U.S. Violates World Health Organization Guidelines for Mad Cow Disease: A Comparison of North American and European Safeguards
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U.S. Violates World Health Organization Guidelines for Mad Cow Disease:
A Comparison of North American and European Safeguards


Updated July 15, 2003 by Michael Greger, M.D. for the Organic 
Consumers Association

The National Cattlemen's Beef Association describes government and industry efforts to safeguard the American public from mad cow disease as "swift," "decisive" and "aggressive."[1] The US Secretary of Agriculture adds "diligent,"[2] "vigilant" and "strong."[3] The world's authority on these diseases disagrees.

Dr. Stanley Prusiner is the scientist who won the Nobel Prize in Medicine for his discovery of prions, the infectious agents thought to cause bovine spongiform encephalopathy (BSE), or mad cow disease. The word Dr. Prusiner uses to describe the efforts of the U.S. government and the cattle industry is "terrible."[4] What are these "stringent protective measures"[5] that the Cattlemen's Association is talking about, and how do they compare to global standards and internationally recognized guidelines?

In 1996, in response to the revelation that young people in Britain were dying from variant Creutzfeldt Jakob Disease (vCJD), the human equivalent of mad cow disease, the World Health Organization (WHO) issued seven "Recommendations." Numbers 5-7 were observations and/or recommendations for further research. The first four recommendations, however, were concrete proscriptions to reduce the likelihood of mad cow disease spreading to human populations.[6] To this day, the United States government continues to violate each and every one of these four guidelines.

#1. Stop Feeding Infected Animals to Other Animals

The number one recommendation of the World Health Organization was that no "part or product" of any animal showing signs of a transmissible spongiform encephalopathy (TSE), or mad cow-like disease, should be fed to any animal.[7] "All countries," the guideline reads, "must ensure the slaughter and safe disposal of TSE-affected animals so that TSE infectivity cannot enter any food chain."[8] Yet, in the U.S., it remains legal to feed deer and elk known to be infected with a transmissible spongiform encephalopathy called chronic wasting disease to livestock such as pigs and chickens.[9]

Although science has yet to investigate whether pigs and chickens are susceptible to "mad deer" prions, there is a concern that even if these animals don't develop clinical symptoms of the disease, they could become so-called "silent carriers." Dr. Richard Race is a Senior Investigator with the National Institutes of Health.[10] In 2001, he published a landmark paper showing that even species thought to be resistant to particular strains of prions could invisibly harbor the disease and pass it on to other animals.[11] He also found that these deadly prions were somehow able to adapt to the new species, becoming even more lethal and replicating faster and faster.[12]

At a 2002 symposium on chronic wasting disease, Dr. Race expressed concern that U.S. cattle could be invisibly harboring chronic wasting disease and passing it on to humans.[13] The reason Dr. Race is so concerned is because chronic wasting disease seems unique in that it's the only prion disease thought to be spread by casual contact[14] between deer through exposure to, or exchange of, bodily fluids such as saliva.[15] And, the best available research suggests that CWD prions can infect humans as well, perhaps even as readily as mad cow disease can.[16] Dr. Race wonders if people could become silent carriers as well.[17] And, "If these people are subclinical carriers," Race asked, "do they represent a threat to other people?"[18] All transmissible spongiform encephalopathies are invariably fatal.[19] Consumer advocates argue that these prions should not be allowed to enter into the food chain.[20]

In May 2003, the Food and Drug Administration finally drafted up proposed voluntary "suggestions" for the rendering industry, recommending that deer and elk infected with chronic wasting disease, or at high risk for the disease, be excluded from animal feed.[21] However, even if this proposal is enacted, it represents only non-binding, non-enforceable "guidance" recommendations for the industry. The FDA made these same kinds of "guidance" recommendations to pharmaceutical companies over a decade ago, discouraging the use of bovine-derived materials from countries with mad cow disease in manufacturing their vaccines,[22] only to learn 7 years later that major pharmaceutical manufacturers simply ignored the guidelines.[23]

Europe's Scientific Steering Committee met in 2003 and agreed that the United States should comply with the World Health Organization guidelines and ban the feeding of animals infected with chronic wasting disease to other animals.[24] The United States seems to remain the only country that knowingly allows prion infected animals to be fed to other animals, including those destined for the dinner plate.

#2. All Countries Need to Establish Adequate Testing and Surveillance

The World Health Organization's second guideline was for all countries to establish adequate testing and surveillance for mad cow disease according to the standards set down by the Office International des Epizooties (OIE), World Animal Health Organization.[25] The beef industry and the USDA claim that the level of U.S. testing "far exceeds" these international testing standards.[26] If one goes to the USDA website and clicks on "for the latest info on BSE Surveillance," for example, one can read that "OIE recommends a surveillance level of 433 samples per year."[27] And that, in 2002 alone, the U.S. tested almost 20,000 cattle for the disease.[28] But if one reads the actual recommendations,[29] one can see that the USDA isn't telling the whole story.

The oft-cited "433" figure[30-32] is indeed found in Article 3.8.4.2. of the OIE's International Animal Health Code.[33] But it just represents the required minimum number of cattle showing suspicious signs that should be examined each year.[34] For examples, these are cows that show "excitability," or "persistent kicking when milked."[35] The Animal Health Code then directly goes on to recommend, in Article 3.8.4.3, that "Cattle that have died or have been killed for reasons other than routine slaughter (including 'fallen' stock and emergency slaughter) should be examined."[36] This is where the United States (and Canada) fall seriously short.

The combination of these two populations, "fallen stock and emergency slaughter cattle," is essentially equivalent to the U.S. nonambulatory, or "downer" cattle population.[37] Every year, an estimated 195,000[38] to a million[39] cattle collapse in the U.S. for largely unknown reasons and are too sick or injured to rise.[40] Even though these downed animals are not even fit enough to stand, an investigation of USDA slaughterhouse records showed that most of them are still ruled fit enough for human consumption.[41] Quoting from a USDA document released in 2002, "Thus, if BSE were present in the U.S., downer cattle infected with BSE could potentially be offered for slaughter and, if the clinical signs of the disease were not detected, pass ante-mortem inspection. These cattle could then be slaughtered for human food."[42]

Based on findings in Europe,[43] and evidence of at least a rare form of mad cow disease already striking downer cows in the U.S.,[44] downer cattle are considered to be a particularly high risk population. The OIE recommends they be tested for mad cow disease.[45] Over the past ten or so years, though, the USDA has tested less than 2% of the downer cattle in United States.[46] And, those tests were almost exclusively limited to animals that were sent to slaughter.[47] The U.S. tests even fewer of the downer cattle on farms and ranches that never make it to the slaughterhouse, considered the single highest risk cattle population in the United States.[48] These dead, dying or downed cattle can still then be fed to other livestock.[49] It's no wonder that Dr. Prusiner, the world's expert on prion disease, describes the number of tests done by USDA as "appalling."[50]

When asked what level of testing in the U.S. he'd be comfortable with, Prusiner replied, ""Well, I'd like to see every downer cattle, every fallen cow tested. That's a beginning. And then after that, at some point, I'd like to see every cow tested, just as they do in Japan. Every single cow is being tested in Japan."[51] In Europe, 100% of all adult downer cattle are tested,[52] as well as 100% of all healthy cows over a certain age that are slaughtered for human consumption.[53] If the animal isn't tested, then by law, the animal must be destroyed.[54] July, 2003, an amendment was brought before the House that would have banned the sale downed animals for human food in the United States. The amendment lost by two votes.[292]

The United States and Europe have similar cattle populations,[55] yet Europe tests almost a million cattle every month.[56] France, which has only a fraction of the U.S. cattle population, tests more cattle in a single week then the U.S. has tested in a decade.[57] According to Europe's latest annual report, Europe is testing cattle at a rate of almost two thousand times that of the United States.[58] Yes, the beef industry argues, but they have the disease, and we don't.

The beef industry's position is an illustration of circular reasoning: We don't rigorously test, because we haven't found any cases.[59] In the Summer of 2000, the Scientific Steering Committee of the European Union, an internationally recognized group of BSE experts, conducted and published elaborate risk assessments for a wide variety of countries.[60] They concluded that the risk status of a country like Austria ("Unlikely, but not excluded"),[61] was identical to that of the United States.[62] This didn't stop Austria, though, from learning from the rest of Europe's example and testing all cattle slaughtered for human consumption over a certain age.[63] Though they too declared their country "BSE-free,"[64] within months of initiating their testing program they discovered their first case.[65]

The meat industry, however, opposes more testing.[66] Dan Murphy, the spokesperson for the American Meat Institute, responded to criticism by stating, "Further testing would cost taxpayers more money, could slow production and would yield no benefits."[67] He reiterated, "It's a matter of asking the question, 'Where would the benefit be?'"[68] I'm sure Don Simms has an answer for Mr. Murphy. His teenage son lies twitching in a hospital bed in Belfast. Jonathan Simms, once healthy, strong and athletic, is in a coma, wasting away on the verge of death from mad cow disease, like so many dozens of teens before him.[69]

Dan Murphy argues that the U.S. government "already tests the animals that are at risk."[70] He likened expanding the testing program to a larger number of animals "to testing elementary students for Alzheimer's disease."[71] Or "like testing children for breast cancer," the President of the American Feed Industry Association adds. "It simply makes no sense."[289] But again, the United States tests only a minuscule percentage of the animals at most risk--the downer cattle.[72]

Beyond high risk populations, though, Dan Murphy is correct when he implies that the U.S. cattle population is younger than that in Britain. Less than half of American dairy cows make it past their fourth birthday, before being retired into hamburger meat.[73] In fact the majority of U.S. cattle are slaughtered before they reach age two.[74] While this may mean that the prion load in an infected animal may be less at slaughter (since prions accumulate with age), it also means mad cow disease may be harder to detect in the United States.[75]

On that fated Oprah show, the spokesperson for the National Cattlemen's Beef Industry assured consumers that no animal could ever enter a U.S. slaughterhouse displaying BSE symptoms.[76] As the European Commission's risk assessment of the U.S. points out, though, the "young age at slaughter makes it unlikely that fully developed clinical cases would occur (and could be detected)..."[77] Younger cattle could be infected and infectious, but be slaughtered for human consumption before they started showing symptoms.[78] In fact, that first case of mad cow disease in Austria was detected in a cow who presented no clinical signs.[79] The only reason that the infected Austrian cow was prevented from entering the human food supply is because, even though they had no recorded cases[80] and even though the country was deemed as low risk as the United States,[81] Austria instituted a surveillance program that tested every cow slaughtered for human food over 30 months of age.[82] The chief reason that the present mad cow surveillance program has not confirmed cases in the U.S. could be because the surveillance program is inadequate.[83]

Another country that was ruled just as unlikely as the United States to have mad cow disease was Canada.[84] Saying Canada has mad cow disease is not far from saying the United States does, because the cattle industries of both countries are fully integrated across an open border.[85] Every year, the U.S. imports over a million head of cattle[86] and billions of pounds of beef from Canada.[87] How can the U.S. still call itself BSE-free when over three quarters[88] of Canadian cattle exports end up in the United States? Mad cow disease has been detected in North America.

Dr. Bruno Oesch of Zurich University recently told the BBC that US consumers may well have been eating infected beef for some time now.[89] The New Scientist, a weekly British science digest, reports that, based on the Canadian case, it is "likely" that the mad cow disease is also present in the United States.[90] So the question of whether or not the U.S. had in the past been meeting international testing standards for BSE-free countries may now be moot. Now that mad cow disease has been found in a downer cow in North America, is the USDA drafting plans to at least step up its surveillance of downer cattle? According to a spokesperson for the USDA, "at the moment, no changes [in the U.S. testing program] are being discussed."[91]

#3. Stop Feeding Bovine Brains, Eyes, Spinal Cords or Intestines to People or Livestock

The third key recommendation of the World Health Organization is that "Countries should not permit tissues that are likely to contain the BSE agent to enter any food chain, human or animal."[92] Basically, this means excluding cattle brains, eyes, spinal cord and intestine (from small intestine to rectum) from the human food supply, and from all animal feed.[93] Unfortunately, the U.S. still feeds those potentially risky tissues to people, pigs, pets and poultry.

High risk tissues in human food

Although beef brains, guts, eyes and spinal cords are available to consumers as "variety meats," they are labeled as such and therefore represent only a small fraction of the American public's exposure to these organs.[94] People are more likely to consume potentially infectious tissues such as spinal cord disguised within all-American favorites, like hot dogs and hamburgers.

After a cow is slaughtered and the standard cuts of beef removed, one is left with a bloody skeleton with a few scraps of meat still attached. To recover any last shreds of meat, the bones, prebroken or whole, may be placed in a giant vice-like device that crushes the carcass into bone "cakes."[95] Out through a sieve at the bottom runs a "batter-like"[96] paste of "spread-like consistency" referred to as mechanically separated meat.[97] The potentially highly infectious spinal cord and fluid may be forced out of the backbone and spewed in the final product.[98] Mechanically separated beef has been "used as a meat ingredient in the formulation of quality meat food products"[99] in the United States since the 1970's.[100] Examples of such "quality meat food products" include hot dogs, sausages and burgers.[101] By law, hot dogs can contain up to 20% of this mechanically separated beef.[102]

Although food containing mechanically separated beef must be labeled as such, there are no labels on food in restaurants.[103] So people could be exposed to spinal cord tissue in hot dogs, sausages, hamburgers, and ground meat products when dining out.[104] Although Europe heeded the World Health Organization's warnings and banned such meat recovery systems years ago, these devices remain one of the best opportunities for prion-infected tissues to enter the human food supply in North America.[105]

In 1994, meat processors began using a new technology, called advanced meat recovery (AMR), to help "increase yields and profitability."[106] These systems also extrude meat from the remains of the carcass under pressure, but without crushing the bones.[107] The American Meat Institute describes the process: "Just as fruit processors use machines to remove fruit from peels thoroughly and efficiently, meat companies use similar equipment to remove meat from some hard to trim bones."[108]

The end-product varies from a ground beef-like texture to the consistency of thick tomato sauce.[109] Prior to 1994, only cattle skeletal muscle, tongue, diaphragm, heart, and esophagus could be labeled as beef.[110] But by the end of that year, the USDA had already amended the definition of "meat" to include the product of advanced meat recovery machinery.[111] This meant that unlike mechanically separated meat, AMR meat was considered 100% beef and could be labeled as such.[112] With no special labeling requirements, adoption of AMR machinery spread rapidly throughout the industry, largely replacing mechanical separation equipment.[113]

Today, the majority of cattle are now processed using AMR.[114] Over twenty thousand tons of AMR beef is produced every year in the U.S., valued at over $100 million.[115] AMR beef typically ends up as a hidden ingredient in hamburgers, hot dogs, sausages, and beef jerky, as well as part of ground beef in meatballs, pizza toppings and taco fillings.[116] The danger, once again, is that if the spinal cord isn't removed before entering one of these machines, it is bound to be incorporated into the meat that is produced.[117]

Companies are supposed to remove the animals' brains and spinal cords before processing the carcasses through the AMR machinery, but getting out all of the spinal cord can be challenging. "It requires special tools and skills," says Glenn Schmidt, a meat scientist at Colorado State University. "The workers have to reach down to the neck region of the carcass to remove the spinal cord by scraping or suction, and sometimes they don't get all of it."[118]

In 1997, the consumer advocacy organization Public Citizen obtained USDA inspection records through the Freedom of Information Act showing that a significant percentage of AMR samples were turning up contaminated with central nervous system (CNS) tissue (brain or spinal cord).[119] Instead of simply requiring that spinal columns be removed from carcasses before being placed in advanced meat recovery systems, the USDA responded by merely directing its inspectors to continue testing samples of AMR meat for the presence of central nervous tissue.[120]

Despite their promise to initiate testing, the USDA took fewer than 60 samples over the next 3 years, yet still found spinal cord in a number of them.[121] The first major study of AMR meat was published in 2001.[122] Colorado State University researchers found that "well over 50%" of the samples of AMR beef from neck bones were contaminated with CNS tissue.[122] Then they went to 7 major suppliers of large fast food chains across the country to sample hamburger patties. Six out of seven suppliers had detectable CNS tissue in their burgers.[123]

The USDA again responded only with promises to do more testing.[124] The results of the USDA's tests were made public in 2002.[125] Eighty-eight percent of the meat processors (30 out of 34) were producing AMR beef which contained unacceptable nervous tissue, and almost all of the samples (96.5%) contained bone marrow,[126] which may also be infectious.[127]

In 2001, the World Health Organization, in consultation with the World Animal Health Organization and the Food and Agriculture Organization of the United Nations, reiterated the need for countries to remove and destroy all tissues proven capable of transmitting mad cow disease, such as spinal cord.[128] And, the only way to guarantee that AMR beef, or mechanically separated "beef," is free of spinal cord is to require meat processors to remove the entire spinal column before sending cattle carcasses through their machinery.[129] So that year, the consumer advocacy group Center for Science in the Public Interest (CSPI) petitioned the USDA to do just that.[130] The petition was supported by the American Public Health Association, the Consumer Federation of America, the Government Accountability Project, the National Consumers League, and Safe Tables Our Priority.[131]

The petition was opposed by the National Cattlemen's Beef Association,[132] the National Renderers Association,[133] the National Meat Association,[134], the Pork Producers Council, the sheep industry, the milk producers, the Turkey Federation, and eight other industry trade groups.[135] After all, about 50 percent of AMR meat comes from the neck bones and spine which contain the spinal cord.[136] U.S. meat industry analysts claim that any public health measure to remove these bones would simply be too costly for the industry.[137]

The meat industry has invested at least $40 million in AMR machines since their introduction in 1994, some of which that can process 9,000 lbs. of bones per hour.[138] Industry analysts place the final figure of complying with any proposed USDA regulation that bans neck bones and backbones at close to $200 million dollars.[138] The European Commission considers the removal of cattle brains, eyes, spinal cord and intestines from the human food supply as "the single biggest contribution that can be made to reducing the risk to humans."[139] Rather than learning from the outbreak in Europe though, the U.S. livestock industry seems to oppose even the most minimal tightening of U.S. feed regulations.[140]

The meat industry argues that voluntary compliance is enough.[141] Seven years of testing by USDA inspectors, however, has demonstrated otherwise.[142] This same inability to rely on industry efforts was discovered in Britain. British meat processors also weren't able to completely remove the spinal cord, so the law was changed to simply remove the entire spine prior to processing.[143]

However, here in the United States, the USDA continues to allow tissues in the American beef supply which are so potentially dangerous that the Food and Drug Administration has excluded them from cattle feed.[144] As CSPI's Director of Food Safety put it, "U.S. cattle aren't allowed to eat cattle spinal cord - and neither should people," especially children--AMR beef is still allowed in the National School Lunch Program.[145] Thanks to CSPI,[146] at least AMR beef from downer cattle is now excluded from the school lunch program.[147] And, for years the government has excluded mechanically separated meat from baby food, but only because the product might mottle an infant's teeth as a result of increased fluoride intake[148] from all the crushed bone particles that get extruded into the paste.[149]

And, even if Americans just stick to steak, they may not be shielded from risk. The "T" in a T-bone steak is a vertebra from the animal's spinal column, and as such may contain a section of the actual spinal cord.[150] Other potentially contaminated cuts include porterhouse, standing rib roast, prime rib with bone, bone-in rib steak, and (if they contain bone) chuck blade roast and loin.[151] These cuts may include spinal cord tissue and/or so-called dorsal root ganglia, swellings of nerve roots coming into the meat from the spinal cord which have been proven to be infectious as well.[152] This concern has led the FDA to consider banning the incorporation of "plate waste" from restaurants into cattle feed.[290] The American Feed Industry Associations's Rex Runyon defends the current exemption of plate scrapings from the 1997 feed regulations: "How can you tell the consumer 'Hey, you've just eaten a T-bone steak and it's fine for you, but you can't feed it to animals'? "[291]

Even boneless cuts may not be risk-free, though. In the slaughterhouse, the bovine carcass is typically split in half down the middle with a band saw, sawing right through the spinal column. This has been shown to aerosolize the spinal cord and contaminate the surrounding meat.[153] A study in Europe found contamination with spinal cord material on 100% of the split carcasses examined.[154] Similar contamination of meat derived from cattle cheeks can occur from brain tissue, if the cheek meat is not removed before the skull is fragmented or split.[155] The World Health Organization has pointed out that American beef can be contaminated with brain and spinal cord tissue in another way as well.[156]

Except for Islamic halal and Jewish kosher slaughter (which involve slitting the cow's throat while the animal is still conscious), cattle slaughtered in the United States are first stunned unconscious with an impact to the head before being bled to death. Medical science has known for over 60 years that people suffering head trauma can end up with bits of brain embolized into their bloodstream; so Texas A&M researchers wondered if fragments of brain could be found within the bodies of cattle stunned for slaughter. They checked and reportedly exclaimed, "Oh, boy did we find it."[158] They even found a 14 cm piece of brain in one cow's lung.[159] They concluded, "It is likely that prion proteins are found throughout the bodies of animals stunned for slaughter."[160]

There are different types of stunning devices, however, which likely have different levels of risk associated with them. The Texas A&M study was published in 1996 using the prevailing method at the time, pneumatic-powered air injection stunning.[161] The device is placed in the middle of the animal's forehead and fired, shooting a 4 inch bolt through the skull and injecting compressed air into the cranial vault which scrambles the brain tissue. The high pressure air not only "produces a smearing of the head of the animal with liquefied brain,"[162] but has been shown over and over to blow brain back into the circulatory system, scattering whole plugs of brain into a number of organs[163] and smaller brain bits likely into the muscle meat as well.[164]

Although this method of stunning has been used in the United States for over 20 years,[165] the meat industry, to their credit, has been phasing out these particularly risky air injection-type stunners. The Deputy Director of Public Citizen argues that this industry initiative should be given the force of federal regulation and banned,[166] as they have been throughout Europe.[167]

The stunning devices that remain in widespread use drive similar bolts through the skull of the animal, but without air injection.[168] Operators then may or may not pith the animals by sticking a rod into the stun hole to further agitate the deeper brain structures to reduce or eliminate reflex kicking during shackling of the hind limbs.[169] Even without pithing, which has been shown to be risky, these stunners currently in use in the U.S. today may still force brain into the bloodstream of some of these animals.[170-173]

In one experiment, for example, researchers applied a marker onto the stunner bolt. The marker was later detected within the muscle meat of the stunned animal. They conclude: "This study demonstrates that material present in... the CNS of cattle during commercial captive bolt stunning may become widely dispersed across the many animate and inanimate elements of the slaughter-dressing environment and within derived carcasses including meat entering the human food chain."[174] Even non-penetrative "mushroom-headed" stunners which just rely on concussive force to the skull to render the animal unconscious may not be risk free. People in automobile accidents with non-invasive head trauma can still end up with brain embolization,[175] and these bolts move at over 200 miles per hour.[176] The researchers at Texas A&M conclude, "Reason dictates that any method of stunning to the head will result in the likelihood of brain emboli in the lungs or, indeed, other parts of the body."[177]

And, finally, even if consumers of American beef just stick to boneless cuts from ritually slaughtered animals who just happen to have had their spinal columns safely removed, the muscle meat itself may be infected with prions. The National Cattlemen's Beef Association continues to assure consumers that beef is safe because the deadly prions aren't found in muscle meat.[178] Even putting aside contamination issues, it seems they are simply behind the times. In 2002, Stanley Prusiner, the Nobel laureate who discovered prions, proved in mice, at least, that muscle cells themselves were capable of forming prions.[179] He describes the levels of prions in muscle as "quite high," and describes the studies relied upon by the Cattlemen's Association as "extraordinarily inadequate."[180] Follow-up studies in Germany published May, 2003 confirm Prusiner's findings, showing that an animal who are orally infected may indeed end up with prions contaminating muscles throughout their body.[181]

This newly discovered muscle infectivity highlights how little we know about these diseases. For example, the American Meat Institute released a fact sheet on BSE stressing that while the new variant of Creutzfeldt Jakob Disease (vCJD) was known to be caused by eating infected cattle parts, the more common classic form of CJD, the so-called "sporadic" form, had nothing to do with mad cow disease. The November 2002 fact sheet emphatically stated, "There is absolutely no evidence to suggest that CJD is caused by any food, including beef.[182] But by the next month, December 2002, there was evidence.[183]

The surprising new finding linking mad cow disease with classic CJD has been used to explain the rising numbers of those stricken with the classic form of CJD in Europe.[184] We don't the incidence of this fatal disease in North America, because the disease isn't tracked here like it is in Europe.[185] We do know though, that when researchers have actually gone back and looked at the brains of presumed Alzheimer's deaths--where Alzheimer's was indicated on the death certificate--anywhere from between 3%[186-187] to 25%[188-190] had actually died of Creutzfeldt Jakob Disease. According to the CDC, Alzheimer's Disease is now the 8th leading cause of death in the United States,[191] affecting as many as 4 million Americans.[192] Despite the fact that an unknown number of Americans are already dying from this disease, the beef industry continues to ignore the evidence.[193]

The uncertainties inherent to this mysterious class of diseases make it even more important for the U.S. to follow the directives of the World Health Organization, and the lead of affected countries around the world, to implement concrete, practical measures to safeguard the American public.

High risk tissues in animal feed

In another direct violation of the World Health Organization recommendations and international standards,[194] the tissues with the highest potential for risk, cattle brains and spinal cord, are rendered directly into animal feed that continues to be fed legally to pigs[195] and chickens[196] in North America.[197-198] The major concern in feeding rendered cattle remains to other animals is that the cattle remains may directly, or indirectly, find their way back into cattle feed, which could potentially spark a British style outbreak of mad cow disease.

In the United States, slaughterhouse waste from cattle is rendered, or melted down, into "meat and bone meal" which is used in animal feed, to help "animals grow bigger and faster."[199] Over 18 million pounds of meat and bone meal are produced every day in the United States.[200] Up until May 20th, 2003, the U.S. imported an extra 100,000 lbs. from Canada every day as well.[201] While rendering can destroy conventional pathogens like viruses and bacteria, none of the rendering methods used in the U.S.[202] or Canada[203] have been shown to significantly destroy prion infectivity.

Almost all fattening beef cattle, all dairy calves and all adult dairy cows raised conventionally are fed meat and bone meal in the United States.[204] In fact, conventional dairy cows eat about a pound of meat and bone every day in North America.[205-206] Since the partial 1997 FDA feed ban, however, this meat and bone meal is not supposed to come from ruminants--other cattle, sheep or deer. Unfortunately, these regulations have been poorly enforced. In 2001, the Food and Drug Administration published the results of a national survey of rendering plants and feed mills. Up to a quarter of the plants were found in violation of the 1997 feed regulations years after the so-called "ban" went into effect.[207]

Ruminant meat and bone meal, even derived from downer cattle too sick to walk or stand, can still be sold in North America. As pointed out by Dr. Michael Hansen from the Consumers Union, "All they said is that you've got to label it, 'Do not feed to cattle and other ruminants.'[208] Farmers can walk in a feed store and still buy it. Nobody asks, 'Are you feeding it to cattle or pigs?'"[209] As tough as it is to enforce the feed-labeling compliance among renderers and feed mills, it's virtually impossible to effectively monitor America's thousands of livestock producers.

Even in Britain, the country most affected by mad cow disease, inspections showed that it was impossible to enforce the feed ban. If ruminant bone meal was available, and it was cheap, British farmers continued to illegally feed it to their cattle. The U.K. even had to ban the use of mammalian meat and bone meal as agricultural fertilizer to keep it out of the stores.[210] Meanwhile in the United States, violations of the 1997 feed regulations continue to this day.[211]

Even with 100% compliance with the feed regulations, however, cattle remains are still legally fed to pigs, for example, which have been found to be susceptible to BSE prions.[212] Then the pig remains can be fed back to cattle.[213] Or cattle remains can be fed to chickens, and then the poultry litter can be fed back to cows.[214] In these ways, prions may be indirectly cycled back into cattle feed.

Poultry litter is the mixture of excrement, spilled feed, dirt, feathers, etc. that gets scooped from the floors of poultry sheds every year.[215] Because poultry litter can be as much as eight times cheaper than alfalfa,[216] the cattle industry feeds an estimated one million tons of poultry litter to cattle every year.[217] Although excrement from other animals is fed to livestock in the U.S., chicken droppings are considered more nutritious for cows, compared to hog feces or cattle dung.[218] A thousand chickens can make enough waste to feed a growing calf year round.[219]

Although a single cow can eat as much as 3 tons of poultry waste a year,[220] the manure in the feed does not seem to affect the taste of the milk or the meat.[221] Taste panels have found little difference in the tenderness, juiciness and flavor of beef made from steers fed up to 50% poultry litter. In fact, beef made from steers fed bird droppings may be even more juicy and tender.[222] Cows are typically not fed more than 80% litter, since it's not as palatable[223] and may not fully meet protein and energy needs.[224]

Under the 1997 feed regulations, the FDA specifically allowed the feeding of chicken litter to cattle to continue, even if the chickens had just been fed meat and bone meal made from cattle remains.[225] Not only would the passage of infected feed through the chicken's intestinal tract be unlikely to reduce prion infectivity, some of the feed inevitably spills on the floor and mixes into the poultry litter that's fed to cattle.[226] So in this way, the cannibalistic practice of feeding cows to cows continues legally in the United States.

The industry realizes that this practice might not stand up to public scrutiny. They understand the practice carries "certain stigmas,"[227] "presents special consumer issues,"[228] and poses "potential public relations problems."[229] They seem puzzled as to why the public so "readily accepts organically grown vegetables" grown with composted manure, while there seems to be "apparent reluctance on the part of the public" to accept the feeding of poultry litter to cattle.[230] "We hope," says one industry executive, "common sense will prevail."[231]

Writes the editor of Beef magazine, "The Public Sees It As 'Manure.' We can call it what we want and argue its safety, feed value, environmental attributes, etc., but outsiders still see it simply as 'chicken manure.' And, the most valid and convincing scientific argument isn't going to counteract a gag reflex."[Joe Roybal. Beef, Dec 1, 1997] The industry's reaction, then, has been to silence the issue.

According to Beef magazine, public relations experts within the National Cattlemen's Beef Association warned beef producers that discussing the issue publicly would only, "bring out more adverse publicity."[232] When the Kansas Livestock Association dared to bring public attention to the issue by passing a resolution urging the discontinuation of the practice, for example, irate producers in neighboring states threatened a boycott of Kansas feedyards.[233]

The beef industry argues that this practice is safe because poultry litter is processed to eliminate pathogens before being fed to cattle.[234] This typically involves heating the litter to about 140 degrees Fahrenheit,[235] which is less than your typical sauna.[236]. Prions have been shown even to survive incineration[237], at temperatures hot enough to melt lead.[238]

The National Cattlemen's Beef Association and 14 other industry groups petitioned the FDA in 2003 to continue to allow the feeding of poultry litter to cattle.[239] As one industry executive said, the National Cattlemen's Beef Association has a history of working to prevent "unnecessary" federal regulations from "encumbering the cattle business."[240]

In compliance with World Health Organization guidelines, Europe has forbidden the feeding of all slaughterhouse and animal waste to livestock[241] The American Feed Industry Association called such a ban "a radical proposition."[242] The American Meat Institute also disagreed stating, "no good is accomplished by... prejudicing segments of society against the meat industry."[243] The reason the industry may be so recalcitrant is that approximately 60% of the meat and bone meal produced in the United States is of ruminant origin.[244] But as far back as 1993, Gary Weber, a spokesperson for the National Cattlemen's Beef Association, admitted that the industry could indeed find economically feasible alternatives to feeding rendered animal protein to other animals, but that the Cattlemen's Association did not want to set a precedent of being ruled by "activists."[245]

Gary Weber was the beef industry spokesperson who appeared on the infamous Oprah Winfrey show in 1996. Clearly alarmed and disturbed by the fact that cows in the U.S. are fed the remains of other cattle, Oprah swore she would never eat another burger again. After Oprah tried to remind the audience that cows were supposed to be herbivores, Dr. Weber defended the practice by stating, "Now keep in mind, before you--you view the ruminant animal, the cow, as simply a vegetarian--remember that they drink milk."[246] Besides the obvious absurdity of the statement, it's not even entirely accurate. In modern agribusiness, humans drink the milk. The calves get milk "replacer."

#4. Stop Weaning Calves on Cow's Blood

The last key recommendation of the World Health Organization was that "All countries should ban the use of ruminant tissues in ruminant feed."[247] The USDA boasts, "To stop the way the [mad cow] disease is thought to spread, in 1997, FDA prohibited the use of most mammalian protein in the manufacture of animal feed intended for cows and other ruminants."[248] The pivotal word being "most."

Like all mammals, cows can only produce milk after they've had a baby. And, most newborn calves in the United States are separated from their mothers within 12 hours--many immediately after birth--so that the mother's milk can be marketed for human consumption.[249] Though many dairy farmers still wean their calves on whole milk, the majority of dairy producers use milk replacer, which is basically a blend of water with a source of protein and some source of fat, as a cheaper alternative to milk.[250] Outbreaks of mad cow disease in Denmark,[251] Germany[252] and Japan[253] have already been tentatively tied to milk replacer which used beef tallow as a source of fat.

The protein source in milk replacer is most often milk protein (whey), but dairy farmers also suckle their calves with milk replacer made from cattle blood protein.[254] The number one advantage given for using blood as a protein source in milk replacer is that it is cheaper than whey.[255] The chief disadvantage of blood-based milk replacer, according to Jim Quigley, vice president of product development for the Animal Protein Corporation, is simply its "different color." Milk replacer containing blood concentrate typically has a "chocolate brown" color which can leave a dark residue on the bottles, buckets and utensils used to feed the liquid.[256] "For some producers," Quigley remarks, "the difference is difficult to accept at first, since the product does not look 'like milk.'" But the "Calves don't care," he is quick to add.[257]

The calves may not care, but Stanley Prusiner does. When asked if the Nobel Laureate was concerned that the U.S. was feeding cattle blood to calves, Dr. Prusiner replied, "Yeah, I think that we shouldn't be using anything from ruminants in cattle feed; I think that's clear." [258] The reason Prusiner is so concerned is that there is experimental proof that prions can indeed be transmitted through blood.

The medical director for the US Public Health Service reviewed the blood infectivity literature and found 15 published studies showing prion transmission through blood.[259] A sixteenth study, published in 2002, showed that blood taken even from an asymptomatic animal that was silently incubating BSE could still transmit the infection via a blood transfusion.[260] Reviewing the published science, the European Commission concluded, "There is little doubt that. humans or animals could be exposed to the BSE agent by consuming blood products..."[261]

The European Commission specifically condemned the practice of "intraspecies recycling of ruminant blood and blood products"--the practice of feeding cow's blood to calves.[262] Even excluding the fact that brain emboli may pass into the trough that collects the blood once an animal's throat is slit,[263] the report concludes, "As far as ruminant blood is concerned, it is considered that the best approach to protect public health at present is to assume that it could contain low levels of infectivity."[264] Yet calves in the U.S. to this day are still drinking up to 3 cups of "red blood cell protein" concentrate every day.[265]

The American Protein Corporation, based in Ames, Iowa, is the single largest blood spray-dryer in the world.[266] They advertise blood products that can even be fed "through the drinking water" to calves and pigs[267] Indeed, the majority of pigs in the U.S. are raised in part on spray-dried blood meal.[268] According to the National Renderers Association, although young pigs may find spray-dried blood meal initially unpalatable, they eventually get used to it.[269]

In response to public concerns, the industry formed the Spray Dried Blood and Plasma Producers Association to defend the practice.[270] The association was founded on the commitment to "producing safe, high quality blood products to use in feeds for commercial livestock and companion animals."[271] The industry points out that blood meal is one of the richest sources of protein available to the feed industry and is produced using only "clean, fresh animal blood."[272] "We are winning this battle [for consumer confidence]," the president of the American Feed Industry Association recently wrote, "but it continues to be slow and precarious when it should be a slam-dunk."[273]

Conclusion

Since 1996, the World Health Organization has recommended that all countries stop feeding prion infected animals to other animals, yet the U.S. government continues to allow deer infected with chronic wasting disease to be rendered into animal feed,[274] and the industry continues to oppose any proposed change in the law.[275]

Since 1996, the World Health Organization has recommended that all countries test their downer cattle for mad cow disease, yet the U.S. government continues to test but a tiny fraction of this high risk population. The beef industry calls U.S. surveillance "aggressive" and doesn't think more testing is necessary[276]. The world's authority on these diseases just calls it "appalling."[277]

Since 1996, the World Health Organization has recommended that all countries remove beef products containing risky organs like spinal cord from the human food supply. The U.S. government continues to refuse to implement such a measure, and the industry continues to oppose it, referring to such products as nothing but "wholesome."[278]

Since 1996, the World Health Organization has recommended that all countries stop feeding risky cattle organs like brains to all livestock. The U.S. government is considering it. The American Meat Institute, and 14 other industry groups remain vocally opposed.[279]

And, Since 1996, the World Health Organization has recommended that all countries stop feeding any remains of cows to cows, yet the U.S. government still allows dairy farmers to feed calves gallons worth of cow blood and fat collected at the slaughterhouse.[280] Industry representatives continue to actively support this practice.[281]

In 2002, the USDA requested feedback on a number of options for further preventive measures, including a total ban on allowing the brains and spinal cords from downer cattle in the human food supply.[282] The spokesperson for the American Meat Institute explained that the meatpacking industry would take a "significant hit" financially if the USDA enacted such a proposal.[283]

The American Meat Institute explained that spinal cords pose no health risk, "because the U.S. is BSE-free."[284] Despite grossly inadequate surveillance for the disease, when asked if we have BSE in U.S. cattle, the American Meat Institute in 2002 emphatically replied, "No, BSE is a foreign animal disease." They stressed that, "The fact that we share no physical borders with any affected nations has been a key means of protecting our cattle."[285]

Now that mad cow disease has been discovered in North America, the USDA should immediately enact measures to prevent human exposure by issuing an emergency interim rule to ban products that may contain the agent that causes mad cow disease.[286] So far, though, according to an agency spokesperson, the USDA isn't even discussing plans to increase testing for the disease.[287]

Years ago, once mad cow disease started appearing up in Europe, David Byrne, the European Commissioner for Health and Consumer Protection, immediately called for a comprehensive Europe-wide surveillance program to test every cow slaughtered for human consumption over a certain age. Commenting on the program he said, "One of the major lessons I have learned in dealing with BSE is that the political establishment must be fully transparent with the public on the issue. There must be no hidden agendas. No distortions. No false assurances. Transparency, information and open dialogue must guide our actions."[288] The United States could learn from Europe's experience.

   

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Jonathan Simms

Jonathan Simms is still fighting for his life.

You can watch "Johnny's Story," a special BBC presentation, by clicking on the picture of Jonathan and his parents.

May 31st was Jonathan's Birthday.

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

[1] National Cattlemen's Beef Association news release. 6 December 2000.
[2] USDA Release No. 0166.03 20 May 2003.
[3] USDA Release No. 0012.03 15 January 2003.
[4] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted by Angie Coiro. <http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&ResultCount=10&type=radio>.
[5] National Cattlemen's Beef Association. FMD and BSE: What Every Producer Should Know. April 2001.
[6] World Health Organization Consultation on Public Health Issues Related to Bovine Spongiform Encephalopathy and the Emergence of a New Variant of Creutzfeldt-Jakob Disease. MMWR 45(14);295-6, 303. 12 April 1996.
[7] Ibid.
[8] Ibid.
[9] American Feed Industry Organization. Feedgram. 10 December 2002. <http://www.afia.org/Feedgram_Articles/December_10__2002/Feed_Control.html>.
[10] <http://www.niaid.nih.gov/dir/labs/lpvd/race.htm>.
[11] R Race et al. Long-term subclinical carrier state precedes scrapie replication and adaptation in a resistant species: analogies to human BSE/vCJD. Journal of Virology 75(21):10073-89 (2001).
[12] National Institutes of Health. NIAID News Release "Study Examines How Prion Disease Adapts to New Species." 17 October 2001.
[13] "CWD carriers among us?" Rocky Mountain News (Denver, CO) August 8, 2002.
[14] Navy Environmental Health Center. Chronic Wasting Disease: An Emerging Threat? <http://www-nehc.med.navy.mil/nepmu2/Chronic%20Wasting%20Disease%20Draft.doc>.
[15] American Veterinary Medical Association. What you should know about chronic wasting disease. 23 October 2002. <http://www.avma.org/communications/cwd/cwd_faq.asp>.
[16] European Molecular Biology Organization Journal. 19(2000):4425.
[17] "CWD carriers among us?" Rocky Mountain News (Denver, CO) August 8, 2002.
[18] Ibid.
[19] DEFRA. Transmissible Spongiform Encephalopathy Agents. 7 May 1998. <http://www.archive.official-documents.co.uk/document/doh/spongifm/part-1.htm>.
[20] Center for Science in the Public Interest. Docket Number 98N-0359, CFSAN Program Priorities for FY2003. 20 August 2002. <http://www.fda.gov/ohrms/dockets/dailys/ 02/Aug02/082302/80022685.pdf>.
[21] Guidance for Industry: Use of Material from Deer and Elk in Animal Feed. 14 May 2003. <http://www.fda.gov/cvm/guidance/dguide158.pdf>.
[22] Federal Register on August 29, 1994, 59 FR 44591.
[23] Food and Drug Administration. Bovine Spongiform Encephalopathy. 9 January 2003. <http://www.fda.gov/cber/bse/bse.htm>.
[24] European Commission Health & Consumer Protection Directorate-General Scientific Steering Committee Opinion on Chronic Wasting Disease and Tissues That Might Carry a Risk for Human and Animal Feed Chains. 7 March 2003.
[25] World Health Organization Consultation on Public Health Issues Related to Bovine Spongiform Encephalopathy and the Emergence of a New Variant of Creutzfeldt-Jakob Disease. MMWR 45(14);295-6, 303. 12 April 1996.
[26] USDA Release No. 0012.03 15 January 2003.
[27] USDA. Bovine Spongiform Encephalopathy (BSE) Surveillance. <http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>.
[28] Ibid.
[29] International Office of Epizooties. International Animal Health Code. 2002. <http://www.oie.int/eng/normes/mcode/A_00154.htm>.
[30] Bovine Spongiform Encephalopathy (BSE) Surveillance <http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>.
[31] USDA Release No. 0012.03 15 January 2003.
[32] USDA APHIS Backgrounder on USDA's BSE Surveillance July 2001.
[33] International Office of Epizooties. International Animal Health Code. 2002. <http://www.oie.int/eng/normes/mcode/A_00154.htm>.
[34] Ibid.
[35] Ibid.
[36] Ibid.
[37] USDA Food Safety and Inspection Service. Current Thinking on Measures that Could be Implemented to Minimize Human Exposure to Materials that Could Potentially Contain the Bovine Spongiform Encephalopathy Agent. 15 January 2002.
[38] Bovine Spongiform Encephalopathy (BSE) Surveillance. <http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>.
[39] Prusiner's estimate of one million [Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted by Angie Coiro. <http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&ResultCount=10&type=radio>] may be closer to the truth based on comprehensive European records showing a downer rate of 1.92%,[Report on the monitoring and testing of bovine animals for the presence of Bovine Spongiform Encephalopathy (BSE) in 2001. June 2002. <http://europa.eu.int/comm/food/fs/bse/testing/bse45_en.pdf>] which would translate to about 864,000 downers in U.S. every year.
[40] Bovine Spongiform Encephalopathy: Implications for the United States. United States Department of Agriculture. Animal and Plant Health Inspection Service. Fort Collins: Centers for Epidemiology and Animal Health, 1993.
[41] A Review of USDA Slaughterhouse Records for Downed Animals (U.S. District 65 from January, 1999 to June, 2001) Farm Sanctuary, October 2001. <http://www.nodowners.org/downedanimals.pdf>.
[42] USDA Food Safety and Inspection Service. Current Thinking on Measures that Could be Implemented to Minimize Human Exposure to Materials that Could Potentially Contain the Bovine Spongiform Encephalopathy Agent. 15 January 2002.
[43] Report on the monitoring and testing of bovine animals for the presence of Bovine Spongiform Encephalopathy (BSE) in 2001. June 2002. <http://europa.eu.int/comm/food/fs/bse/testing/bse45_en.pdf>.
[44] A population of mink in Wisconsin that almost exclusively ate downer cows was decimated by a transmissible milk encephalopathy. See [Marsh RF, Bessen RA, Lehmann S, Hartsough GR. Epidemiological and experimental studies on a new incident of transmissible mink encephalopathy. Journal of General Virology 72(1991):589-594] for one of the original papers describing this incident. For a full discussion, read Mad Cow USA by Rampton and Stauber, available free online at <http://www.prwatch.org/books/madcow.html>.
[45] International Office of Epizooties. International Animal Health Code. 2002. <http://www.oie.int/eng/normes/mcode/A_00154.htm>.
[46] Even assuming 195,000 downers a year and that every single of the tests in the surveillance program's history was performed on downer cattle, (48,000 in 13 years)/(195,000 x 13 years) is less than 2%.
[47] General Accounting Office. GAO Report to Congressional Requesters. January 2002 Mad Cow Disease: Improvements in the Animal Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention Efforts. GAO-02-183. <http://www.gao.gov/new.items/d02183.pdf>.
[48] USDA Food Safety and Inspection Service. Current Thinking on Measures that Could be Implemented to Minimize Human Exposure to Materials that Could Potentially Contain the Bovine Spongiform Encephalopathy Agent. 15 January 2002.
[49] Food and Drug Administration 2000 CFR Title 21, Volume 6, Chapter 1, Part 589. <http://www.access.gpo.gov/nara/cfr/waisidx_00/21cfr589_00.html>.
[50] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted by Angie Coiro. <http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&ResultCount=10&type=radio>.
[51] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted by Angie Coiro. <http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&ResultCount=10&type=radio>.
[52] Older cattle are targeted in part, "because the diagnostic tests for BSE that are available today are not likely to detect the BSE agent in the brain tissue of cattle under 24 months of age even if the animals were infected with BSE."[USDA Food Safety and Inspection Service. Current Thinking on Measures that Could be Implemented to Minimize Human Exposure to Materials that Could Potentially Contain the Bovine Spongiform Encephalopathy Agent. 15 January 2002].
[53] European Commission press release IP/01/827.Brussels, 12 June 2001.
[54] USDA Food Safety and Inspection Service. Current Thinking on Measures that Could be Implemented to Minimize Human Exposure to Materials that Could Potentially Contain the Bovine Spongiform Encephalopathy Agent. 15 January 2002.
[55] The U.S. adult cattle population is approximately 45 million [Bovine Spongiform Encephalopathy (BSE) Surveillance <http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>] compared to a 40.6 million adult cattle in Europe [<http://europa.eu.int/comm/food/fs/bse/testing/bse_01-03_en.pdf>].
[56] <http://europa.eu.int/comm/food/fs/bse/testing/bse_01-03_en.pdf>.
[57] France tests 75,000 cattle a week [<http://europa.eu.int/comm/food/fs/bse/testing/bse_01-03_en.pdf>] compared to our 48,000 in the entire 13 year history of the U.S. testing program [USDA. Bovine Spongiform Encephalopathy (BSE) Surveillance <http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>].
[58] In 2001 (the latest annual report available), Europe tested 8,516,227 out of 40.4 million adult cattle [<http://europa.eu.int/comm/food/fs/bse/testing/bse45_en.pdf>]. In the same year the U.S. tested 4,870[General Accounting Office. GAO Report to Congressional Requesters. January 2002 MAD COW DISEASE: Improvements in the Animal Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention Efforts. GAO-02-183. <http://www.gao.gov/new.items/d02183.pdf>] out of 45 million adult cattle [Bovine Spongiform Encephalopathy (BSE) Surveillance <http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>] for a rate 1,948 times greater.
[59] The Independent (London) 29 May 2003.
[60] European Commission Scientific Steering Committee. Outcome of Discussions. <http://europa.eu.int/comm/food/fs/sc/ssc/outcome_en.html>.
[61] European Commission Scientific Steering Committee. Report on the Assessment of the Geographical BSE - Risk of Austria (July 2000). <http://europa.eu.int/comm/food/fs/sc/ssc/out259_en.pdf>.
[62] European Commission Scientific Steering Committee. Report on the Assessment of the Geographical BSE - Risk of USA (July 2000). <http://europa.eu.int/comm/food/fs/sc/ssc/out137_en.pdf>.
[63] USDA. Bovine Spongiform Encephalopathy, Austria. USDA Impact Worksheet, 18 December 2001. <http://www.aphis.usda.gov/vs/ceah/cei/bse_austria1201.htm>.
[64] "Austria declared BSE free" CNN. 17 January 2001. <http://edition.cnn.com/2001/WORLD/europe/01/17/madcow.austria/. >
[65] USDA. Bovine Spongiform Encephalopathy, Austria. USDA Impact Worksheet, 18 December 2001. <http://www.aphis.usda.gov/vs/ceah/cei/bse_austria1201.htm>.
[66] "Critics say U.S. needs to do more to protect against mad cow." The Journal News (New York) 29 May 2003.
[67] Ibid.
[68] Ibid.
[69] The New York Times Magazine. 11 May 2003.
[70] "Critics say U.S. needs to do more to protect against mad cow." The Journal News (New York) 29 May 2003.
[71] Ibid.
[72] General Accounting Office. GAO Report to Congressional Requesters. January 2002 Mad Cow Disease: Improvements in the Animal Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention Efforts. GAO-02-183. <http://www.gao.gov/new.items/d02183.pdf>.
[73] Walker, K.D., et al. "Comparison of Bovine Spongiform Encephalopathy Risk Factors in the United States and Great Britain." Journal of the American Veterinary Medical Association 199 (1991): 1554-1561.
[74] Estimates range from 76%[USDA: Animal Disposition Reporting System. 1998] to between 81% and 83%[European Commission Report on the assessment of the Geographical BSE-risk of the USA <http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000] to 88%[Bovine Spongiform Encephalopathy (BSE) Surveillance <http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>].
[75] European Commission Report on the assessment of the Geographical BSE-risk of the USA <http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[76] "Dangerous Food." Oprah Winfrey Show. Harpo Productions. 16 April 1996. Burrelle's Information Services. Livingston, NJ.
[77] European Commission Report on the assessment of the Geographical BSE-risk of the USA <http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[78] USDA Food Safety and Inspection Service. Current Thinking on Measures that Could be Implemented to Minimize Human Exposure to Materials that Could Potentially Contain the Bovine Spongiform Encephalopathy Agent. 15 January 2002.
[79] USDA. Bovine Spongiform Encephalopathy, Austria. USDA Impact Worksheet, 18 December 2001. <http://www.aphis.usda.gov/vs/ceah/cei/bse_austria1201.htm>.
[80] "Austria declared BSE free." CNN. 17 January 2001.
[81] European Commission Scientific Steering Committee. Report on the Assessment of the Geographical BSE - Risk of Austria (July 2000).
[82] USDA. Bovine Spongiform Encephalopathy, Austria. USDA Impact Worksheet, 18 December 2001. <http://www.aphis.usda.gov/vs/ceah/cei/bse_austria1201.htm>.
[83] Public Citizen. Letter to the FDA and USDA RE: BSE April 12, 2001.
[84] European Commission Report on the assessment of the Geographical BSE-risk of Canada. July 2000. <http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf>.
[85] "Mad-cow disease also probably present in US." Agence France-Presse (Paris) 29 May 2003.
[86] The Associated Press 21 May 2003.
[87] The New York Times 21 May 2003.
[88] Denver Post 26 May 2003.
[89] The Independent (London) 29 May 2003.
[90] "Mad-cow disease also probably present in US" Agence France-Presse (Paris) 29 May 2003.
[91] "Critics say U.S. needs to do more to protect against mad cow." The Journal News (New York) 29 May 2003.
[92] World Health Organization Consultation on Public Health Issues Related to Bovine Spongiform Encephalopathy and the Emergence of a New Variant of Creutzfeldt-Jakob Disease. MMWR 45(14);295-6, 303. 12 April 1996.
[93] Regulation (EC)No 999/2001 of the European Parliament and of the Council of 22 May 2001 laying down rules for the prevention, control and eradication of certain transmissible spongiform encephalopathies.
[94] Harvard Center for Risk Analysis. Risk Analysis of Transmissible Spongiform Encephalopathies in Cattle and the Potential for Entry of the Etiologic Agent(s) Into the U.S. Food Supply . 2001. <http://www.hcra.harvard.edu/pdf>/madcow_report.pdf>.
[95] Federal Register: April 13, 1998 (Volume 63, Number 70). <http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/96-027P.htm>.
[96] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE Headquarters, Paris, 11-14 June 2001.
[97] USDA. Focus On Hot Dogs. June 2002. <http://www.fsis.usda.gov/OA/pubs/focushotdog.htm>.
[98] Center for Science in the Public Interest. Letter to the Secretary of Agriculture. January 7, 1997. <http://www.cspinet.org/reports/madcomnt.htm>.
[99] Federal Register: April 13, 1998 (Volume 63, Number 70). <http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/96-027P.htm>.
[100] USDA. Focus On Hot Dogs. June 2002. <http://www.fsis.usda.gov/OA/pubs/focushotdog.htm>.
[101] Center for Science in the Public Interest. Nutrition Health Letter. June, 2001
[102] USDA. Focus On Hot Dogs. June 2002. <http://www.fsis.usda.gov/OA/pubs/focushotdog.htm>.
[103] USDA. Focus On Hot Dogs. June 2002. <http://www.fsis.usda.gov/OA/pubs/focushotdog.htm>.
[104] Center for Science in the Public Interest. Nutrition Health Letter. June, 2001.
[105] Center for Science in the Public Interest. Letter to the Secretary of Agriculture. January 7, 1997. <http://www.cspinet.org/reports/madcomnt.htm>.
[106] Sparks Companies. Advanced Meat Recovery Systems -An Economic Analysis of Proposed USDA Regulations. July 1999.
[107] Center for Science in the Public Interest. Nutrition Health Letter. June, 2001.
[108] American Meat Institute Fact Sheet. Meat Derived by Advanced Meat Recovery. October 2002. www.amif.org/FactSheetAdvancedMeatRecovery.pdf>.
[109] USDA. Analysis of 2002 FSIS Bovine AMR Products Survey Results. February 2003. <http://www.fsis.usda.gov/OA/topics/AMRAnalysis.pdf>.
[110] Government Actions to Prevent Bovine Spongiform Encephalopathy in the United States. November 2001.
[111] Federal Register: April 13, 1998 (Volume 63, Number 70) <http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/96-027P.htm>.
[112] USDA Meat and Poultry Labeling Terms. January 2001. <http://www.fsis.usda.gov/OA/pubs/lablterm.htm>.
[113] Sparks Companies. Advanced Meat Recovery Systems--An Economic Analysis of Proposed USDA Regulations. July 1999.
[114] Ibid.
[115] American Meat Institute Fact Sheet. Meat Derived by Advanced Meat Recovery. October 2002.
[116] Sparks Companies. Advanced Meat Recovery Systems--An Economic Analysis of Proposed USDA Regulations. July 1999.
[117] B.P. Demos and R.W. Mandigo, "Chemistry and Composition of Mechanically Recovered Beef Neck Bone Lean," Journal Series, Nebraska Agricultural Research Division, Paper No. 10997, p. 64-65.
[118] Center for Science in the Public Interest. Nutrition Health Letter. June, 2001
[119] Testimony of Peter Lurie, MD, MPH Deputy Director Public Citizen's Health Research Group Before the Consumer Affairs, Foreign Commerce and Tourism Subcommittee Senate Commerce, Science and Transportation Committee. 4 April 2001.
[120] Ibid.
[121] Testimony of Caroline Smith DeWaal Director of Food Safety before the Senate Committee on Commerce, Science and Transportation Hearing on "Mad Cow Disease: Are Our Precautions Adequate?" 4 April 2001. Washington, D.C.
[122] National Cattlemen's Beef Association. Presence of Central Nervous System (CNS) Tissue In Advanced Meat Recovery (AMR) Products. April 2001.
[123] Ibid.
[124] USDA. Revised Directive for Advanced Meat Recovery Systems. December 2002. <http://www.fsis.usda.gov/OA/background/amrdirec.htm>.
[125] USDA. Analysis of 2002 FSIS Bovine AMR Products Survey Results. February 2003. <http://www.fsis.usda.gov/OA/topics/AMRAnalysis.pdf>.
[126] Ibid.
[127] Inter-American institute of Cooperation for Agriculture. Argentine Scientific Advisory Committee On BSE Following A Meeting On Transmissible Spongiform Encephalopathies. Review of the current status of the obscure points in TSE by Ray Bradley. 9 August 1999.
[128] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE Headquarters, Paris, 11-14 June 2001.
[129] Center for Science in the Public Interest. Nutrition Health Letter. June, 2001.
[130] August 10, 2001 Center for Science in the Public Interest News Release.
[131] Ibid.
[132] "FDA changes in feed restriction won't reduce BSE risk, industry groups say by Dan Murphy on 1/15/03 for www.meatingplace.com.
[133] Ibid.
[134] Ibid.
[135] Ibid.
[136] Sun Herald 7 August 2001.
[137] Sparks Companies. Advanced Meat Recovery Systems -An Economic Analysis of Proposed USDA Regulations. July 1999.
[138] Ibid.
[139] European Commission press release ip/00/423 .Brussels, 3 May 2000.
[140] "FDA changes in feed restriction won't reduce BSE risk, industry groups say by Dan Murphy on 1/15/03 for www.meatingplace.com.
[141] Center for Science in the Public Interest. Letter to the Secretary of Agriculture. January 7, 1997. <http://www.cspinet.org/reports/madcomnt.htm>.
[142] Testimony of Caroline Smith DeWaal Director of Food Safety before the Senate Committee on Commerce, Science and Transportation Hearing on "Mad Cow Disease: Are Our Precautions Adequate?" 4 April 2001. Washington, D.C. and USDA. Analysis of 2002 FSIS Bovine AMR Products Survey Results. February 2003. <http://www.fsis.usda.gov/OA/topics/AMRAnalysis.pdf> as above.
[143] Center for Science in the Public Interest. Letter to the Secretary of Agriculture. January 7, 1997. <http://www.cspinet.org/reports/madcomnt.htm>.
[144] August 10, 2001 Center for Science in the Public Interest News Release.
[145] Ibid.
[146] August 10, 2001 Center for Science in the Public Interest News Release.
[147] Public Citizen. Letter to the FDA and USDA RE: BSE April 12, 2001.
[148] Federal Register: April 13, 1998 (Volume 63, Number 70).
</www.fsis.usda.gov/OPPDE/rdad/FRPubs/96-027P.htm>
[149] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE Headquarters, Paris, 11-14 June 2001.
[150] Center for Science in the Public Interest. Nutrition Health Letter. June, 2001.
[151] Ibid.
[152] Ibid.
[153] Harvard Center for Risk Analysis. Risk Analysis of Transmissible Spongiform Encephalopathies in Cattle and the Potential for Entry of the Etiologic Agent(s) Into the U.S. Food Supply . 2001. <http://www.hcra.harvard.edu/pdf>/madcow_report.pdf>.
[154] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE Headquarters, Paris, 11-14 June 2001.
[155] USDA Food Safety and Inspection Service. Current Thinking on Measures that Could be Implemented to Minimize Human Exposure to Materials that Could Potentially Contain the Bovine Spongiform Encephalopathy Agent. 15 January 2002.
[156] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE Headquarters, Paris, 11-14 June 2001.
[157] Reuters 29 August 19996.
[158] Reuters 29 August 1996.
[159] Lancet Vol 348 August 31, 1996.
[160] Ibid.
[161] Lancet Vol 348 August 31, 1996.
[162] European Commission Health & Consumer Protection Directorate-General Scientific Opinion on Stunning Methods and BSE Risks. January 2002.
[163] Transfusion, Vol. 41, No. 11, 1325, November 2001.
[164] European Commission Health & Consumer Protection Directorate-General Scientific Opinion on Stunning Methods and BSE Risks. January 2002.
[165] Transfusion, Vol. 41, No. 11, 1325, November 2001.
[166] Testimony of Peter Lurie, MD, MPH Deputy Director Public Citizen's Health Research Group Before the Consumer Affairs, Foreign Commerce and Tourism Subcommittee Senate Commerce, Science and Transportation Committee. 4 April 2001.
[167] Regulation (EC)No 999/2001 of the European Parliament and of the Council. Laying down rules for the prevention, control and eradication of certain transmissible spongiform encephalopathies. 22 May 2001.
[168] European Commission Health & Consumer Protection Directorate-General Scientific Opinion on Stunning Methods and BSE Risks. January 2002.
[169] European Commission Scientific Report on Stunning Methods And BSE Risks (The Risk of Dissemination of Brain Particles Into the Blood And Carcass When Applying Certain Stunning Methods. December 2001).
[170] Berliner und M�nchener Tier�rztliche Wochenschrift 2002 Jan-Feb; 115(1-2): 1-5.
[171] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE Headquarters, Paris, 11-14 June 2001.
[172] European Commission Health & Consumer Protection Directorate-General. Scientific Steering Committee Opinion on the Safety of Ruminant Blood with Respect to Risks. 14 April 2000.
[173] European Commission Scientific Report On Stunning Methods and BSE Risks (The Risk of Dissemination of Brain Particles into the Blood and Carcass when Applying Certain Stunning Methods. December 2001).
[174] Applied and Environmental Microbiology. 2002 Feb; 68(2): 791-8.
[175] Letters to the Editor. The Lancet Vol 348 September 14, 1996.
[176] European Commission Health & Consumer Protection Directorate-General. Scientific Steering Committee Opinion on the Safety of Ruminant Blood with Respect to Risks. 14 April 2000.
[177] Letters to the Editor. The Lancet Vol 348 September 14, 1996.
[178] National Cattlemen's Beef Association news release. 21 May 2003. <http://www.beef.org/dsp/dsp_content.cfm?locationId=45&contentTypeId=2&contentId=2098>.
[179] Proceedings of the National Academy of Sciences. 2002 Mar 19;99(6):3812-7.
[180] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted by Angie Coiro.
<http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&ResultCount=10&type=radio>.
[181] European Molecular Biology Organization Reports 4, 5 (2003), 530.
[182] AMI Fact Sheet Bovine Spongiform Encephalopathy. November 2002.
[183] E. A. Asante et al. European Molecular Biology Oorganization Joutnal. 21, 6358-6366; 2002.
[184] "Prion data suggest BSE link to sporadic CJD." Nature 420, 450 (2002).
[185] World Health Organization. Variant Creutzfeldt-Jakob Disease. Fact sheet No. 180. Revised November 2002.
[186] Mahendra, B. Dementia Lancaster: MTP Press Limited, 1987: 174.
[187] Wade, J. P. H., et al. "The Clinical Diagnosis of Alzheimer's Disease." Archives of Neurology 44 (1987): 24-29.
[188] Boller, F., O. L. Lopez, and J. Moossy. "Diagnosis of Dementia." Neurology 38 (1989): 76-79.
[189] Manuelidis, Elias E. and Laura Manuelidis. "Suggested Links between Different Types of Dementias: Creutzfeldt-Jakob Disease, Alzheimer Disease, and Retroviral CNS Infections." Alzheimer Disease and Associated Disorders 2 (1989): 100-109.
[190] Teixeira, F., et al. "Clinico-Pathological Correlation in Dementias." _Journal of Psychiatry and Neuroscience 20 (1995): 276-282.
[191] Centers for Disease Control. Deaths/Mortality. <http://www.cdc.gov/nchs/fastats/deaths.htm>.
[192] Alzheimer's Association. Statistics about Alzheimer's Disease. 1 February 2003. <http://www.alz.org/AboutAD/Statistics.htm>.
[193] National Cattlemen's Beef Association. BSE Questions and Answers. June 2003. <http://www.bseinfo.org/dsp/dsp_locationContent.cfm?locationId=1267>.
[194] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE Headquarters, Paris, 11-14 June 2001.
[195] European Commission memo/03/94. Brussels, 30 April 2003.
[196] National Renderers Association. North American Rendering: A Source Of Essential, High-Quality Products.
[197] Canadian Food Inspection Agency, Regulations: Food for Ruminants, Livestock and Poultry (Part XIV), "Prohibited Materials".
[198] Food and Drug Administration 2000 CFR Title 21, Volume 6, Chapter 1, Part 589. <http://www.access.gpo.gov/nara/cfr/waisidx_00/21cfr589_00.html>.
[199] Dan Murphy. American Meat Institute Spokesperson. Quoted in The Journal News (New York) 29 May 2003.
[200] Docket No. 01-068-1] RIN 0579-AB43. Federal Register (Volume 68(2003):2704-2711.
[201] European Commission Report on the assessment of the Geographical BSE-risk of Canada <http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[202] European Commission Report on the assessment of the Geographical BSE-risk of the USA <http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[203] European Commission Report on the assessment of the Geographical BSE-risk of Canada <http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[204] European Commission Report on the assessment of the Geographical BSE-risk of the USA <http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[205] European Commission Report on the assessment of the Geographical BSE-risk of Canada <http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[206] European Commission Report on the assessment of the Geographical BSE-risk of the USA <http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[207] And the FDA numbers [FDA Center for Veterinary Medicine News Release 10 January 2001] are underestimates [General Accounting Office. GAO Report to Congressional Requesters. January 2002 Mad Cow Disease: Improvements in the Animal Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention Efforts. GAO-02-183. <http://www.gao.gov/new.items/d02183.pdf>].
[208] USDA Food Safety and Inspection Service. Current Thinking on Measures that Could be Implemented to Minimize Human Exposure to Materials that Could Potentially Contain the Bovine Spongiform Encephalopathy Agent. 15 January 2002.
[209] Kirchheimer, Gabe. Bovine Bioterrorism: The Perfect Pathogen. In Everything You Know Is Wrong. The Disinformation Company. 2002.
[210] U.K. Bans Use of Meat and Bone Meal in Fertilizer." Reuters Financial Report 19 April 1996.
[211] FDA Warning Letter. 22 May 2003. <http://www.fda.gov/foi/warning_letters/g4056d.htm>.
[212] "Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted by Angie Coiro. <http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&ResultCount=10&type=radio>.
[213] Public Citizen. Letter to the FDA and USDA RE: BSE. 21 April 2001. <http://www.citizen.org/cmep/foodsafety/gsfc/articles.cfm?ID=1562>.
[214] Food and Drug Administration Sec. 685.100 Recycled Animal Waste (CPG 7126.34).
[215] Mississippi State University Cooperative Extension Service. Broiler Litter as a Feed or Fertilizer in Livestock Operations. 1998.
[216] US News & World Report Sept. 1, 1997.
[217] Utilization Of Poultry Litter as Feed for Beef Cattle. <http://www.fda.gov/ohrms/dockets/dailys/01/Nov01/110501/ts00014.doc>.
[218] Fontenot, J. P. Recycling animal wastes by feeding to enhance environmental quality. 1991. The Professional Animal Scientist 7:l.
[219] Joseph P. Fontenot. Department of Animal And Poultry Sciences. Virginia Polytechnic Institute. Feeding Poultry Wastes To Cattle. 18 September 1996.
[220] Mississippi State University Extension Service. Poultry Nutrient Management Through Livestock Feedstuffs. 2000.
[221] Joseph P. Fontenot. Department of Animal And Poultry Sciences. Virginia Polytechnic Institute. Feeding Poultry Wastes To Cattle. 18 September 1996.
[222] Fontenot, J. P., K. E. Webb, Jr., B. W. Harmon, R. E. Tucker, and W. E. C. Moore. 1971. Studies of processing, nutritional value and palatability of broiler litter for ruminants. Proc. Int. Symp on Livestock Wastes, ASAE, St. Joseph, MI, p. 301.
[223] University of Florida Cooperative Extension. Broiler Litter, Part 2: Feeding to ruminants. August 1997.
[224] Joseph P. Fontenot. Department of Animal And Poultry Sciences. Virginia Polytechnic Institute. Feeding Poultry Wastes To Cattle. 18 September 1996.
[225] FDA. Guidance For Industry.Questions And Answers. BSE Feed Regulation 21 Code of Federal Regulations (CFR) 589.2000.
[226] Mississippi State University Cooperative Extension Service. Broiler Litter as a Feed or Fertilizer in Livestock Operations. 199.
[227] Feeding Poultry Litter to Beef Cattle. Agricultural publication G2077 - New February 15, 2001.
[228] Ibid.
[229] Mississippi State University Cooperative Extension Service. Broiler Litter as a Feed or Fertilizer in Livestock Operations. 1998.
[230] Alabama Cooperative Extension Service. US Policy Of Feeding 'Broiler Litter' (Chicken Sh**) To Beef Cattle 19 February 2001.
[231] Becky Mills. Alabama Cries 'Foul.' Beef, Jan 1, 1998.
[232] Beef magazine. More on poultry litter. 1 March 1998.
[233] Becky Mills. Alabama Cries 'Foul.' Beef, Jan 1, 1998.
[234] Joseph P. Fontenot. Utilization of Poultry Litter as Feed for Beef Cattle. Presented at FDA Public Hearing, Kansas City, MO, October 30, 2001, on animal feeding regulation "Animal Proteins Prohibited in Ruminant Feed"--Code of Federal Regulations, Title 21, Part 589.2000.
[235] Alabama Cooperative Extension Service. US Policy Of Feeding 'Broiler Litter' (Chicken Sh**) To Beef Cattle 19 February 2001.
[236] Hot Spring Spa of North County. Frequently Asked Questions. <http://www.spasandtubs.com/Finnleo/mostfrequentsauna_qa.html>.
[237] Brown, Paul, et al. "Resistance of Scrapie Infectivity to Steam Autoclaving after Formaldehyde Fixation and Limited Survival after Ashing at 360oC." Journal of Infectious Diseases 161 (1990): 467-472.
[238] Bentor, Yinon. Chemical Element.com - Lead. Jun. 3, 2003. <http://www.chemicalelements.com/elements/pb.html>.
[239] American Farm Bureau Federation. American Feed Industry Association. American Meat Institute. American Sheep Industry Association. Fats and Proteins Research Foundation. National Cattlemen's Beef Association. National Chicken Council. National Grain and Feed Association. National Institute for Animal Agriculture. National Milk Producers Federation. National Meat Association. National Pork Producers Council. National Renderers Association. National Turkey Federation. Pet Food Institute. Petition Re: Docket No. 02N-0273. 13 January 2003.
[240] Becky Mills. Alabama Cries 'Foul.' Beef, Jan 1, 1998.
[241] FDA, Center for Veterinary Medicine, Office of Management and Communications. Update On Ruminant Feed (BSE) Enforcement Activities. January 10, 2001.
[242] Evans, Eddie. "Agency to Ban Some Feeds to Block Mad-Cow Disease." Reuters World Report 13 May 1996.
[243] "AVMA Casts Doubt on Spread of BSE Through Sheep Offal." Food Chemical News 28 November 1994: 42-45.
[244] European Commission Report on the assessment of the Geographical BSE-risk of the USA <http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[245] "BSE/Scrapie Group Share Research, Debate Feed Bans." Food Chemical News 5 July 1993: 57-59.
[246] "Dangerous Food." Oprah Winfrey Show. Harpo Productions. 16 April 1996. Burrelle's Information Services. Livingston, NJ.
[247] World Health Organization Consultation on Public Health Issues Related to Bovine Spongiform Encephalopathy and the Emergence of a New Variant of Creutzfeldt-Jakob Disease. MMWR 45(14);295-6, 303. 12 April 1996.
[248] USDA Release No. 0012.03 15 January 2003.
[249] USDA Dairy Herd Management Practices Focusing on Preweaned Heifers N129.0793. July 1993. <http://cofcs66.aphis.usda.gov/vs/ceah/cahm/Dairy_Cattle/ndhep/dr91des1.pdf>.
[250] Ibid and Cornell Animal Science Department. A Guide To Calf Milk Replacers: Types Use and Quality. <http://www.ansci.cornell.edu/cgi-bin/db2www/ getdoc.d2w/query?doc=72>.
[251] Spongiform Encephalopathy Advisory Committee Draft Minutes of the 74th meeting held on 13th June 2002 at DEFRA.
[252] Ibid.
[253] Japan Today 24 August 2002.
[254] USDA Dairy Herd Management Practices Focusing on Preweaned Heifers N129.0793. July 1993. <http://cofcs66.aphis.usda.gov/vs/ceah/cahm/Dairy_Cattle/ndhep/dr91des1.pdf>.
[255] Dr. Jim Quigley. "Red blood cell protein in calf milk replacers." <http://www.calfnotes.com/pdf>files/CN049.pdf>.
[256] Dr. Jim Quigley. "Red blood cell protein in calf milk replacers." <http://www.calfnotes.com/pdf>files/CN049.pdf>.
[257] Ibid.
[258] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted by Angie Coiro. <http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&ResultCount=10&type=radio>.
[259] Paul Brown. Summary of Research Findings on TSE Infectivity in Blood. Annex 1. European Commission Health & Consumer Protection Directorate-General Scientific Steering Committee Opinion on the Implications of the Recent Papers an Transmission of BSE by Blood. 13 September 2002. <http://europa.eu.int/comm/food/fs/bse/scientific_advice08_en.html>.
[260] Hunter,N., Foster, J., Chong,A., McCutcheon, S., Parnham, D., Eaton, S., MacKenzie, C., and Houston, F., 2002. Transmission of prion diseases by blood transfusion. Journal of General Virology (2002), 83: Published ahead of print (16 July 2002).
[261] European Commission Scientific Report on Stunning Methods and BSE Risks (The Risk of Dissemination of Brain Particles into the Blood and Carcass when Applying Certain Stunning Methods. December 2001).
[262] European Commission Health & Consumer Protection Directorate- General Scientific Steering Committee Opinion an the Implications af the Recent Papers on Transmission of BSE by Blood. 13 September 2002. <http://europa.eu.int/comm/food/fs/bse/scientific_advice08_en.html>.
[263] European Commission Scientific Report on Stunning Methods and BSE Risks (The Risk of Dissemination of Brain Particles into the Blood and Carcass when Applying Certain Stunning Methods. December 2001).
[264] European Commission Health & Consumer Protection Directorate- General Scientific Steering Committee Opinion an the Implications af the Recent Papers on Transmission of BSE by Blood. 13 September 2002. <http://europa.eu.int/comm/food/fs/bse/scientific_advice08_en.html>.
[265] Milk replacer is up to 15% red blood cell protein [Dr. Jim Quigley. "Red blood cell protein in calf milk replacers." <http://www.calfnotes.com/pdf>files/CN049.pdf> ] and calves drink up to 5 quarts per day [USDA Dairy Herd Management Practices Focusing on Preweaned Heifers N129.0793. July 1993. <http://cofcs66.aphis.usda.gov/vs/ceah/cahm/Dairy_Cattle/ndhep/dr91des1.pdf>].
[266] APC Overview. 2002. <http://functionalproteins.com/overview/index.html>.
[267] APC. The Basic Science Behind Spray-Dried Plasma and Serum Proteins. <http://www.functionalproteins.com/functional_prots/ images/thebasicscience.pdf>.
[268] American Protein Corporation. The Basic Science Behind Spray-Dried Plasma and Serum Proteins.
[269] National Renderers Association. Rendered Animal Products for Swine. <http://www.renderers.org/links/swine.htm>.
[270] Feed Management October 2001.
[271] North American Spray Dried Blood and Plasma Producers statement. June 22, 2001.
[272] National Renderers Association. Rendered Animal Products for Poultry. <http://www.renderers.org/Poultry/index.htm>.
[273] American Feed Industry Organization. Feedgram. 23 December 2002. <http://www.afia.org/Feedgram_Articles/December_23_2002/FeedBag.html>.
[274] Guidance for Industry: Use of Material from Deer and Elk in Animal Feed. 14 May 2003. <http://www.fda.gov/cvm/guidance/dguide158.pdf>.
[275] American Feed Industry Organization. Feedgram. 30 April 2002. <http://www.afia.org/Feedgram_Articles/April_30__2002/CWD.html>.
[276] "Critics say U.S. needs to do more to protect against mad cow." The Journal News (New York) 29 May 2003.
[277] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted by Angie Coiro. <http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&ResultCount=10&type=radio>.
[278] Referring to mechanically separated meat [American Meat Institute Fact Sheet. Meat Derived by Advanced Meat Recovery. October 2002. www.amif.org/FactSheetAdvancedMeatRecovery.pdf>].
[279] "FDA changes in feed restriction won't reduce BSE risk, industry groups say." by Dan Murphy on 1/15/03 for www.meatingplace.com.
[280] Based on average 7.9 week weaning period [USDA Dairy Herd Management Practices Focusing on Preweaned Heifers N129.0793. July 1993. <http://cofcs66.aphis.usda.gov/vs/ceah/cahm/Dairy_Cattle/ndhep/dr91des1.pdf>].
[281] Testimony of Richard Sellers, Vice President for Feed Control & Nutrition, American Feed Industry Association, before the U.S. Senate Subcommittee on Consumer Affairs. 4 April 2001 Washington, DC.
[282] USDA Food Safety and Inspection Service. Current Thinking on Measures that Could be Implemented to Minimize Human Exposure to Materials that Could Potentially Contain the Bovine Spongiform Encephalopathy Agent. 15 January 2002.
[283] US Meat Groups Oppose BSE Rules. January 21, 2002 Farms.com.
[284] American Meat Institute Fact Sheet. Meat Derived by Advanced Meat Recovery. October 2002.
[285] AMI Fact Sheet Bovine Spongiform Encephalopathy. November 2002.
[286] USDA Food Safety and Inspection Service. Current Thinking on Measures that Could be Implemented to Minimize Human Exposure to Materials that Could Potentially Contain the Bovine Spongiform Encephalopathy Agent. 15 January 2002.
[287] The Journal News (New York) 29 May 2003.
[288] European Commission press release IP/00/1289. Brussels, 13 November 2000.
[289] David Bossman quoted in USA Today, June 3, 2003.
[290] FDA Veterinarian Newsletter. Volume XVII, No. VI. November/December 2002.
[291] USA Today, June 10, 2003.
[292] Associated Press, Frederic J. Frommer, July 14, 2003.

   
         

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