadian slaughter facilities conducted this summer indicates that the average cost of complying with the 2007 federal SRM removal and disposal regulation is $31.70 per animal over 30 months old (OTM).
The Beef Value Chain Roundtable reviewed this matter at its September 15 meeting and made the following recommendation: “The Beef Value Chain Roundtable supports the findings of the Canadian Meat Council with regard to the costs associated in complying with the enhanced feed ban. The Roundtable asks Governments to promptly implement a plan to offset the costs associated with meeting the requirements of the enhanced feed ban. This recommendation would serve to be a transition measure only until a remedy is found to restore competitiveness.”
The undersigned organizations request that the Government of Canada immediately create an OTM Cattle SRM Disposal Compensation Program. Specifically, we request a payment of $31.70/head be made to abattoirs for every OTM animal slaughtered in Canada. Both federally and provincially inspected facilities should be eligible for this payment. With an estimated annual OTM slaughter of 750,000 head, the program would cost approximately $24 million per year.
The primary objective of any assistance must be to maintain OTM slaughter capacity in Canada. If we fail to achieve this objective, we will lose thousands of jobs throughout the nation, and Canadian beef and dairy cattle producers will be at the mercy of any disruptive US trade rules that may be introduced in the future. All the excellent work you are doing to re-establish market access for Canadian beef will be wasted if we lose the capacity to slaughter our own cattle in Canada. We are already seeing that with reduced OTM slaughter in Canada, beef imports have increased dramatically in 2009. Neither beef nor dairy cattle producers want to return to the pre-BSE practice where large numbers of Canadian OTM cattle went to the US for processing while large quantities of non-NAFTA beef were imported to satisfy Canada’s beef demand.
We request that this OTM Cattle SRM Disposal Compensation Program remain in effect until the SRM removal and disposal policies of Canada and the United States can be harmonized. As an industry, we are committed to work closely with your officials to reduce the volumes and costs of SRM removal. There are several critical actions, that when achieved, can have a significant impact on improving our competitive position with our American counterparts. But it is also widely recognized that any of these beneficial measures will take time to implement, and that immediate need for cash remains in the short term. We recommend that a review process be formalized to ensure these improvements are implemented and the OTM Cattle SRM Disposal Compensation Program can be adjusted when necessary.
In closing, we thank you for your recognition of this serious matter and we urge you to respond quickly. As we are now entering the peak OTM slaughter season, our request requires urgent attention to ensure that Canadian facilities can compete for their fair share of this business.
Brad Wildeman, President Canadian Cattlemen’s Association Jacques Laforge, President Dairy Farmers of Canada Laurent Pellerin, President Canadian Federation of Agriculture Brian Read, Chair - Beef Committee Canadian Meat Council Kevin Golding, President Canadian Renderers Association Michel Dessureault, President La Fédération des producteurs de bovins du Québec Serge Michel, Chairman of the board Levinoff-Colbex SEC Brian Nilsson, President XL Foods Shane Murphy, President Atlantic Beef Producers Dennis Laycraft, Industry Co-Chair Beef Value Chain Roundtable Scott Entz, Vice President and General Manager Cargill Beef
Other Priority Issues and Required Actions Competitiveness The top challenge facing the Canadian cattle industry today is that several factors are contributing to a lack of competitiveness in the cattle feeding and beef processing sectors. Left unchecked, greater numbers of cattle will be fed and slaughtered in the US and increasing quantities of beef will be imported into Canada. A high Canadian dollar exacerbates these problems necessitating swift action.
Promptly implement a plan to offset the cost of disposal of Specified Risk Materials (SRMs) as required by the enhanced feed ban. This would be a transitional measure until remedies are implemented to restore industry competitiveness. See coalition letter requesting a creation of an OTM Compensation Program .
Remove the prohibition on using SRM meat and bone meal as fertilizer as a way to restore value for the SRMs Traceability should not impede commerce. Pilot projects currently underway testing scanning equipment in auction marts need to be completed prior to proceeding. Regulating additional costs to producers will put industry at greater disadvantage. Implement 2008 Federal Election commitment to cut diesel excise tax from 4 cents to 2 cents per litre, Ensure Canada’s approval process for products (veterinary/pharmaceutical, pesticides, biologics, new forage and grain varieties, etc) are as or more efficient than our international competitors such as the United States and Australia. Ensure enforcement by regulators is commensurate with consequences of non-compliance (eg: fines for lost CCIA tags; high value meat removal around spinal cord). ...SNIP...END
FULL TEXT ;
> Remove the prohibition on using SRM meat and bone meal as fertilizer as a way to restore value for the SRMs<
13. Q: Can CMPAF be rendered for use as fertilizer?
A: This rule does not place any restrictions on the use of CMPAF as fertilizer.
MAMMALIAN MEAT AND BONE-MEAL AS FERTILISER ON AGRICULTURAL LAND
1. The Department for Environment, Food and Rural Affairs (Defra) has asked SEAC to consider a risk assessment (Annex A) entitled “Risk assessment of TSE related risks associated with the use of rendered Category 3 animal by-products (ABP) as fertiliser on non-pasture land” produced by the Veterinary Laboratories Agency.
2. In 2005, at its 87th meeting, SEAC considered (Annex B) a ‘release assessment’ which evaluated the amount of potential infectivity available in the soil of non-pasture land following the application of Category 3-derived1 fertiliser. In summary, the committee concluded:
• It was content with the approach used and assumptions made in the risk assessment.
• The assessment predicted that TSE infectivity levels on land as a result of the application of fertiliser would be extremely low. However, because of the likely heterogeneous nature of infectivity in fertiliser and the uneven spread of fertiliser, TSE infectivity levels might be higher in some geographical locations than predicted.
• Controls to ensure that Category 3 ABP are processed separately from Category 1 and Category 2 ABP2 be audited.
1 Category 3 is low risk material, most of which is fit for human consumption, but not intended for human consumption.
2 Categories 1 & 2 are the highest risk materials, animals with a suspected or confirmed TSE, Specified Risk Material, condemned meat, diseased animals etc. • A watching brief be kept on CWD and BARB cases to assess the possible persistence of the agent in the environment.
3. Domestic TSE legislation was then amended in 2006 to lift the ban on the application of Category 3-derived mammalian meat and bone meal (MMBM) as organic fertiliser and soil improvers (OFSI) on agricultural land. Also in 2006 EU Animal By-Products legislation was amended3 to permit application of OFSI to land in accordance with certain conditions. This change in EU legislation was underpinned by an EFSA Opinion of 3 March 2004 (Annex C).
4. The EU Animal By-Products Regulation (1774/2002) requires that the category 3-derived MMBM must have been submitted to “Method 1” rendering. Method 1 is the most stringent of the seven rendering methods permitted by the Regulation. The animal by-products must be reduced to a particle size of no greater than 50mm, heated to a core temperature of more than 133°C at 3 bar pressure (absolute) for at least 20 minutes without interruption. The EU ABP Regulation is now being renegotiated and Defra are considering whether it is appropriate to seek a relaxation of the requirement for Method 1 rendering. To this end Defra need an understanding of the difference in the risk of transmitting a TSE, as between the use of Method 1 and Method 7, which is potentially the least stringent method. This is because Method 7 does not prescribe any particle size, time, temperature or pressure standards on the processing of animal by-products but requires the processed product to comply with a microbiological standard set out in the Regulation. It can only be used for Category 3 animal by-products.
5. If there is a difference in risk in this context Defra would then consider whether it would be feasible to manage any increased risk resulting from the use of Method 7, for example the better labelling of the fertiliser or by reducing its palatability to animals.
6. In order to inform this consideration, Defra commissioned a full risk assessment to evaluate the danger to cattle and sheep of becoming infected with BSE and/or scrapie as a result of the change to the domestic TSE legislation in the use of rendered Category 3 ABP with regard to MMBM being converted into fertiliser and applied to nonpasture land. This new risk assessment, which SEAC is now invited to consider, represents a significant overhaul of the original assessment and includes additional analyses.
3 Regulation (EC) 181/2006 amended the ABP Regulation 1774/2002 as regards the use of organic fertilisers and soil improvers (except manure).
7. The main changes compared to the previous release assessment
• the values assigned to parameters within the release assessment have been amended to take account of an increase in scientific knowledge, legislative changes and the decline in disease incidence over time.
• account is taken of a case study investigating the palatability to ruminants of fertilisers applied to land.
• a new exposure assessment and a new dose response model are included.
8. The effects of each of the seven processing methods on TSE infectivity are not known, with the exception of limited experimental data regarding Method 1 as set out in the risk assessment. Due to the absence of such information, the risk assessment makes a number of assumptions in order to compare two scenarios based on the use of the processing methods at opposite ends of the range permitted in legislation: Method 1 and Method 7.
9. The main conclusions from the risk assessment are that the number of animals infected with a TSE disease annually, due to exposure to fertilizer produced from Category 3 ABP according to Method 1 is low (i.e. below one). Indeed, there is 90% certainty that the maximum number would be one new infection. The assessment concludes that when considering fertiliser produced by Method 7 the estimated mean number of new BSE new infections in cattle is 1.1, the number of new infections of scrapie is 47 and the number of new infections of sheep BSE is 0.04.
10. The risk assessment also considers what further investigations might help to reduce the uncertainty in the risk assessment and concludes that the following information would be helpful:
• The proportion of processed materials destined for fertiliser production.
• The average yearly livestock stocking density on grassland.
• The average depth of penetration of the fertiliser within the top soil upon application.
• The reduction rate in TSE infectivity due to processing into fertiliser.
• The proportion of scrapie that is masking sheep BSE disease.
• The probability that a scrapie infected sheep is slaughtered for human consumption in GB.
11. SEAC is asked to:
• consider the scientific validity of the methodology used, and the assumptions made, in the new risk assessment and to comment on its findings; and
• whether any other information, other than that suggested above, would be likely to improve the uncertainties associated with the assumptions made in the risk assessment.
A copy of “Risk assessment of TSE related risks associated with the use of rendered Category 3 animal by-products as fertiliser on non-pasture land”.
Paper from SEAC
Prions Adhere to Soil Minerals and Remain Infectious
Christopher J. Johnson1,2, Kristen E. Phillips3, Peter T. Schramm3, Debbie McKenzie2, Judd M. Aiken1,2, Joel A. Pedersen3,4*
1 Program in Cellular and Molecular Biology, University of Wisconsin Madison, Madison, Wisconsin, United States of America, 2 Department of Animal Health and Biomedical Sciences, School of Veterinary Medicine, University of Wisconsin Madison, Madison, Wisconsin, United States of America, 3 Molecular and Environmental Toxicology Center, University of Wisconsin Madison, Madison, Wisconsin, United States of America, 4 Department of Soil Science, University of Wisconsin Madison, Madison, Wisconsin, United States of America
Abstract Top An unidentified environmental reservoir of infectivity contributes to the natural transmission of prion diseases (transmissible spongiform encephalopathies [TSEs]) in sheep, deer, and elk. Prion infectivity may enter soil environments via shedding from diseased animals and decomposition of infected carcasses. Burial of TSE-infected cattle, sheep, and deer as a means of disposal has resulted in unintentional introduction of prions into subsurface environments. We examined the potential for soil to serve as a TSE reservoir by studying the interaction of the disease-associated prion protein (PrPSc) with common soil minerals. In this study, we demonstrated substantial PrPSc adsorption to two clay minerals, quartz, and four whole soil samples. We quantified the PrPSc-binding capacities of each mineral. Furthermore, we observed that PrPSc desorbed from montmorillonite clay was cleaved at an N-terminal site and the interaction between PrPSc and Mte was strong, making desorption of the protein difficult. Despite cleavage and avid binding, PrPSc bound to Mte remained infectious. Results from our study suggest that PrPSc released into soil environments may be preserved in a bioavailable form, perpetuating prion disease epizootics and exposing other species to the infectious agent.
Oral Transmissibility of Prion Disease Is Enhanced by Binding to Soil Particles
Christopher J. Johnson1,2, Joel A. Pedersen3, Rick J. Chappell4, Debbie McKenzie2, Judd M. Aiken1,2*
1 Program in Cellular and Molecular Biology, University of Wisconsin-Madison, Madison, Wisconsin, United States of America, 2 Department of Comparative Biosciences, School of Veterinary Medicine, University of Wisconsin-Madison, Madison, Wisconsin, United States of America, 3 Department of Soil Science and Molecular and Environmental Toxicology Center, University of Wisconsin-Madison, Madison, Wisconsin, United States of America, 4 Biostatistics and Medical Informatics, University of Wisconsin Medical School, Madison, Wisconsin, United States of America
Soil may serve as an environmental reservoir for prion infectivity and contribute to the horizontal transmission of prion diseases (transmissible spongiform encephalopathies [TSEs]) of sheep, deer, and elk. TSE infectivity can persist in soil for years, and we previously demonstrated that the disease-associated form of the prion protein binds to soil particles and prions adsorbed to the common soil mineral montmorillonite (Mte) retain infectivity following intracerebral inoculation. Here, we assess the oral infectivity of Mte- and soil-bound prions. We establish that prions bound to Mte are orally bioavailable, and that, unexpectedly, binding to Mte significantly enhances disease penetrance and reduces the incubation period relative to unbound agent. Cox proportional hazards modeling revealed that across the doses of TSE agent tested, Mte increased the effective infectious titer by a factor of 680 relative to unbound agent. Oral exposure to Mte-associated prions led to TSE development in experimental animals even at doses too low to produce clinical symptoms in the absence of the mineral. We tested the oral infectivity of prions bound to three whole soils differing in texture, mineralogy, and organic carbon content and found soil- bound prions to be orally infectious. Two of the three soils increased oral transmission of disease, and the infectivity of agent bound to the third organic carbon-rich soil was equivalent to that of unbound agent. Enhanced transmissibility of soil-bound prions may explain the environmental spread of some TSEs despite the presumably low levels shed into the environment. Association of prions with inorganic microparticles represents a novel means by which their oral transmission is enhanced relative to unbound agent.
Discussion These experiments address the critical question of whether soil particlebound prions are infectious by an environmentally relevant exposure route, namely, oral ingestion. Oral infectivity of soil particlebound prions is a conditio sine qua non for soil to serve as an environmental reservoir for TSE agent. The maintenance of infectivity and enhanced transmissibility when TSE agent is bound to the common soil mineral Mte is remarkable given the avidity of the PrPTSEMte interaction . One might expect the avid interaction of PrPTSE with Mte to result in the mineral serving as a sink, rather than a reservoir, for TSE infectivity. Our results demonstrate this may not be the case. Furthermore, sorption of prions to complex whole soils did not diminish bioavailability, and in two of three cases promoted disease transmission by the oral route of exposure. While extrapolation of these results to environmental conditions must be made with care, prion sorption to soil particles clearly has the potential to increase disease transmission via the oral route and contribute to the maintenance of TSE epizootics.
Two of three tested soils potentiated oral prion disease transmission. The reason for increased oral transmissibility associated with some, but not all, of the soils remains to be elucidated. One possibility is that components responsible for enhancing oral transmissibility were present at higher levels in the Elliot and Bluestem soils than in the Dodge soil. The major difference between the Dodge soil and the other two soils was the extremely high natural organic matter content of the former (34%, ). The Dodge and Elliot soils contained similar levels of mixed-layer illite/smectite, although the contribution of smectite layers was higher in the Dodge soil (14%16%, ). The organic matter present in the Dodge soil may have obstructed access of PrPTSE to sorption sites on smectite (or other mineral) surfaces.
The mechanism by which Mte or other soil components enhances the oral transmissibility of particle-bound prions remains to be clarified. Aluminosilicate minerals such as Mte do not provoke inflammation of the intestinal lining . Although such an effect is conceivable for whole soils, soil ingestion is common in ruminants and other mammals . Prion binding to Mte or other soil components may partially protect PrPTSE from denaturation or proteolysis in the digestive tract [22,40] allowing more disease agent to be taken up from the gut than would otherwise be the case. Adsorption of PrPTSE to soil or soil minerals may alter the aggregation state of the protein, shifting the size distribution toward more infectious prion protein particles, thereby increasing the specific titer (i.e., infectious units per mass of protein) . In the intestine, PrPTSE complexed with soil particles may be more readily sampled, endocytosed (e.g., at Peyer's patches), or persorbed than unbound prions. Aluminosilicate (as well as titanium dioxide, starch, and silica) microparticles, similar in size to the Mte used in our experiments, readily undergo endocytotic and persorptive uptake in the small intestine . Enhanced translocation of the infectious agent from the gut lumen into the body may be responsible for the observed increase in transmission efficiency.
Survival analysis indicated that when bound to Mte, prions from both BH and purified PrPTSE preparations were more orally infectious than unbound agent. Mte addition influenced the effective titer of infected BH to a lesser extent than purified PrPTSE. Several nonmutually exclusive factors may explain this result: (1) other macromolecules present in BH (e.g., lipids, nucleic acids, other proteins) compete with PrPTSE for Mte binding sites; (2) prion protein is more aggregated in the purified PrPTSE preparation than in BH , and sorption to Mte reduces PrPTSE aggregate size, increasing specific titer ; and (3) sorption of macromolecules present in BH to Mte influences mineral particle uptake in the gut by altering surface charge or size, whereas the approximately 1,000-fold lower total protein concentration in purified PrPTSE preparations did not produce this effect.
We previously showed that other inorganic microparticles (kaolinite and silicon dioxide) also bind PrPTSE . All three types of microparticles are widely used food additives and are typically listed as bentonite (Mte), kaolin (kaolinite), and silica (silicon dioxide). Microparticles are increasingly included in Western diets. Dietary microparticles are typically inert and considered safe for consumption by themselves, do not cause inflammatory responses or other pathologies, even with chronic consumption, and are often sampled in the gut and transferred from the intestinal lumen to lymphoid tissue [39,46,47]. Our data suggest that the binding of PrPTSE to dietary microparticles has the potential to enhance oral prion disease transmission and warrants further investigation.
In conclusion, our results provide compelling support for the hypothesis that soil serves as a biologically relevant reservoir of TSE infectivity. Our data are intriguing in light of reports that naïve animals can contract TSEs following exposure to presumably low doses of agent in the environment [5,79]. We find that Mte enhances the likelihood of TSE manifestation in cases that would otherwise remain subclinical (Figure 3B and 3C), and that prions bound to soil are orally infectious (Figure 5). Our results demonstrate that adsorption of TSE agent to inorganic microparticles and certain soils alter transmission efficiency via the oral route of exposure.
snip...full text is here:
PLoS ONE. 2008; 3(8): e2969. Published online 2008 August 13. doi: 10.1371/journal.pone.0002969. PMCID: PMC2493038
Copyright This is an open-access article distributed under the terms of the Creative Commons Public Domain declaration which stipulates that, once placed in the public domain, this work may be freely reproduced, distributed, transmitted, modified, built upon, or otherwise used by anyone for any lawful purpose.
Prion Infected Meat-and-Bone Meal Is Still Infectious after Biodiesel Production
Cathrin E. Bruederle,1* Robert M. Hnasko,1 Thomas Kraemer,2 Rafael A. Garcia,3 Michael J. Haas,3 William N. Marmer,3 and John Mark Carter1 1USDA-ARS WRRC, Foodborne Contaminants Research Unit, Albany, California, United States of America 2Forensic Toxicology, Institute of Legal Medicine, Saarland University, Homburg/Saar, Germany 3USDA-ARS ERRC, Fats, Oils and Animal Coproducts Research Unit, Wyndmoor, Pennsylvania, United States of America Neil Mabbott, EditorUniversity of Edinburgh, United Kingdom * E-mail: email@example.comConceived and designed the experiments: CEB RMH WNM JMC. Performed the experiments: CEB RMH TK. Analyzed the data: CEB TK JMC. Contributed reagents/materials/analysis tools: CEB RMH TK RAG MJH JMC. Wrote the paper: CEB. Received April 21, 2008; Accepted July 24, 2008. Other Sections? AbstractIntroductionResultsDiscussionMaterials and MethodsSupporting InformationReferencesAbstract The epidemic of bovine spongiform encephalopathy (BSE) has led to a world-wide drop in the market for beef by-products, such as Meat-and-Bone Meal (MBM), a fat-containing but mainly proteinaceaous product traditionally used as an animal feed supplement. While normal rendering is insufficient, the production of biodiesel from MBM has been suggested to destroy infectivity from transmissible spongiform encephalopathies (TSEs). In addition to producing fuel, this method simultaneously generates a nutritious solid residue. In our study we produced biodiesel from MBM under defined conditions using a modified form of alkaline methanolysis. We evaluated the presence of prion in the three resulting phases of the biodiesel reaction (Biodiesel, Glycerol and Solid Residue) in vitro and in vivo. Analysis of the reaction products from 263K scrapie infected MBM led to no detectable immunoreactivity by Western Blot. Importantly, and in contrast to the biochemical results the solid MBM residue from the reaction retained infectivity when tested in an animal bioassay. Histochemical analysis of hamster brains inoculated with the solid residue showed typical spongiform degeneration and vacuolation. Re-inoculation of these brains into a new cohort of hamsters led to onset of clinical scrapie symptoms within 75 days, suggesting that the specific infectivity of the prion protein was not changed during the biodiesel process. The biodiesel reaction cannot be considered a viable prion decontamination method for MBM, although we observed increased survival time of hamsters and reduced infectivity greater than 6 log orders in the solid MBM residue. Furthermore, results from our study compare for the first time prion detection by Western Blot versus an infectivity bioassay for analysis of biodiesel reaction products. We could show that biochemical analysis alone is insufficient for detection of prion infectivity after a biodiesel process.
Sunday, April 12, 2009
CWD UPDATE Infection Studies in Two Species of Non-Human Primates and one Environmental reservoir infectivity study and evidence of two strains
DEPENDS ALSO what were calling srm's now?
WITH the atypical BSE's, ARS said they were going to update and possibly enhance SRM regulations as the transmission studies were due out in 2009 i.e. (h-BSE, and l-BSE) ??
Animal fats/oils certified with maximum insoluble impurities of less than 0.15% in weight (bovine origin animal fats imported for animal consumption must also come from animals that passed FSIS inspection, and must not be derived from the head, distal ileum, spinal cord, or vertebral column of cattle of any age);
2. Annex XI, Part A is amended as follows:
(a) point 1(a)(i) is replaced by the following:
"(i) the skull excluding the mandible and including the brain and eyes, and the spinal cord of bovine animals aged over 12 months, the vertebral column excluding the vertebrae of the tail, the spinous and transverse processes of the cervical, thoracic and lumbar vertebrae and the median sacral crest and wings of the sacrum, but including the dorsal root ganglia of bovine animals aged over 24 months, and the tonsils, the intestines from the duodenum to the rectum and the mesentery of bovine animals of all ages;"
HOWEVER, as with other non-effective BSE regulations put forth by the O.I.E., SRM regulations are being watered down now by AGE. ...
The sensitivity of PrPTSE detection is still lower than certain bioassays: failure to detect PrPTSE does not guarantee absence of infectivity in a tissue. Opinion on the likelihood of the infectivity in SRM derived from cattle at different age groups estimated by back calculation modelling...
Tuesday, November 10, 2009
Surveillance On the Bovine Spongiform Encephalopathy and rabies in Taiwan and USA
Monday, October 19, 2009
Atypical BSE, BSE, and other human and animal TSE in North America Update October 19, 2009
2009 UPDATE ON ALABAMA AND TEXAS MAD COWS 2005 and 2006
Monday, October 26, 2009
MAD COW DISEASE, AND U.S. BEEF TRADE
MAD COW DISEASE, CJD, TSE, SOUND SCIENCE, COMMERCE, AND SELLING YOUR SOUL TO THE DEVIL
IN A NUT SHELL ;
(Adopted by the International Committee of the OIE on 23 May 2006)
11. Information published by the OIE is derived from appropriate declarations made by the official Veterinary Services of Member Countries. The OIE is not responsible for inaccurate publication of country disease status based on inaccurate information or changes in epidemiological status or other significant events that were not promptly reported to the Central Bureau,
Docket APHIS-2006-0026 Docket Title Bovine Spongiform Encephalopathy; Animal Identification and Importation of Commodities Docket Type Rulemaking Document APHIS-2006-0026-0001 Document Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions, Identification of Ruminants and Processing and Importation of Commodities Public Submission APHIS-2006-0026-0012 Public Submission Title Comment from Terry S Singletary
Docket APHIS-2006-0041 Docket Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived from Bovines Commodities Docket Type Rulemaking Document APHIS-2006-0041-0001 Document Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived From Bovines Public Submission APHIS-2006-0041-0028 Public Submission Title Comment from Terry S Singletary
Comment 2006-2007 USA AND OIE POISONING GLOBE WITH BSE MRR POLICY
THE USA is in a most unique situation, one of unknown circumstances with human and animal TSE. THE USA has the most documented TSE in different species to date, with substrains growing in those species (BSE/BASE in cattle and CWD in deer and elk, there is evidence here with different strains), and we know that sheep scrapie has over 20 strains of the typical scrapie with atypical scrapie documented and also BSE is very likely to have passed to sheep. all of which have been rendered and fed back to animals for human and animal consumption, a frightening scenario. WE do not know the outcome, and to play with human life around the globe with the very likely TSE tainted products from the USA, in my opinion is like playing Russian roulette, of long duration, with potential long and enduring consequences, of which once done, cannot be undone. These are the facts as I have come to know through daily and extensive research of TSE over 9 years, since 12/14/97. I do not pretend to have all the answers, but i do know to continue to believe in the ukbsenvcjd only theory of transmission to humans of only this one strain from only this one TSE from only this one part of the globe, will only lead to further failures, and needless exposure to humans from all strains of TSE, and possibly many more needless deaths from TSE via a multitude of proven routes and sources via many studies with primates and rodents and other species.
MY personal belief, since you ask, is that not only the Canadian border, but the USA border, and the Mexican border should be sealed up tighter than a drum for exporting there TSE tainted products, until a validated, 100% sensitive test is available, and all animals for human and animal consumption are tested. all we are doing is the exact same thing the UK did with there mad cow poisoning when they exported it all over the globe, all the while knowing what they were doing. this BSE MRR policy is nothing more than a legal tool to do just exactly what the UK did, thanks to the OIE and GW, it's legal now. and they executed Saddam for poisoning ???
go figure. ...
Docket APHIS-2006-0041 Docket Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived from Bovines Commodities Docket Type Rulemaking Document APHIS-2006-0041-0001 Document Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived From Bovines Public Submission APHIS-2006-0041-0028.1 Public Submission Title Attachment to Singletary comment
January 28, 2007
I would kindly like to submit the following to ;
BSE; MRR; IMPORTATION OF LIVE BOVINES AND PRODUCTS DERIVED FROM BOVINES [Docket No. APHIS-2006-0041] RIN 0579-AC01
Thursday, November 12, 2009
BSE FEED RECALL Misbranding of product by partial label removal to hide original source of materials 2009
HUMAN and ANIMAL TSE Classifications i.e. mad cow disease and the UKBSEnvCJD only theory