4/15/2009 10:37:00 AM
R-CALF: FDA Should Not Delay Implementation Of Enhanced Feed Ban
Washington, D.C. – In formal comments submitted to the U.S. Food and Drug Administration (FDA) on Monday, R-CALF USA requested the agency – because of its obligation to put the health and safety of U.S. consumers and the U.S. cattle herd ahead of the self-interested corporations and their trade association that continue to ignore the very real and long-term risks associated with BSE (bovine spongiform encephalopathy, or mad cow disease) – immediately reverse its plan to delay implementation of the enhanced feed ban while higher-risk Canadian cattle continue to enter the United States.
"R-CALF USA believes that USDA (U.S. Department of Agriculture) acted recklessly and irresponsibly by allowing higher-risk Canadian cattle to enter the United States even before the U.S. implemented such basic measures as an enhanced feed ban to at least attempt to reduce that higher risk, and before USDA conducted a scientific investigation to determine if Canada's upgraded feed ban was even meeting Canada's expectations for BSE eradication," wrote R-CALF USA President/Region VI Director Max Thornsberry, a Missouri veterinarian who also chairs the group's animal health committee.
"Under present circumstances, the U.S. remains exposed to a heightened BSE risk from Canadian cattle, and the FDA has no choice but to immediately implement the enhanced feed ban to at least attempt to reduce the increased risk of BSE," he continued.
The current U.S. feed ban – which is weaker than the feed ban initially implemented in Canada and found to be insufficient to halt the spread of Canada's level of BSE infectivity – is likewise inadequate to prevent the amplification and spread of BSE that USDA has forecast to be continually introduced into the U.S. from Canadian cattle.
"There is no justifiable reason for the FDA to delay the enhanced feed ban," Thornsberry concluded. "The FDA has given the public only until this Thursday, April 16th, to comment on the delay, and we encourage independent cattle producers and consumers alike to demand that the agency act in the most responsible manner in the public's interest. If USDA does not immediately eliminate the source of this heightened BSE risk by prohibiting the importation of Canadian cattle, FDA has no choice but to immediately implement the 2008 BSE final rule to at least attempt to begin mitigating this heightened risk. There are no responsible alternatives."
R-CALF USA encourages U.S. consumers and U.S. cattle producers to submit comments on the FDA's proposal before midnight Eastern, April 16, 2009. For information on how to submit a public comment and to see a sample comment letter, as well as R-CALF USA's formal comments, go to www.r-calfusa.com and click on "Food Safety."
http://www.cattlenetwork.com/Content.as ... tID=306970
Sunday, April 12, 2009 r-calf and the USA mad cow problem, don't look, don't find, and then blame Canada Greetings cjdvoice,
don't be fooled cjdvoice. r-calf jumped on the mad cow band wagon only after a federal judge ordered a temporary halt to the shipment of bone-in cuts of meat to the United States. the mad cow was out of the barn in North America, they knew it, and jumped on that to better surve themselves to block Canadian beef. it had nothing to do with consumer safety, and it had everything to do with r-calf closing the Canadian border so USA cattle ranchers would have a closed market here. it's all about money$ r-calf whines about Canada and it's feed ban, and it's mad cows, while the USA has been covering up mad cow disease, this is fact. it took the OIG and an act of congress to finally document that Texas mad cow. this beside the one they did succeed in covering up in Texas. then you had 9,200 suspect mad cows that were ONLY TESTED with the least likely test to detect mad cow disease.
snip...
r-calf talks the talk NOW, but they need to practice what they preach at home. clean up their own backyards, stop worrying about Canada. the USA and Canadian cattle market, feed market, import and export between the two, were so intertwined, it was one market. Canada is just being honest, they are testing to find, and finding. the USDA et al did just the opposite, and or years and years that was o.k. with R-CALF. Canada's feed ban is stronger that the USA's feed ban. the only reason the USA is not finding mad cow cases of any phenotype is because of the SSS policy of shoot, shovel, and shut the hell up. ...
BSE MRR TSS, R-CALF ON CANADA VS USA
Bill Rancher
Joined: 10 Feb 2005 Posts: 1418 Location: GWN Posted: Fri Jan 05, 2007 9:49 am Post subject:
Texan wrote:
Hey Terry, I'd like to get a little further clarification on something if/when you have time. I'm not sure if I'm reading you correctly....
flounder wrote:
This is what sank my battleship in regards to testifying for r-calf. they actually appoached me about it, but i told them i would be glad to testify, but i was not stopping at the Canadian border, my testimony was to come south as well if given the opportunity. and that ended that, but i did supply them with a load of data, for whatever that was worth.
I highlighted the parts that confuse me. This almost makes it seem as if R-CALF was asking you to testify for them, but changed their mind when they found out that you were going to tell the WHOLE truth, instead of just the truth as regards Canadian imports.
I thought that R-CALF was only interested in the WHOLE truth - not just the selected parts of the truth that fit their protectionist agenda? After reading your post, it makes a person wonder. Maybe I read it wrong...
Am I reading this correctly, Terry? That can't be right, can it? Thanks.
I was wondering exactly the same thing Texan.
_________________
Canadian Beef....A cut above the rest!
my answer to big muddy from canada ;
hello there Texan,
yep, you read it right. don't know what ya'll gonna do without me. you know i plan on retiring from this mess soon. the pay is simply too excessive ;-( i fed them all i had at the time, and they shot the teacher. then hired old stanley i heard, go figure, must have been all those PhDs i had ;-)
as with the fuji-tv, when they came here and interviewed me for a BSE show, that i don't know what happened too, or the madcowboy documentary i was asked to proofread, and did, assured i would get some credit for, to never hear from again, to the speech in south Korea i was to make Nov. 23, but was shipwrecked somehow there too, and that might have been a good thing considering all the riots, and they did get the information anyway, to the TSS documentary, that too fell apart for good reasons i suppose, to helping creekstone, and finally to the NIH attempted destruction of an historical bank of donated tissue from CJD victims, and that one i think i did manage to stop, and that thanks to a Republican John Cornyn, i simply think it's time to let you fellars and gals clear this mess up. i have wasted enough time. it will be a decade next Christmas. i just would hate to keep kicking the same old mad cow. i know what happened for the most part, and the ones that don't get it now, never will.
now there Texan, as far as your question, and confusion ;-) i bet you thought i was not going to answer it, or, maybe hoping i would ;
flounder wrote:
This is what sank my battleship in regards to testifying for r-calf. they actually appoached me about it, but i told them i would be glad to testify, but i was not stopping at the Canadian border, my testimony was to come south as well if given the opportunity. and that ended that, but i did supply them with a load of data, for whatever that was worth.
I highlighted the parts that confuse me. This almost makes it seem as if R-CALF was asking you to testify for them, but changed their mind when they found out that you were going to tell the WHOLE truth, instead of just the truth as regards Canadian imports.
I thought that R-CALF was only interested in the WHOLE truth - not just the selected parts of the truth that fit their protectionist agenda? After reading your post, it makes a person wonder. Maybe I read it wrong...
Am I reading this correctly, Terry? That can't be right, can it? Thanks.
=========================================================
hello again there Texan,
i don't guess it matters anymore, i don't think ill be testifying for anyone, unless it is my own execution.
i was willing to participate in good faith, and sound science, that is why i think i was never sent to testify,
because in my opinion, R-Calf only wanted to cherry-pick the science, to use to there advantage, to try and
claim that Canada had a worse BSE problem than the USA, and i could not conceed to that. the science did
not confirm this. all one has to do is read the BSE GBR risk assessments, and that is why GW/OIE et al revised
there own risk assessments ;-) the BSE MRR policy.
i don't know, maybe i misinterpreted it all, maybe not, you can be the judge ;
oh what tangled webs we weave, when all we do is practice to deceive. ...TSS
SNIP...END... SEE FULL TEXT ;
*** http://ranchers.net/forum/viewtopic.php ... c&start=12
http://ranchers.net/forum/viewtopic.php ... c&start=24
http://ranchers.net/forum/viewtopic.php ... c&start=36
http://ranchers.net/forum/viewtopic.php ... c&start=48
Saturday, April 11, 2009 CJD FOUNDATION SIDES WITH R-CALFERS NO BSE OR HUMAN TSE THERE OF IN USA 'don't be fooled'
http://prionunitusaupdate2008.blogspot. ... rs-no.html
FOR all these reasons, is why i oppose the CJD Foundation decission to side with a cattle company that over the years, was as responsible for exposing the USA consumer to mad cow disease as was Canada, and then submit a letter that was written and in support of blaming only Canada. This letter the CJD Foundation supports and ask you to write, is only in support of R-CALF and a closed market to Canada beef, ALL THE WHILE IGNORING AND NOT SAYING A WORD OF PAST AND PRESENT FAILLURES OF THE SAME THING HERE IN THE USA. don't be fooled CJDVOICE. if you support this letter the way it was written, you are only fooling yourselves. you are being played like a pawn. write your own letter/comment, tell them the rest of the story. THIS IS NOT ABOUT CANADA ! the only reason we don't find mad cow disease in the USA, is because they did everything they could do in NOT finding BSE in those some 800,000 cattle that were tested. even Paul Brown called it flawed. dont be fooled cjdvoice and cjd foundation members, don't be fooled. ...
CJD FOUNDATION AND R-CALF LETTER
Sample Comment Letter for Your Use (You are free to use all or part of this letter):
April 9, 2009 Division of Dockets Management (HFA-305) Food and Drug Administration 5630 Fishers Lane, Rm. 1061Rockville, MD 20852
Re: Docket Number: FDA-2002-N-0031 (formerly Docket No. 2002N-0273)
Dear Administrator,
As the family member of a loved one who has died of a Creutzfeldt-Jakob Disease (CJD), one form of which can be acquired by ingesting BSE contaminated beef, I want to express my outrage at the recent announcement of the U.S. Food and Drug Administration's (FDA) delay of its April 17, 2009 scheduled implementation of the final rule titled "Substances Prohibited from Use in Animal Food or Feed," commonly referred to as the 2008 BSE final rule. They have made this announcement with full knowledge that the U.S. Department of Agriculture (USDA) continues to subject U.S. consumers and the U.S. cattle herd to a heighted risk of bovine spongiform encephalopathy (BSE) from imports of live Canadian cattle, particularly imports of Canadian cattle over 30 months (OTM) of age.
In Canada the disease occurrence is between three cases per million to eight cases per million cattle. The U.S. Centers for Disease Control and Prevention (CDC) states the level of BSE prevalence in the Canadian cattle herd is 18-fold to 48-fold higher than the prevalence estimated in the U.S. cattle herd. Just in 2008, nearly 1.6 million Canadian cattle were imported into the United States. By delaying the implementation of the Feed Ban the FDA risks yet another break in an already severely compromised food safety firewall.
When USDA reopened the U.S. border in 2007 to Canada's highest-risk cattle population – OTM cattle – its risk modeling based on a Canadian BSE prevalence of fewer than 4 cases per million predicted that the U.S. would import over 100 head of BSE-infected cattle from Canada over the next 20 years. In addition, the risk modeling showed that human exposure to BSE would increase. However, as the CDC explained, the BSE prevalence in Canada could well be 8 cases per million, meaning that USDA likely has grossly underestimated the risk of introducing BSE-infected cattle into the U.S. as a result of allowing OTM Canadian cattle imports. Canada already has detected 16 native cases of BSE in its OTM cattle herd, 10 of which were born after the 1997 feed ban. The most recent of these cases was detected just last November. Nine of Canada's BSE-infected cattle met USDA's age requirements to be exported to the United States, as they were born after March 1, 1999, the date after which USDA erroneously claims BSE-infectivity was no longer circulating in Canada.
The current U.S. feed ban implemented in 1997 is comparable to the initial Canadian feed ban also implemented in 1997. Canada's feed ban proved ineffective at preventing the spread of BSE in Canada. Despite the repeated urging of international scientists, Canada resisted any upgrades to its feed ban until after it detected multiple BSE cases in cattle born years after its 1997 feed ban. Canada's July 2007 upgraded feed ban now protects Canadian consumers against the spread of BSE from Canadian cattle by closing known transmission routes, including cross-contamination and inadvertent feeding of contaminated cattle parts. It is unthinkable that the FDA would not afford U.S. consumers the same level of protection against these same Canadian cattle that are imported into the United States.
The FDA cannot legitimately argue that its current feed ban implemented in 1997, which is nearly identical to Canada's original feed ban also implemented in 1997, is any more effective at mitigating Canada's heightened BSE risk within U.S. borders than it was in mitigating Canada's heightened BSE risk in Canada. Nor can FDA ignore the scientific evidence that overwhelmingly shows that the current U.S. feed ban is insufficient to mitigate the heightened BSE risk associated with OTM cattle imported from Canada. These higher-risk OTM Canadian cattle are entering the U.S. at the rate of several thousand per week, are being commingled in the U.S. cattle herd where some would be expected to die, and are entering both the U.S. food system as well as the U.S. animal feed system. The U.S. already is accepting Canada's higher BSE risk without the protections necessary to mitigate that higher risk.
The FDA cannot bury its head in the sand and pretend the upgraded feed ban contained in the 2008 BSE final rule is not urgently needed to mitigate the increased BSE risk associated with the importation of millions of Canadian cattle. In fact, the FDA already has failed to timely implement an upgraded feed ban, which should have been implemented before USDA began to expose U.S. consumers and the U.S. cattle herd to Canada's heightened BSE risk.
The FDA has an absolute responsibility to protect the health and safety of U.S. consumers and the U.S. cattle herd against this foreign animal disease which is always 100% fatal, and has been known to cross the species barrier infecting humans with variant Creutzfeldt-Jakob Disease (vCJD), the human form of BSE. We need only look to the United Kingdom's recent tragic experience when it was discovered that BSE had crossed the species barrier to humans. Thus far this preventable disease has caused the deaths of 168 young adults. The long incubation period (which can be up to 40 years), means that tragically, there could be many more cases in the future. The FDA must break away from the manipulative actions by corporate-controlled, self-serving trade associations that have caused both FDA and USDA to endanger the health and safety of U.S. consumers and the U.S. cattle herd by exposing them to an unnecessary and avoidable risk of BSE.
The USDA must immediately eliminate the source of this heightened BSE risk by prohibiting the importation of OTM Canadian cattle, and the FDA must immediately implement the 2008 BSE final rule to mitigate this heightened risk. There are no responsible alternatives.
http://cjdadvocacy.blogspot.com/2009/04 ... d-ban.html
http://www.cjdfoundation.org/
CANADA DID NOT KILL MY MOTHER, AND HER DEATH WAS NO SPONTANEOUS EVENT, OR HAPPENSTANCE OF BAD LUCK. ...
Thursday, April 9, 2009
Docket No. FDA2002N0031 (formerly Docket No. 2002N0273) RIN 0910AF46 Substances Prohibited From Use in Animal Food or Feed; Final Rule: Proposed
http://madcowfeed.blogspot.com/2009/04/ ... ocket.html
TSS
Thursday, April 9, 2009
Docket No. FDA2002N0031 (formerly Docket No. 2002N0273) RIN 0910AF46 Substances Prohibited From Use in Animal Food or Feed; Final Rule: Proposed
http://madcowfeed.blogspot.com/2009/04/ ... ocket.html
http://prionunitusaupdate2008.blogspot. ... l#comments
Sunday, April 12, 2009 r-calf and the USA mad cow problem, don't look, don't find, and then blame Canada
http://prionunitusaupdate2008.blogspot. ... -dont.html
http://prionunitusaupdate2008.blogspot. ... l#comments
TSS
R-CALF: FDA Should Not Delay Implementation Of Enhanced Feed Ban
Washington, D.C. – In formal comments submitted to the U.S. Food and Drug Administration (FDA) on Monday, R-CALF USA requested the agency – because of its obligation to put the health and safety of U.S. consumers and the U.S. cattle herd ahead of the self-interested corporations and their trade association that continue to ignore the very real and long-term risks associated with BSE (bovine spongiform encephalopathy, or mad cow disease) – immediately reverse its plan to delay implementation of the enhanced feed ban while higher-risk Canadian cattle continue to enter the United States.
"R-CALF USA believes that USDA (U.S. Department of Agriculture) acted recklessly and irresponsibly by allowing higher-risk Canadian cattle to enter the United States even before the U.S. implemented such basic measures as an enhanced feed ban to at least attempt to reduce that higher risk, and before USDA conducted a scientific investigation to determine if Canada's upgraded feed ban was even meeting Canada's expectations for BSE eradication," wrote R-CALF USA President/Region VI Director Max Thornsberry, a Missouri veterinarian who also chairs the group's animal health committee.
"Under present circumstances, the U.S. remains exposed to a heightened BSE risk from Canadian cattle, and the FDA has no choice but to immediately implement the enhanced feed ban to at least attempt to reduce the increased risk of BSE," he continued.
The current U.S. feed ban – which is weaker than the feed ban initially implemented in Canada and found to be insufficient to halt the spread of Canada's level of BSE infectivity – is likewise inadequate to prevent the amplification and spread of BSE that USDA has forecast to be continually introduced into the U.S. from Canadian cattle.
"There is no justifiable reason for the FDA to delay the enhanced feed ban," Thornsberry concluded. "The FDA has given the public only until this Thursday, April 16th, to comment on the delay, and we encourage independent cattle producers and consumers alike to demand that the agency act in the most responsible manner in the public's interest. If USDA does not immediately eliminate the source of this heightened BSE risk by prohibiting the importation of Canadian cattle, FDA has no choice but to immediately implement the 2008 BSE final rule to at least attempt to begin mitigating this heightened risk. There are no responsible alternatives."
R-CALF USA encourages U.S. consumers and U.S. cattle producers to submit comments on the FDA's proposal before midnight Eastern, April 16, 2009. For information on how to submit a public comment and to see a sample comment letter, as well as R-CALF USA's formal comments, go to www.r-calfusa.com and click on "Food Safety."
http://www.cattlenetwork.com/Content.as ... tID=306970
Sunday, April 12, 2009 r-calf and the USA mad cow problem, don't look, don't find, and then blame Canada Greetings cjdvoice,
don't be fooled cjdvoice. r-calf jumped on the mad cow band wagon only after a federal judge ordered a temporary halt to the shipment of bone-in cuts of meat to the United States. the mad cow was out of the barn in North America, they knew it, and jumped on that to better surve themselves to block Canadian beef. it had nothing to do with consumer safety, and it had everything to do with r-calf closing the Canadian border so USA cattle ranchers would have a closed market here. it's all about money$ r-calf whines about Canada and it's feed ban, and it's mad cows, while the USA has been covering up mad cow disease, this is fact. it took the OIG and an act of congress to finally document that Texas mad cow. this beside the one they did succeed in covering up in Texas. then you had 9,200 suspect mad cows that were ONLY TESTED with the least likely test to detect mad cow disease.
snip...
r-calf talks the talk NOW, but they need to practice what they preach at home. clean up their own backyards, stop worrying about Canada. the USA and Canadian cattle market, feed market, import and export between the two, were so intertwined, it was one market. Canada is just being honest, they are testing to find, and finding. the USDA et al did just the opposite, and or years and years that was o.k. with R-CALF. Canada's feed ban is stronger that the USA's feed ban. the only reason the USA is not finding mad cow cases of any phenotype is because of the SSS policy of shoot, shovel, and shut the hell up. ...
BSE MRR TSS, R-CALF ON CANADA VS USA
Bill Rancher
Joined: 10 Feb 2005 Posts: 1418 Location: GWN Posted: Fri Jan 05, 2007 9:49 am Post subject:
Texan wrote:
Hey Terry, I'd like to get a little further clarification on something if/when you have time. I'm not sure if I'm reading you correctly....
flounder wrote:
This is what sank my battleship in regards to testifying for r-calf. they actually appoached me about it, but i told them i would be glad to testify, but i was not stopping at the Canadian border, my testimony was to come south as well if given the opportunity. and that ended that, but i did supply them with a load of data, for whatever that was worth.
I highlighted the parts that confuse me. This almost makes it seem as if R-CALF was asking you to testify for them, but changed their mind when they found out that you were going to tell the WHOLE truth, instead of just the truth as regards Canadian imports.
I thought that R-CALF was only interested in the WHOLE truth - not just the selected parts of the truth that fit their protectionist agenda? After reading your post, it makes a person wonder. Maybe I read it wrong...
Am I reading this correctly, Terry? That can't be right, can it? Thanks.
I was wondering exactly the same thing Texan.
_________________
Canadian Beef....A cut above the rest!
my answer to big muddy from canada ;
hello there Texan,
yep, you read it right. don't know what ya'll gonna do without me. you know i plan on retiring from this mess soon. the pay is simply too excessive ;-( i fed them all i had at the time, and they shot the teacher. then hired old stanley i heard, go figure, must have been all those PhDs i had ;-)
as with the fuji-tv, when they came here and interviewed me for a BSE show, that i don't know what happened too, or the madcowboy documentary i was asked to proofread, and did, assured i would get some credit for, to never hear from again, to the speech in south Korea i was to make Nov. 23, but was shipwrecked somehow there too, and that might have been a good thing considering all the riots, and they did get the information anyway, to the TSS documentary, that too fell apart for good reasons i suppose, to helping creekstone, and finally to the NIH attempted destruction of an historical bank of donated tissue from CJD victims, and that one i think i did manage to stop, and that thanks to a Republican John Cornyn, i simply think it's time to let you fellars and gals clear this mess up. i have wasted enough time. it will be a decade next Christmas. i just would hate to keep kicking the same old mad cow. i know what happened for the most part, and the ones that don't get it now, never will.
now there Texan, as far as your question, and confusion ;-) i bet you thought i was not going to answer it, or, maybe hoping i would ;
flounder wrote:
This is what sank my battleship in regards to testifying for r-calf. they actually appoached me about it, but i told them i would be glad to testify, but i was not stopping at the Canadian border, my testimony was to come south as well if given the opportunity. and that ended that, but i did supply them with a load of data, for whatever that was worth.
I highlighted the parts that confuse me. This almost makes it seem as if R-CALF was asking you to testify for them, but changed their mind when they found out that you were going to tell the WHOLE truth, instead of just the truth as regards Canadian imports.
I thought that R-CALF was only interested in the WHOLE truth - not just the selected parts of the truth that fit their protectionist agenda? After reading your post, it makes a person wonder. Maybe I read it wrong...
Am I reading this correctly, Terry? That can't be right, can it? Thanks.
=========================================================
hello again there Texan,
i don't guess it matters anymore, i don't think ill be testifying for anyone, unless it is my own execution.
i was willing to participate in good faith, and sound science, that is why i think i was never sent to testify,
because in my opinion, R-Calf only wanted to cherry-pick the science, to use to there advantage, to try and
claim that Canada had a worse BSE problem than the USA, and i could not conceed to that. the science did
not confirm this. all one has to do is read the BSE GBR risk assessments, and that is why GW/OIE et al revised
there own risk assessments ;-) the BSE MRR policy.
i don't know, maybe i misinterpreted it all, maybe not, you can be the judge ;
oh what tangled webs we weave, when all we do is practice to deceive. ...TSS
SNIP...END... SEE FULL TEXT ;
*** http://ranchers.net/forum/viewtopic.php ... c&start=12
http://ranchers.net/forum/viewtopic.php ... c&start=24
http://ranchers.net/forum/viewtopic.php ... c&start=36
http://ranchers.net/forum/viewtopic.php ... c&start=48
Saturday, April 11, 2009 CJD FOUNDATION SIDES WITH R-CALFERS NO BSE OR HUMAN TSE THERE OF IN USA 'don't be fooled'
http://prionunitusaupdate2008.blogspot. ... rs-no.html
FOR all these reasons, is why i oppose the CJD Foundation decission to side with a cattle company that over the years, was as responsible for exposing the USA consumer to mad cow disease as was Canada, and then submit a letter that was written and in support of blaming only Canada. This letter the CJD Foundation supports and ask you to write, is only in support of R-CALF and a closed market to Canada beef, ALL THE WHILE IGNORING AND NOT SAYING A WORD OF PAST AND PRESENT FAILLURES OF THE SAME THING HERE IN THE USA. don't be fooled CJDVOICE. if you support this letter the way it was written, you are only fooling yourselves. you are being played like a pawn. write your own letter/comment, tell them the rest of the story. THIS IS NOT ABOUT CANADA ! the only reason we don't find mad cow disease in the USA, is because they did everything they could do in NOT finding BSE in those some 800,000 cattle that were tested. even Paul Brown called it flawed. dont be fooled cjdvoice and cjd foundation members, don't be fooled. ...
CJD FOUNDATION AND R-CALF LETTER
Sample Comment Letter for Your Use (You are free to use all or part of this letter):
April 9, 2009 Division of Dockets Management (HFA-305) Food and Drug Administration 5630 Fishers Lane, Rm. 1061Rockville, MD 20852
Re: Docket Number: FDA-2002-N-0031 (formerly Docket No. 2002N-0273)
Dear Administrator,
As the family member of a loved one who has died of a Creutzfeldt-Jakob Disease (CJD), one form of which can be acquired by ingesting BSE contaminated beef, I want to express my outrage at the recent announcement of the U.S. Food and Drug Administration's (FDA) delay of its April 17, 2009 scheduled implementation of the final rule titled "Substances Prohibited from Use in Animal Food or Feed," commonly referred to as the 2008 BSE final rule. They have made this announcement with full knowledge that the U.S. Department of Agriculture (USDA) continues to subject U.S. consumers and the U.S. cattle herd to a heighted risk of bovine spongiform encephalopathy (BSE) from imports of live Canadian cattle, particularly imports of Canadian cattle over 30 months (OTM) of age.
In Canada the disease occurrence is between three cases per million to eight cases per million cattle. The U.S. Centers for Disease Control and Prevention (CDC) states the level of BSE prevalence in the Canadian cattle herd is 18-fold to 48-fold higher than the prevalence estimated in the U.S. cattle herd. Just in 2008, nearly 1.6 million Canadian cattle were imported into the United States. By delaying the implementation of the Feed Ban the FDA risks yet another break in an already severely compromised food safety firewall.
When USDA reopened the U.S. border in 2007 to Canada's highest-risk cattle population – OTM cattle – its risk modeling based on a Canadian BSE prevalence of fewer than 4 cases per million predicted that the U.S. would import over 100 head of BSE-infected cattle from Canada over the next 20 years. In addition, the risk modeling showed that human exposure to BSE would increase. However, as the CDC explained, the BSE prevalence in Canada could well be 8 cases per million, meaning that USDA likely has grossly underestimated the risk of introducing BSE-infected cattle into the U.S. as a result of allowing OTM Canadian cattle imports. Canada already has detected 16 native cases of BSE in its OTM cattle herd, 10 of which were born after the 1997 feed ban. The most recent of these cases was detected just last November. Nine of Canada's BSE-infected cattle met USDA's age requirements to be exported to the United States, as they were born after March 1, 1999, the date after which USDA erroneously claims BSE-infectivity was no longer circulating in Canada.
The current U.S. feed ban implemented in 1997 is comparable to the initial Canadian feed ban also implemented in 1997. Canada's feed ban proved ineffective at preventing the spread of BSE in Canada. Despite the repeated urging of international scientists, Canada resisted any upgrades to its feed ban until after it detected multiple BSE cases in cattle born years after its 1997 feed ban. Canada's July 2007 upgraded feed ban now protects Canadian consumers against the spread of BSE from Canadian cattle by closing known transmission routes, including cross-contamination and inadvertent feeding of contaminated cattle parts. It is unthinkable that the FDA would not afford U.S. consumers the same level of protection against these same Canadian cattle that are imported into the United States.
The FDA cannot legitimately argue that its current feed ban implemented in 1997, which is nearly identical to Canada's original feed ban also implemented in 1997, is any more effective at mitigating Canada's heightened BSE risk within U.S. borders than it was in mitigating Canada's heightened BSE risk in Canada. Nor can FDA ignore the scientific evidence that overwhelmingly shows that the current U.S. feed ban is insufficient to mitigate the heightened BSE risk associated with OTM cattle imported from Canada. These higher-risk OTM Canadian cattle are entering the U.S. at the rate of several thousand per week, are being commingled in the U.S. cattle herd where some would be expected to die, and are entering both the U.S. food system as well as the U.S. animal feed system. The U.S. already is accepting Canada's higher BSE risk without the protections necessary to mitigate that higher risk.
The FDA cannot bury its head in the sand and pretend the upgraded feed ban contained in the 2008 BSE final rule is not urgently needed to mitigate the increased BSE risk associated with the importation of millions of Canadian cattle. In fact, the FDA already has failed to timely implement an upgraded feed ban, which should have been implemented before USDA began to expose U.S. consumers and the U.S. cattle herd to Canada's heightened BSE risk.
The FDA has an absolute responsibility to protect the health and safety of U.S. consumers and the U.S. cattle herd against this foreign animal disease which is always 100% fatal, and has been known to cross the species barrier infecting humans with variant Creutzfeldt-Jakob Disease (vCJD), the human form of BSE. We need only look to the United Kingdom's recent tragic experience when it was discovered that BSE had crossed the species barrier to humans. Thus far this preventable disease has caused the deaths of 168 young adults. The long incubation period (which can be up to 40 years), means that tragically, there could be many more cases in the future. The FDA must break away from the manipulative actions by corporate-controlled, self-serving trade associations that have caused both FDA and USDA to endanger the health and safety of U.S. consumers and the U.S. cattle herd by exposing them to an unnecessary and avoidable risk of BSE.
The USDA must immediately eliminate the source of this heightened BSE risk by prohibiting the importation of OTM Canadian cattle, and the FDA must immediately implement the 2008 BSE final rule to mitigate this heightened risk. There are no responsible alternatives.
http://cjdadvocacy.blogspot.com/2009/04 ... d-ban.html
http://www.cjdfoundation.org/
CANADA DID NOT KILL MY MOTHER, AND HER DEATH WAS NO SPONTANEOUS EVENT, OR HAPPENSTANCE OF BAD LUCK. ...
Thursday, April 9, 2009
Docket No. FDA2002N0031 (formerly Docket No. 2002N0273) RIN 0910AF46 Substances Prohibited From Use in Animal Food or Feed; Final Rule: Proposed
http://madcowfeed.blogspot.com/2009/04/ ... ocket.html
TSS
Thursday, April 9, 2009
Docket No. FDA2002N0031 (formerly Docket No. 2002N0273) RIN 0910AF46 Substances Prohibited From Use in Animal Food or Feed; Final Rule: Proposed
http://madcowfeed.blogspot.com/2009/04/ ... ocket.html
http://prionunitusaupdate2008.blogspot. ... l#comments
Sunday, April 12, 2009 r-calf and the USA mad cow problem, don't look, don't find, and then blame Canada
http://prionunitusaupdate2008.blogspot. ... -dont.html
http://prionunitusaupdate2008.blogspot. ... l#comments
TSS
