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US Violates Global Standards on Preventing Mad Cow Disease

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

by Michael Greger, M.D. for the Organic Consumers Association
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June 4, 2003

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]

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] 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]

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.

Michael Greger, MD, is a graduate of the Cornell University School of
Agriculture and the Tufts University School of Medicine. Dr. Greger
has been publicly speaking about mad cow disease since 1993. In
1997 he was invited as an expert witness to defend Oprah Winfrey
in the infamous meat defamation trial. He has contributed to many
books and articles on the subject and continues to lecture extensively.
Dr. Greger can be contacted at 857-928-2778, or mhg1@cornell.edu

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

Jonathan Simms is still fighting for his life.
"Johnny's Story," a special BBC presentation, is online at:
<http://news.bbc.co.uk/media/video/39254000/rm/_39254221_johnnysstory_vi.ram
>.

May 31st was Jonathan's Birthday.

--
Michael Greger, M.D.
mhg1@cornell.edu
857-928-2778

[1] National Cattlemen's Beef Association news release. 6 December 2000.
[2] USDA Release No. 0166.03 20 May 2003.
[3] USDA Release No. 0012.03 15 January 2003.
[4] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted
by Angie Coiro.
<http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&R
esultCount=10&type=radio>.
[5] National Cattlemen's Beef Association. FMD and BSE: What Every
Producer Should Know. April 2001.
[6] World Health Organization Consultation on Public Health Issues
Related to Bovine Spongiform Encephalopathy and the Emergence of a
New Variant of Creutzfeldt-Jakob Disease. MMWR 45(14);295-6, 303. 12
April 1996.
[7] Ibid.
[8] Ibid.
[9] American Feed Industry Organization. Feedgram. 10 December 2002.
<http://www.afia.org/Feedgram_Articles/December_10__2002/Feed_Control.html>..
[10] <http://www.niaid.nih.gov/dir/labs/lpvd/race.htm>.
[11] R Race et al. Long-term subclinical carrier state precedes
scrapie replication and adaptation in a resistant species: analogies
to human BSE/vCJD. Journal of Virology 75(21):10073-89 (2001).
[12] National Institutes of Health. NIAID News Release "Study
Examines How Prion Disease Adapts to New Species." 17 October 2001.
[13] "CWD carriers among us?" Rocky Mountain News (Denver, CO) August 8,
2002.
[14] Navy Environmental Health Center. Chronic Wasting Disease: An
Emerging Threat?
<http://www-nehc.med.navy.mil/nepmu2/Chronic%20Wasting%20Disease%20Draft.doc
>.
[15] American Veterinary Medical Association. What you should know
about chronic wasting disease. 23 October 2002.
<http://www.avma.org/communications/cwd/cwd_faq.asp>.
[16] European Molecular Biology Organization Journal. 19(2000):4425.
[17] "CWD carriers among us?" Rocky Mountain News (Denver, CO) August 8,
2002.
[18] Ibid.
[19] DEFRA. Transmissible Spongiform Encephalopathy Agents. 7 May
1998.
<http://www.archive.official-documents.co.uk/document/doh/spongifm/part-1.ht
m>.
[20] Center for Science in the Public Interest. Docket Number
98N-0359, CFSAN Program Priorities for FY2003. 20 August 2002.
<http://www.fda.gov/ohrms/dockets/dailys/
02/Aug02/082302/80022685.pdf>.
[21] Guidance for Industry: Use of Material from Deer and Elk in
Animal Feed. 14 May 2003.
<http://www.fda.gov/cvm/guidance/dguide158.pdf>.
[22] Federal Register on August 29, 1994, 59 FR 44591.
[23] Food and Drug Administration. Bovine Spongiform Encephalopathy.
9 January 2003. <http://www.fda.gov/cber/bse/bse.htm>.
[24] European Commission Health & Consumer 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&R
esultCount=10&type=radio>]
may be closer to the truth based on comprehensive European records
showing a downer rate of 1.92%,[Report on the monitoring and testing
of bovine animals for the presence of Bovine Spongiform
Encephalopathy (BSE) in 2001. June 2002.
<http://europa.eu.int/comm/food/fs/bse/testing/bse45_en.pdf>] which
would translate to about 864,000 downers in U.S. every year.
[40] Bovine Spongiform Encephalopathy: Implications for the United
States. United States Department of Agriculture. Animal and Plant
Health Inspection Service. Fort Collins: Centers for Epidemiology and
Animal Health, 1993.
[41] A Review of USDA Slaughterhouse Records for Downed Animals (U.S.
District 65 from January, 1999 to June, 2001) Farm Sanctuary, October
2001. <http://www.nodowners.org/downedanimals.pdf>.
[42] USDA Food Safety and Inspection Service. Current Thinking on
Measures that Could be Implemented to Minimize Human Exposure to
Materials that Could Potentially Contain the Bovine Spongiform
Encephalopathy Agent. 15 January 2002.
[43] Report on the monitoring and testing of bovine animals for the
presence of Bovine Spongiform Encephalopathy (BSE) in 2001. June
2002. <http://europa.eu.int/comm/food/fs/bse/testing/bse45_en.pdf>.
[44] A population of mink in Wisconsin that almost exclusively ate
downer cows was decimated by a transmissible milk encephalopathy. See
[Marsh RF, Bessen RA, Lehmann S, Hartsough GR. Epidemiological and
experimental studies on a new incident of transmissible mink
encephalopathy. Journal of General Virology 72(1991):589-594] for one
of the original papers describing this incident. For a full
discussion, read Mad Cow USA by Rampton and Stauber, available free
online at <http://www.prwatch.org/books/madcow.html>.
[45] International Office of Epizooties. International Animal Health
Code. 2002. <http://www.oie.int/eng/normes/mcode/A_00154.htm>.
[46] Even assuming 195,000 downers a year and that every single of
the tests in the surveillance program's history was performed on
downer cattle, (48,000 in 13 years)/(195,000 x 13 years) is less than
2%.
[47] General Accounting Office. GAO Report to Congressional
Requesters. January 2002 Mad Cow Disease: Improvements in the Animal
Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention
Efforts. GAO-02-183. <http://www.gao.gov/new.items/d02183.pdf>.
[48] USDA Food Safety and Inspection Service. Current Thinking on
Measures that Could be Implemented to Minimize Human Exposure to
Materials that Could Potentially Contain the Bovine Spongiform
Encephalopathy Agent. 15 January 2002.
[49] Food and Drug Administration 2000 CFR Title 21, Volume 6,
Chapter 1, Part 589.
<http://www.access.gpo.gov/nara/cfr/waisidx_00/21cfr589_00.html>.
[50] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted
by Angie Coiro.
<http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&R
esultCount=10&type=radio>.
[51] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted
by Angie Coiro.
<http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&R
esultCount=10&type=radio>.
[52] Older cattle are targeted in part, "because the diagnostic tests
for BSE that are available today are not likely to detect the BSE
agent in the brain tissue of cattle under 24 months of age even if
the animals were infected with BSE."[USDA Food Safety and Inspection
Service. Current Thinking on Measures that Could be Implemented to
Minimize Human Exposure to Materials that Could Potentially Contain
the Bovine Spongiform Encephalopathy Agent. 15 January 2002].
[53] European Commission press release IP/01/827.Brussels, 12 June 2001.
[54] USDA Food Safety and Inspection Service. Current Thinking on
Measures that Could be Implemented to Minimize Human Exposure to
Materials that Could Potentially Contain the Bovine Spongiform
Encephalopathy Agent. 15 January 2002.
[55] The U.S. adult cattle population is approximately 45 million
[Bovine Spongiform Encephalopathy (BSE) Surveillance
<http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>]
compared to a 40.6 million adult cattle in Europe
[<http://europa.eu.int/comm/food/fs/bse/testing/bse_01-03_en.pdf>].
[56] <http://europa.eu.int/comm/food/fs/bse/testing/bse_01-03_en.pdf>.
[57] France tests 75,000 cattle a week
[<http://europa.eu.int/comm/food/fs/bse/testing/bse_01-03_en.pdf>]
compared to our 48,000 in the entire 13 year history of the U.S.
testing program [USDA. Bovine Spongiform Encephalopathy (BSE)
Surveillance
<http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>].
[58] In 2001 (the latest annual report available), Europe tested
8,516,227 out of 40.4 million adult cattle
[<http://europa.eu.int/comm/food/fs/bse/testing/bse45_en.pdf>]. In
the same year the U.S. tested 4,870[General Accounting Office. GAO
Report to Congressional Requesters. January 2002 MAD COW DISEASE:
Improvements in the Animal Feed Ban and Other Regulatory Areas Would
Strengthen U.S. Prevention Efforts. GAO-02-183.
<http://www.gao.gov/new.items/d02183.pdf>] out of 45 million adult
cattle [Bovine Spongiform Encephalopathy (BSE) Surveillance
<http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>] for
a rate 1,948 times greater.
[59] The Independent (London) 29 May 2003.
[60] European Commission Scientific Steering Committee. Outcome of
Discussions.
<http://europa.eu.int/comm/food/fs/sc/ssc/outcome_en.html>.
[61] European Commission Scientific Steering Committee. Report on the
Assessment of the Geographical BSE - Risk of Austria (July 2000).
<http://europa.eu.int/comm/food/fs/sc/ssc/out259_en.pdf>.
[62] European Commission Scientific Steering Committee. Report on the
Assessment of the Geographical BSE - Risk of USA (July 2000).
<http://europa.eu.int/comm/food/fs/sc/ssc/out137_en.pdf>.
[63] USDA. Bovine Spongiform Encephalopathy, Austria. USDA Impact
Worksheet, 18 December 2001.
<http://www.aphis.usda.gov/vs/ceah/cei/bse_austria1201.htm>.
[64] "Austria declared BSE free" CNN. 17 January 2001.
<http://edition.cnn.com/2001/WORLD/europe/01/17/madcow.austria/.
[65] USDA. Bovine Spongiform Encephalopathy, Austria. USDA Impact
Worksheet, 18 December 2001.
<http://www.aphis.usda.gov/vs/ceah/cei/bse_austria1201.htm>.
[66] "Critics say U.S. needs to do more to protect against mad cow."
The Journal News (New York) 29 May 2003.
[67] Ibid.
[68] Ibid.
[69] The New York Times Magazine. 11 May 2003.
[70] "Critics say U.S. needs to do more to protect against mad cow."
The Journal News (New York) 29 May 2003.
[71] Ibid.
[72] General Accounting Office. GAO Report to Congressional
Requesters. January 2002 Mad Cow Disease: Improvements in the Animal
Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention
Efforts. GAO-02-183. <http://www.gao.gov/new.items/d02183.pdf>.
[73] Walker, K.D., et al. "Comparison of Bovine Spongiform
Encephalopathy Risk Factors in the United States and Great Britain."
Journal of the American Veterinary Medical Association 199 (1991):
1554-1561.
[74] Estimates range from 76%[USDA: Animal Disposition Reporting
System. 1998] to between 81% and 83%[European Commission Report on
the assessment of the Geographical BSE-risk of the USA
<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000]
to 88%[Bovine Spongiform Encephalopathy (BSE) Surveillance
<http://www.aphis.usda.gov/lpa/issues/bse/bse-surveillance.html>].
[75] European Commission Report on the assessment of the Geographical
BSE-risk of the USA
<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[76] "Dangerous Food." Oprah Winfrey Show. Harpo Productions. 16
April 1996. Burrelle's Information Services. Livingston, NJ.
[77] European Commission Report on the assessment of the Geographical
BSE-risk of the USA
<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[78] USDA Food Safety and Inspection Service. Current Thinking on
Measures that Could be Implemented to Minimize Human Exposure to
Materials that Could Potentially Contain the Bovine Spongiform
Encephalopathy Agent. 15 January 2002.
[79] USDA. Bovine Spongiform Encephalopathy, Austria. USDA Impact
Worksheet, 18 December 2001.
<http://www.aphis.usda.gov/vs/ceah/cei/bse_austria1201.htm>.
[80] "Austria declared BSE free." CNN. 17 January 2001.
[81] European Commission Scientific Steering Committee. Report on the
Assessment of the Geographical BSE - Risk of Austria (July 2000).
[82] USDA. Bovine Spongiform Encephalopathy, Austria. USDA Impact
Worksheet, 18 December 2001.
<http://www.aphis.usda.gov/vs/ceah/cei/bse_austria1201.htm>.
[83] Public Citizen. Letter to the FDA and USDA RE: BSE April 12, 2001.
[84] European Commission Report on the assessment of the Geographical
BSE-risk of Canada. July 2000.
<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf>.
[85] "Mad-cow disease also probably present in US." Agence
France-Presse (Paris) 29 May 2003.
[86] The Associated Press 21 May 2003.
[87] The New York Times 21 May 2003.
[88] Denver Post 26 May 2003.
[89] The Independent (London) 29 May 2003.
[90] "Mad-cow disease also probably present in US" Agence
France-Presse (Paris) 29 May 2003.
[91] "Critics say U.S. needs to do more to protect against mad cow."
The Journal News (New York) 29 May 2003.
[92] World Health Organization Consultation on Public Health Issues
Related to Bovine Spongiform Encephalopathy and the Emergence of a
New Variant of Creutzfeldt-Jakob Disease. MMWR 45(14);295-6, 303. 12
April 1996.
[93] Regulation (EC)No 999/2001 of the European Parliament and of the
Council of 22 May 2001 laying down rules for the prevention, control
and eradication of certain transmissible spongiform encephalopathies.
[94] Harvard Center for Risk Analysis. Risk Analysis of Transmissible
Spongiform Encephalopathies in Cattle and the Potential for Entry of
the Etiologic Agent(s) Into the U.S. Food Supply . 2001.
<http://www.hcra.harvard.edu/pdf>/madcow_report.pdf>.
[95] Federal Register: April 13, 1998 (Volume 63, Number 70).
<http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/96-027P.htm>.
[96] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE
Headquarters, Paris, 11-14 June 2001.
[97] USDA. Focus On Hot Dogs. June 2002.
<http://www.fsis.usda.gov/OA/pubs/focushotdog.htm>.
[98] Center for Science in the Public Interest. Letter to the
Secretary of Agriculture. January 7, 1997.
<http://www.cspinet.org/reports/madcomnt.htm>.
[99] Federal Register: April 13, 1998 (Volume 63, Number 70).
<http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/96-027P.htm>.
[100] USDA. Focus On Hot Dogs. June 2002.
<http://www.fsis.usda.gov/OA/pubs/focushotdog.htm>.
[101] Center for Science in the Public Interest. Nutrition Health
Letter. June, 2001
[102] USDA. Focus On Hot Dogs. June 2002.
<http://www.fsis.usda.gov/OA/pubs/focushotdog.htm>.
[103] USDA. Focus On Hot Dogs. June 2002.
<http://www.fsis.usda.gov/OA/pubs/focushotdog.htm>.
[104] Center for Science in the Public Interest. Nutrition Health
Letter. June, 2001.
[105] Center for Science in the Public Interest. Letter to the
Secretary of Agriculture. January 7, 1997.
<http://www.cspinet.org/reports/madcomnt.htm>.
[106] Sparks Companies. Advanced Meat Recovery Systems -An Economic
Analysis of Proposed USDA Regulations. July 1999.
[107] Center for Science in the Public Interest. Nutrition Health
Letter. June, 2001.
[108] American Meat Institute Fact Sheet. Meat Derived by Advanced
Meat Recovery. October 2002.
www.amif.org/FactSheetAdvancedMeatRecovery.pdf>.
[109] USDA. Analysis of 2002 FSIS Bovine AMR Products Survey Results.
February 2003. <http://www.fsis.usda.gov/OA/topics/AMRAnalysis.pdf>.
[110] Government Actions to Prevent Bovine Spongiform Encephalopathy
in the United States. November 2001.
[111] Federal Register: April 13, 1998 (Volume 63, Number 70)
<http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/96-027P.htm>.
[112] USDA Meat and Poultry Labeling Terms. January 2001.
<http://www.fsis.usda.gov/OA/pubs/lablterm.htm>.
[113] Sparks Companies. Advanced Meat Recovery Systems--An Economic
Analysis of Proposed USDA Regulations. July 1999.
[114] Ibid.
[115] American Meat Institute Fact Sheet. Meat Derived by Advanced
Meat Recovery. October 2002.
[116] Sparks Companies. Advanced Meat Recovery Systems--An Economic
Analysis of Proposed USDA Regulations. July 1999.
[117] B.P. Demos and R.W. Mandigo, "Chemistry and Composition of
Mechanically Recovered Beef Neck Bone Lean," Journal Series, Nebraska
Agricultural Research Division, Paper No. 10997, p. 64-65.
[118] Center for Science in the Public Interest. Nutrition Health
Letter. June, 2001
[119] Testimony of Peter Lurie, MD, MPH Deputy Director Public
Citizen's Health Research Group Before the Consumer Affairs, Foreign
Commerce and Tourism Subcommittee Senate Commerce, Science and
Transportation Committee. 4 April 2001.
[120] Ibid.
[121] Testimony of Caroline Smith DeWaal Director of Food Safety
before the Senate Committee on Commerce, Science and Transportation
Hearing on "Mad Cow Disease: Are Our Precautions Adequate?" 4 April
2001. Washington, D.C.
[122] National Cattlemen's Beef Association. Presence of Central
Nervous System (CNS) Tissue In Advanced Meat Recovery (AMR) Products.
April 2001.
[123] Ibid.
[124] USDA. Revised Directive for Advanced Meat Recovery Systems.
December 2002. <http://www.fsis.usda.gov/OA/background/amrdirec.htm>.
[125] USDA. Analysis of 2002 FSIS Bovine AMR Products Survey Results.
February 2003. <http://www.fsis.usda.gov/OA/topics/AMRAnalysis.pdf>.
[126] Ibid.
[127] Inter-American institute of Cooperation for Agriculture.
Argentine Scientific Advisory Committee On BSE Following A Meeting On
Transmissible Spongiform Encephalopathies. Review of the current
status of the obscure points in TSE by Ray Bradley. 9 August 1999.
[128] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE
Headquarters, Paris, 11-14 June 2001.
[129] Center for Science in the Public Interest. Nutrition Health
Letter. June, 2001.
[130] August 10, 2001 Center for Science in the Public Interest News
Release.
[131] Ibid.
[132] "FDA changes in feed restriction won't reduce BSE risk,
industry groups say by Dan Murphy on 1/15/03 for www.meatingplace.com.
[133] Ibid.
[134] Ibid.
[135] Ibid.
[136] Sun Herald 7 August 2001.
[137] Sparks Companies. Advanced Meat Recovery Systems -An Economic
Analysis of Proposed USDA Regulations. July 1999.
[138] Ibid.
[139] European Commission press release ip/00/423 .Brussels, 3 May 2000.
[140] "FDA changes in feed restriction won't reduce BSE risk,
industry groups say by Dan Murphy on 1/15/03 for www.meatingplace.com.
[141] Center for Science in the Public Interest. Letter to the
Secretary of Agriculture. January 7, 1997.
<http://www.cspinet.org/reports/madcomnt.htm>.
[142] Testimony of Caroline Smith DeWaal Director of Food Safety
before the Senate Committee on Commerce, Science and Transportation
Hearing on "Mad Cow Disease: Are Our Precautions Adequate?" 4 April
2001. Washington, D.C. and USDA. Analysis of 2002 FSIS Bovine AMR
Products Survey Results. February 2003.
<http://www.fsis.usda.gov/OA/topics/AMRAnalysis.pdf> as above.
[143] Center for Science in the Public Interest. Letter to the
Secretary of Agriculture. January 7, 1997.
<http://www.cspinet.org/reports/madcomnt.htm>.
[144] August 10, 2001 Center for Science in the Public Interest News
Release.
[145] Ibid.
[146] August 10, 2001 Center for Science in the Public Interest News
Release.
[147] Public Citizen. Letter to the FDA and USDA RE: BSE April 12, 2001.
[148] Federal Register: April 13, 1998 (Volume 63, Number 70).
<http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/96-027P.htm>.
[149] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE
Headquarters, Paris, 11-14 June 2001.
[150] Center for Science in the Public Interest. Nutrition Health
Letter. June, 2001.
[151] Ibid.
[152] Ibid.
[153] Harvard Center for Risk Analysis. Risk Analysis of
Transmissible Spongiform Encephalopathies in Cattle and the Potential
for Entry of the Etiologic Agent(s) Into the U.S. Food Supply . 2001.
<http://www.hcra.harvard.edu/pdf>/madcow_report.pdf>.
[154] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE
Headquarters, Paris, 11-14 June 2001.
[155] USDA Food Safety and Inspection Service. Current Thinking on
Measures that Could be Implemented to Minimize Human Exposure to
Materials that Could Potentially Contain the Bovine Spongiform
Encephalopathy Agent. 15 January 2002.
[156] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE
Headquarters, Paris, 11-14 June 2001.
[157] Reuters 29 August 19996.
[158] Reuters 29 August 1996.
[159] Lancet Vol 348 August 31, 1996.
[160] Ibid.
[161] Lancet Vol 348 August 31, 1996.
[162] European Commission Health & Consumer 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 Münchener Tierärztliche Wochenschrift 2002
Jan-Feb; 115(1-2): 1-5.
[171] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE
Headquarters, Paris, 11-14 June 2001.
[172] European Commission Health & Consumer 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&conte
ntId=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&R
esultCount=10&type=radio>.
[181] European Molecular Biology Organization Reports 4, 5 (2003), 530.
[182] AMI Fact Sheet Bovine Spongiform Encephalopathy. November 2002.
[183] E. A. Asante et al. European Molecular Biology Oorganization
Joutnal. 21, 6358-6366; 2002.
[184] "Prion data suggest BSE link to sporadic CJD." Nature 420, 450 (2002)..
[185] World Health Organization. Variant Creutzfeldt-Jakob Disease.
Fact sheet No. 180. Revised November 2002.
[186] Mahendra, B. Dementia Lancaster: MTP Press Limited, 1987: 174.
[187] Wade, J. P. H., et al. "The Clinical Diagnosis of Alzheimer's
Disease." Archives of Neurology 44 (1987): 24-29.
[188] Boller, F., O. L. Lopez, and J. Moossy. "Diagnosis of
Dementia." Neurology 38 (1989): 76-79.
[189] Manuelidis, Elias E. and Laura Manuelidis. "Suggested Links
between Different Types of Dementias: Creutzfeldt-Jakob Disease,
Alzheimer Disease, and Retroviral CNS Infections." Alzheimer Disease
and Associated Disorders 2 (1989): 100-109.
[190] Teixeira, F., et al. "Clinico-Pathological Correlation in
Dementias." _Journal of Psychiatry and Neuroscience 20 (1995):
276-282.
[191] Centers for Disease Control. Deaths/Mortality.
<http://www.cdc.gov/nchs/fastats/deaths.htm>.
[192] Alzheimer's Association. Statistics about Alzheimer's Disease.
1 February 2003. <http://www.alz.org/AboutAD/Statistics.htm>.
[193] National Cattlemen's Beef Association. BSE Questions and
Answers. June 2003.
<http://www.bseinfo.org/dsp/dsp_locationContent.cfm?locationId=1267>.
[194] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE
Headquarters, Paris, 11-14 June 2001.
[195] European Commission memo/03/94. Brussels, 30 April 2003.
[196] National Renderers Association. North American Rendering: A
Source Of Essential, High-Quality Products.
[197] Canadian Food Inspection Agency, Regulations: Food for
Ruminants, Livestock and Poultry (Part XIV), "Prohibited Materials".
[198] Food and Drug Administration 2000 CFR Title 21, Volume 6,
Chapter 1, Part 589.
<http://www.access.gpo.gov/nara/cfr/waisidx_00/21cfr589_00.html>.
[199] Dan Murphy. American Meat Institute Spokesperson. Quoted in The
Journal News (New York) 29 May 2003.
[200] Docket No. 01-068-1] RIN 0579-AB43. Federal Register (Volume
68(2003):2704-2711.
[201] European Commission Report on the assessment of the
Geographical BSE-risk of Canada
<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[202] European Commission Report on the assessment of the
Geographical BSE-risk of the USA
<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[203] European Commission Report on the assessment of the
Geographical BSE-risk of Canada
<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[204] European Commission Report on the assessment of the
Geographical BSE-risk of the USA
<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[205] European Commission Report on the assessment of the
Geographical BSE-risk of Canada
<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[206] European Commission Report on the assessment of the
Geographical BSE-risk of the USA
<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[207] And the FDA numbers [FDA Center for Veterinary Medicine News
Release 10 January 2001] are underestimates [General Accounting
Office. GAO Report to Congressional Requesters. January 2002 Mad Cow
Disease: Improvements in the Animal Feed Ban and Other Regulatory
Areas Would Strengthen U.S. Prevention Efforts. GAO-02-183.
<http://www.gao.gov/new.items/d02183.pdf>].
[208] USDA Food Safety and Inspection Service. Current Thinking on
Measures that Could be Implemented to Minimize Human Exposure to
Materials that Could Potentially Contain the Bovine Spongiform
Encephalopathy Agent. 15 January 2002.
[209] Kirchheimer, Gabe. Bovine Bioterrorism: The Perfect Pathogen.
In Everything You Know Is Wrong. The Disinformation Company. 2002.
[210] U.K. Bans Use of Meat and Bone Meal in Fertilizer." Reuters
Financial Report 19 April 1996.
[211] FDA Warning Letter. 6 May 2003.
<http://www.fda.gov/foi/warning_letters/g4000d.htm>.
[212] "Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum
hosted by Angie Coiro.
<http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&R
esultCount=10&type=radio>.
[213] Public Citizen. Letter to the FDA and USDA RE: BSE. 21 April
2001.
<http://www.citizen.org/cmep/foodsafety/gsfc/articles.cfm?ID=1562>.
[214] Food and Drug Administration Sec. 685.100 Recycled Animal Waste
(CPG 7126.34).
[215] Mississippi State University Cooperative Extension Service.
Broiler Litter as a Feed or Fertilizer in Livestock Operations. 1998.
[216] US News & World Report Sept. 1, 1997.
[217] Utilization Of Poultry Litter as Feed for Beef Cattle.
<http://www.fda.gov/ohrms/dockets/dailys/01/Nov01/110501/ts00014.doc>.
[218] Fontenot, J. P. Recycling animal wastes by feeding to enhance
environmental quality. 1991. The Professional Animal Scientist 7:l.
[219] Joseph P. Fontenot. Department of Animal And Poultry Sciences.
Virginia Polytechnic Institute. Feeding Poultry Wastes To Cattle. 18
September 1996.
[220] Mississippi State University Extension Service. Poultry
Nutrient Management Through Livestock Feedstuffs. 2000.
[221] Joseph P. Fontenot. Department of Animal And Poultry Sciences.
Virginia Polytechnic Institute. Feeding Poultry Wastes To Cattle. 18
September 1996.
[222] Fontenot, J. P., K. E. Webb, Jr., B. W. Harmon, R. E. Tucker,
and W. E. C. Moore. 1971. Studies of processing, nutritional value
and palatability of broiler litter for ruminants. Proc. Int. Symp on
Livestock Wastes, ASAE, St. Joseph, MI, p. 301.
[223] University of Florida Cooperative Extension. Broiler Litter,
Part 2: Feeding to ruminants. August 1997.
[224] Joseph P. Fontenot. Department of Animal And Poultry Sciences.
Virginia Polytechnic Institute. Feeding Poultry Wastes To Cattle. 18
September 1996.
[225] FDA. Guidance For Industry.Questions And Answers. BSE Feed
Regulation 21 Code of Federal Regulations (CFR) 589.2000.
[226] Mississippi State University Cooperative Extension Service.
Broiler Litter as a Feed or Fertilizer in Livestock Operations. 199.
[227] Feeding Poultry Litter to Beef Cattle. Agricultural publication
G2077 - New February 15, 2001.
[228] Ibid.
[229] Mississippi State University Cooperative Extension Service.
Broiler Litter as a Feed or Fertilizer in Livestock Operations. 1998.
[230] Alabama Cooperative Extension Service. US Policy Of Feeding
'Broiler Litter' (Chicken Sh**) To Beef Cattle 19 February 2001.
[231] Becky Mills. Alabama Cries 'Foul.' Beef, Jan 1, 1998.
[232] Beef magazine. More on poultry litter. 1 March 1998.
[233] Becky Mills. Alabama Cries 'Foul.' Beef, Jan 1, 1998.
[234] Joseph P. Fontenot. Utilization of Poultry Litter as Feed for
Beef Cattle. Presented at FDA Public Hearing, Kansas City, MO,
October 30, 2001, on animal feeding regulation "Animal Proteins
Prohibited in Ruminant Feed"--Code of Federal Regulations, Title 21,
Part 589.2000.
[235] Alabama Cooperative Extension Service. US Policy Of Feeding
'Broiler Litter' (Chicken Sh**) To Beef Cattle 19 February 2001.
[236] Hot Spring Spa of North County. Frequently Asked Questions.
<http://www.spasandtubs.com/Finnleo/mostfrequentsauna_qa.html>.
[237] Brown, Paul, et al. "Resistance of Scrapie Infectivity to Steam
Autoclaving after Formaldehyde Fixation and Limited Survival after
Ashing at 360oC." Journal of Infectious Diseases 161 (1990): 467-472.
[238] Bentor, Yinon. Chemical Element.com - Lead. Jun. 3, 2003.
<http://www.chemicalelements.com/elements/pb.html>.
[239] American Farm Bureau Federation. American Feed Industry
Association. American Meat Institute. American Sheep Industry
Association. Fats and Proteins Research Foundation. National
Cattlemen's Beef Association. National Chicken Council. National
Grain and Feed Association. National Institute for Animal
Agriculture. National Milk Producers Federation. National Meat
Association. National Pork Producers Council. National Renderers
Association. National Turkey Federation. Pet Food Institute. Petition
Re: Docket No. 02N-0273. 13 January 2003.
[240] Becky Mills. Alabama Cries 'Foul.' Beef, Jan 1, 1998.
[241] FDA, Center for Veterinary Medicine, Office of Management and
Communications. Update On Ruminant Feed (BSE) Enforcement Activities.
January 10, 2001.
[242] Evans, Eddie. "Agency to Ban Some Feeds to Block Mad-Cow
Disease." Reuters World Report 13 May 1996.
[243] "AVMA Casts Doubt on Spread of BSE Through Sheep Offal." Food
Chemical News 28 November 1994: 42-45.
[244] European Commission Report on the assessment of the
Geographical BSE-risk of the USA
<http://europa.eu.int/comm/food/fs/sc/ssc/out113_en.pdf> July 2000.
[245] "BSE/Scrapie Group Share Research, Debate Feed Bans." Food
Chemical News 5 July 1993: 57-59.
[246] "Dangerous Food." Oprah Winfrey Show. Harpo Productions. 16
April 1996. Burrelle's Information Services. Livingston, NJ.
[247] World Health Organization Consultation on Public Health Issues
Related to Bovine Spongiform Encephalopathy and the Emergence of a
New Variant of Creutzfeldt-Jakob Disease. MMWR 45(14);295-6, 303. 12
April 1996.
[248] USDA Release No. 0012.03 15 January 2003.
[249] USDA Dairy Herd Management Practices Focusing on Preweaned
Heifers N129.0793. July 1993.
<http://cofcs66.aphis.usda.gov/vs/ceah/cahm/Dairy_Cattle/ndhep/dr91des1.pdf>
..
[250] Ibid and Cornell Animal Science Department. A Guide To Calf
Milk Replacers: Types Use and Quality.
<http://www.ansci.cornell.edu/cgi-bin/db2www/
getdoc.d2w/query?doc=72>.
[251] Spongiform Encephalopathy Advisory Committee Draft Minutes of
the 74th meeting held on 13th June 2002 at DEFRA.
[252] Ibid.
[253] Japan Today 24 August 2002.
[254] USDA Dairy Herd Management Practices Focusing on Preweaned
Heifers N129.0793. July 1993.
<http://cofcs66.aphis.usda.gov/vs/ceah/cahm/Dairy_Cattle/ndhep/dr91des1.pdf>
..
[255] Dr. Jim Quigley. "Red blood cell protein in calf milk
replacers." <http://www.calfnotes.com/pdf>files/CN049.pdf> .
[256] Dr. Jim Quigley. "Red blood cell protein in calf milk
replacers." <http://www.calfnotes.com/pdf>files/CN049.pdf> .
[257] Ibid.
[258] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum
hosted by Angie Coiro.
<http://www.kqed.org/programs/programarchive.jsp?progID=RD19&ResultStart=1&R
esultCount=10&type=radio>.
[259] Paul Brown. Summary of Research Findings on TSE Infectivity in
Blood. Annex 1. European Commission Health & Consumer 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&R
esultCount=10&type=radio>.
[278] Referring to mechanically separated meat [American Meat
Institute Fact Sheet. Meat Derived by Advanced Meat Recovery. October
2002. www.amif.org/FactSheetAdvancedMeatRecovery.pdf>].
[279] "FDA changes in feed restriction won't reduce BSE risk,
industry groups say." by Dan Murphy on 1/15/03 for
www.meatingplace.com.
[280] Based on average 7.9 week weaning period [USDA Dairy Herd
Management Practices Focusing on Preweaned Heifers N129.0793. July
1993.
<http://cofcs66.aphis.usda.gov/vs/ceah/cahm/Dairy_Cattle/ndhep/dr91des1.pdf>
].
[281] Testimony of Richard Sellers, Vice President for Feed Control &
Nutrition, American Feed Industry Association, before the U.S. Senate
Subcommittee on Consumer Affairs. 4 April 2001 Washington, DC.
[282] USDA Food Safety and Inspection Service. Current Thinking on
Measures that Could be Implemented to Minimize Human Exposure to
Materials that Could Potentially Contain the Bovine Spongiform
Encephalopathy Agent. 15 January 2002.
[283] US Meat Groups Oppose BSE Rules. January 21, 2002 Farms.com.
[284] American Meat Institute Fact Sheet. Meat Derived by Advanced
Meat Recovery. October 2002.
[285] AMI Fact Sheet Bovine Spongiform Encephalopathy. November 2002.
[286] USDA Food Safety and Inspection Service. Current Thinking on
Measures that Could be Implemented to Minimize Human Exposure to
Materials that Could Potentially Contain the Bovine Spongiform
Encephalopathy Agent. 15 January 2002.
[287] The Journal News (New York) 29 May 2003.
[288] European Commission press release IP/00/1289. Brussels, 13 November
2000.
--
Michael Greger, M.D.
mhg1@cornell.edu
857-928-2778

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