R-CALF: 40 Groups Disagree With USDA's Latest BSE Court Submission
R-CALF: 40 Groups Disagree With USDA's Latest BSE Court Submission
11/18/2009 03:50PM
Yes, the ball is still in play – although a distant memory for some – with regard to the litigation filed in 2007 by R-CALF USA and 10 other plaintiffs against the U.S. Department of Agriculture’s (USDA’s) decision to allow into the U.S. older Canadian cattle born after March 1, 1999, and beef from Canadian cattle of all ages. Canada continually has had a significant problem with bovine spongiform encephalopathy (BSE), also known as mad cow disease, and the agency’s latest legal notice suggests that ‘the people’s agency’ is about to kowtow to global interests instead of honoring its congressional mandate to protect U.S. citizens.
On July 3, 2008, a South Dakota federal judge essentially ordered USDA to go back to the drawing board on its over-30-month rule (OTM Rule) and instructed the agency to open a new public comment period on the matter. He then required USDA to report the developments to him on a quarterly basis.
USDA, in its Oct. 5, 2009, status submission to the court, reported that more than 4,800 pages of comments were received and that those comments are currently in “intra-departmental clearance,” and afterward will be submitted to the Office of Management and Budget (OMB). The agency estimates OMB will finish its review no later than Jan. 5, 2010, the date USDA’s next status report to the court is due.
On Nov. 17, 2009, R-CALF USA and 39 other groups sent a letter to Agriculture Secretary Tom Vilsack to express their serious concerns about the agency’s status submission.
One such concern is that USDA says it is preparing a docket to initiate rulemaking that would comprehensively amend the BSE regulations, and the criteria it will propose “would be closely aligned with those of the World Organization for Animal Health” (OIE). This new proposed rule is expected to be published in the Federal Register for comment late this year or early in 2010, according to USDA. The 40-member coalition states that such alignment with weaker OIE standards would not achieve the agency’s congressional mandate to protect against the introduction and spread of animal diseases, “particularly from such a pernicious animal disease as BSE that is invariably fatal and that also afflict humans.”
In its letter to Vilsack, the group points out that he has inherited the weakest, most ineffective and liberal BSE import policies when compared to every other major beef-consuming market in the world, and that as past Senators, President Obama and Vice President Biden – as parties to a Senate Resolution of Disapproval declaring that USDA’s OTM Rule shall have no force or effect – had objected to the very rules that exist now.
In fact, at the time when the Resolution of Disapproval passed, only four cases of BSE had been detected in Canadian-born cattle, and no post-feed ban BSE cases had been detected. Since then, 17 cases of BSE have been discovered in Canadian-born cattle. Eleven of these 17 BSE-infected cattle were born after Canada’s 1997 feed ban, and 10 of these 11 infected post-feed ban cattle were eligible, under USDA’s current rules, for export to the United States because they were born after March 1, 1999.
The letter states in part: “We respectfully request that you promulgate BSE rules that restore for U.S. livestock, livestock producers, and the people of the United States the highest possible level of protection against the introduction and spread of animal diseases. Valid science, consumer confidence, and sound economics require the BSE import rules to be tightened according to pre-outbreak norms. This departure from the past Administration’s destructive policies will improve consumer confidence in the beef supply, balance trade flows, remedy the severe financial destruction of the U.S. cattle industry, and substantially decrease the risk of livestock and human disease exposure.
Additionally, the group points out that: “The proper policy is to bring United States’ BSE regulations in line with past standards, which were more closely aligned to the current standards of our trading partners. Animal health, as well as food and product safety, should be held in higher regard by your Administration than trade facilitation. Public support for such a change is clear. The industry need is clear. Consumer confidence would increase. The United States’ current trade imbalances would become more balanced. Risks to animal and human health would be drastically reduced.”
“Current trade policy is losing support, in large part, because food and product safety standards are negated by government efforts to facilitate cross-border trade at all costs, and this trade-trumping-safety policy problem includes, but also goes beyond, cattle and beef,” said R-CALF USA CEO Bill Bullard. “Because of USDA’s past and current persistence in adopting unproven and inapt international standards – rather than continuing pre-BSE disease standards proven to protect consumers of U.S. beef and U.S. citizens, including U.S. cattle producers and their livestock – the U.S. cattle industry is unnecessarily burdened by a flood of unsafe imports. The result is a large trade deficit in cattle and beef that is forcing thousands upon thousands of independent cattle producers out of business each year.”
National organizations that signed on to the letter include: American Grassfed Association; Coalition for a Prosperous America; Consumer Federation of America; CJD (Creutzfeldt-Jakob Disease) Foundation; Farm and Ranch Freedom Alliance; Food & Water Watch; Freedom21, Inc.; International Texas Longhorn Association; National Association of Farm Animal Welfare; National Farmers Union; Organic Consumers Association; Organization for Competitive Markets; R-CALF USA; Sovereignty International, Inc.; The Cornucopia Institute; Western Organization of Resource Councils.
State, regional and county organizations that signed on to the letter include: Buckeye Quality Beef Association (Ohio); Cattle Producers of Washington; Citizens for Private Property Rights, Missouri; Colorado Independent CattleGrower's Association; Independent Cattlemen of Nebraska; Independent Beef Association of North Dakota; Independent Cattlemen of Wyoming; Kansas Cattlemen’s Association; Kansas Farmers Union; Mississippi Livestock Markets Association; Missouri Farmers Union; Nebraska Farmers Union; Nevada Live Stock Association; New England Farmers Union; Northeast Organic Farming Association/Massachusetts Chapter, Inc.; Ohio Farmers Union; Oregon Livestock Producers Association; Ozarks Property Rights Congress, Missouri; PCC Natural Markets (Puget Consumers Co-Op); SmallHolders of Massachusetts; South Dakota Farmers Union; South Dakota Stockgrowers Association; Spokane County Cattlemen, Washington; and, the Stevens County Cattlemen, Washington.
http://www.cattlenetwork.com/R-CALF--40-Groups-Disagree-With-USDA-s-Latest-BSE-Court-Submission/2009-11-18/Article.aspx?oid=941864&fid=CN-LATEST_NEWS_
November 17, 2009
The Honorable Tom Vilsack Secretary of Agriculture U.S. Department of Agriculture 1400 Independence Ave., S.W. Washington, D.C. 20250
Re: Serious Concerns Regarding APHIS’ October 5, 2009 Status Report in R-CALF USA, et al. vs. USDA, et al.
Dear Secretary Vilsack:
On Oct. 5, 2009, the U.S. Department of Agriculture (USDA) provided notice to the United States District Court, District of South Dakota, Northern Division, that states the agency is preparing a docket to initiate rulemaking to amend its bovine spongiform encephalopathy (BSE) regulations regarding the importation of bovines and bovine products. The notice specifically states, “The proposed criteria for country classification and commodity import would be closely aligned with those of the World Organization for Animal Health.”1
We, the undersigned organizations, are deeply concerned with this proposed action and believe USDA is exhibiting a serious lack of judgment by attempting to align U.S. safety measures with the incessantly weak and demonstrably ineffective BSE standards established by the international World Organization for Animal Health (OIE). This proposed action would, if taken, abrogate your agency’s responsibility under the Animal Health Protection Act to protect U.S. livestock and the people of the United States from the introduction into and spread within the United States of animal diseases, particularly from such a pernicious animal disease as BSE that is invariably fatal and that also afflict humans.2 Your Administration must reverse, not perpetuate, the previous Administration’s dangerous policy of preempting sound animal health and human health protections to facilitate trade – a policy that not only has increased domestic health hazards, but also has caused serious economic harm to domestic industries.
USDA’s own risk assessment predicts, with a high level of certainty, that current regulations will cause the introduction and spread of fatal BSE within the United States. 3 The risk assessment further predicts that the people of the United States will be exposed to additional risk for the disease. These regulations, implemented by the prior Administration, defy USDA’s animal health protection mandate while stating, throughout their respective preambles, that the U.S. and Canada, as well as the rules themselves, are in conformity to OIE standards.4 The OIE standards cannot reasonably be expected to protect U.S. livestock and the people of the United States from the introduction and spread of BSE as required by the Animal Health Protection Act.
The OIE standards are not deemed credible. They have not been followed by any of the United States’ major export customers with which the United States maintains a positive trade balance. This situation has not changed in the past six years.5 Current trade policy is losing support, in large part, because food and product safety standards are negated by government
The Honorable Tom Vilsack November 17, 2009 Page 2
efforts to facilitate cross-border trade at all costs. The trade-trumping-safety policy problem includes, but also goes beyond, cattle and beef. Because of USDA’s past and current persistence in adopting unproven and inapt international standards – rather than continuing pre-BSE disease standards proven to protect consumers of U.S. beef and U.S. citizens, including U.S. cattle producers and their livestock – the U.S. cattle industry is unnecessarily burdened by a flood of unsafe imports. The result is a large trade deficit in cattle and beef that is forcing thousands upon thousands of independent cattle producers out of business each year.
The only countries that have scientifically demonstrated a reduction in the incidence of BSE are those that continue to require more BSE testing, stricter feed bans, and more stringent specified risk materials removal practices than the OIE requires.6 Canada, on the other hand, is the only BSE-affected country with multiple cases of BSE detected in animals born after a feed ban that does not require standards far more stringent than those established by the OIE. It is not surprising, therefore, that OIE reports show that Canada is the only BSE-affected country other than Portugal to have experienced an increased incidence of BSE between 2007 and 2008.7
President Barack Obama and Vice President Joseph Biden, Jr., have previously demonstrated their strong opposition to USDA’s final rule that reopened our borders to Canadian cattle and beef after BSE was detected in Canada. Then-Senators Obama and Biden voted in favor of a Senate Resolution of Disapproval declaring that USDA’s rule shall have no force or effect.8 The BSE problem in Canada has grown substantially worse since that Senate Resolution. At the time of their votes, only four cases of BSE had been detected in Canadian-born cattle, and no post-feed ban BSE cases were discovered. Since that time, seventeen (17) cases of BSE have been discovered in Canadian-born cattle. Eleven (11) of these seventeen (17) BSE-infected cattle were born after Canada’s 1997 feed ban. Ten (10) of these eleven (11) infected post-feed ban cattle were eligible, under USDA’s current rules, for export to the United States because they were born after March 1, 1999.9
The proper policy is to bring United States’ BSE regulations in line with past standards, which were more closely aligned to the current standards of our trading partners. Animal health, as well as food and product safety, should be held in higher regard by your Administration than trade facilitation. Public support for such a change is clear. The industry need is clear. Consumer confidence would increase. The United States’ current trade imbalances would become more balanced. Risks to animal and human health would be drastically reduced.
The U.S. is the largest beef consuming market in the world and the largest beef producing country in the world. 10 You have inherited the weakest, most ineffective and liberal BSE import policies when compared to every other major beef consuming market in the world. President Obama and Vice President Biden previously objected to the very rules that exist now. We respectfully request that you promulgate BSE rules that restore for U.S. livestock, livestock producers, and the people of the United States the highest possible level of protection against the introduction and spread of animal diseases. Valid science, consumer confidence, and sound economics require the BSE import rules to be tightened according to pre-outbreak norms. This departure from the past Administration’s destructive policies will improve consumer
The Honorable Tom Vilsack November 17, 2009 Page 3
confidence in the beef supply, balance trade flows, remedy the severe financial destruction of the U.S. cattle industry, and substantially decrease the risk of livestock and human disease exposure.
Sincerely,
National Organizations: American Grassfed Association Coalition for a Prosperous America Consumer Federation of America CJD Foundation Farm and Ranch Freedom Alliance Food & Water Watch Freedom21, Inc. International Texas Longhorn Association National Association of Farm Animal Welfare National Farmers Union Organic Consumers Association Organization for Competitive Markets R-CALF USA Sovereignty International, Inc. The Cornucopia Institute Western Organization of Resource Councils State, Regional and County Organizations: Buckeye Quality Beef Association (Ohio) Cattle Producers of Washington Citizens for Private Property Rights, Missouri Colorado Independent CattleGrower's Association Independent Cattlemen of Nebraska Independent Beef Association of North Dakota Independent Cattlemen of Wyoming Kansas Cattlemen’s Association Kansas Farmers Union Mississippi Livestock Markets Association Missouri Farmers Union Nebraska Farmers Union Nevada Live Stock Association New England Farmers Union Northeast Organic Farming Association/Massachusetts Chapter, Inc. Ohio Farmers Union Oregon Livestock Producers Association Ozarks Property Rights Congress, Missouri PCC Natural Markets (Puget Consumers Co-op) The Honorable Tom Vilsack November 17, 2009 Page 4 SmallHolders of Massachusetts South Dakota Farmers Union South Dakota Stockgrowers Association Spokane County Cattlemen, Washington Stevens County Cattlemen, Washington For More information or to contact individual organizations, please contact R-CALF USA at 406-252-2516 or r-calfusa@r-calfusa.com.
cc: Members of Congress
U.S. Centers for Disease Control and Prevention State Animal Health Officials
1 Defendant’s [USDA’s] Status Report, R-CALF USA et al. vs. USDA, et al., U.S. District Court, District of South Dakota, Northern Division, CIV-07-1023, Oct. 5, 2009. 2 See 7 U.S.C. § 8301 (1) (“the prevention, detection, control and eradication of diseases and pests of animals are essential to protect . . . animal health [and] the health and welfare of the people of the United States.”); see also 7 U.S.C. § 8303 (a) (1) (The Secretary of Agriculture “may prohibit or restrict . . . the importation or entry of any animal . . . if the Secretary determines that the prohibition or restriction is necessary to prevent the introduction into or dissemination within the United States of any pest or disease of livestock.”). 3 See 72 Fed. Reg., 1109, col. 2; 72 Fed. Reg., 53347, col. 1 (USDA’s risk modeling for its over-30-month rule (OTM Rule) predicts the U.S. would import between 19 and 105 BSE-infected cattle from Canada, which would subsequently produce BSE infections in 2 to 75 U.S.-born cattle over a 20-year period). 4 See, e.g., 72 Fed. Reg., 53331, col. 1 (USDA justifies a key decision in its rulemaking by stating it is “entirely consistent with the science and with OIE guidelines.”); see also id., 53341 (“Our proposed changes are consistent with the OIE guidelines for trade in live animals from a controlled risk region.”); see also id., 53342 (For the reasons discussed above, we disagree that this rule is inconsistent with OIE guidelines.”); see also 70 Fed. Reg., 510, col. 3 (“BSE incidence and surveillance in Canada are well within the OIE guidelines for BSE minimal Risk.”); see also id., 464, col. 2 (“our proposed standards for minimal-risk regions were based on the OIE guidelines for BSE minimal-risk regions, using those guidelines as a reference.”); see also, id., 476, col. 3 (“Canada again exceeds OIE guidelines. . .”); see also id., 471, col. 3 (“Although Canada does not precisely meet the OIE guideline for duration of a feed ban, its control measures in other areas (such as surveillance and import restrictions) more than compensate for this.”). 5 See Global Beef Trade: Effects of Animal Health, Sanitary, Food Safety, and Other Measures on U.S. Exports, U.S. International Trade Commission, USITC Publication No. 4033, September 2008, at 4-9 (Japan, with a 37.2% share of U.S. exports in 2003 disallows beef from cattle over 20 months and disallows ground beef; Korea, with a 21.2% share of U.S. exports in 2003 disallows beef from cattle over 30 months of age; Mexico, with a19.6% share of U.S. exports in 2003 disallows beef from cattle over 30 months of age.). 6 See, e.g., Appendix A – APHIS’ consideration of Japan in Light of the World Organization for Animal Health’s (OIE) Guidelines, Analysis of Bovine Spongiform Encephalopathy (BSE) Risk to the U.S. Cattle Population from Importation of Whole Cuts of Boneless Beef from Japan, Veterinary Services, Animal and Plant Health Inspection Services, U.S. Dept. of Agriculture, at 5 (“Since October 2001, all cattle slaughtered in Japan undergo an ELISA screening test, followed by a confirmation test. . .”), (Japan prohibits ruminant derived meat-and-bone meal in animal feed and requires separate feed manufacturing production lines used exclusively for cattle feed.); see also id., at 16 (Japan implemented a complete ban on the use of mammalian protein, including blood products); see also Export Requirements for Japan, U.S. Dept. of Agriculture Food Safety and Inspection Service, JA-179, Oct. 23, 2009 (Japan requires the removal of the spinal cord and spinal column from animals less than 21 months of age.). 7 See Annual incidence rate of bovine spongiform encephalopathy (BSE) in OIE Member Countries that have reported cases, excluding the United Kingdom, OIE, downloaded Oct. 28, 2009, available at http://www.oie.int/eng/info/en_esbincidence.htm. 8 With the help of now President Obama and Vice President Biden, the U.S. Senate in the 109th Congress passed S.J. Res. 4 by a vote of 52 to 46. The Senate Resolution provided for congressional disapproval of USDA’s final rule to The Honorable Tom Vilsack November 17, 2009 Page 5
designate Canada as a minimal-risk country and to allow imports of cattle and beef from cattle that originate in a BSE-affected country, namely Canada. 9 See BSE (Bovine Spongiform Encephalopathy, or Mad Cow Disease), Centers for Disease Control and Prevention, U.S. Department of Health and Human Services, available at http://www.cdc.gov/ncidod/dvrd/bse/index.htm. 10 See Livestock and Poultry: World Markets and Trade, U.S. Dept. of Agriculture, Foreign Agricultural Service, Circular Series April 2009, at 7 (U.S. beef and veal production and U.S. beef and veal consumption far surpass any other country in the world, e.g., the U.S. produced over 12 million metric tons while second place Brazil produced less than 9.1 million metric tons in 2008, and the U.S. consumed over 12 million metric tons while second place EU- 27 consumed less than 8.5 million metric tons during the same year.).
http://www.r-calfusa.com/BSE/091117-40%20Organizations
Tuesday, November 17, 2009
SEAC EFFECT OF AGE ON THE PATHOGENESIS OF TRANSMISSIBLE SPONGIFORM ENCEPHALOPATHIES SEAC 103/2 (USDA CERTIFIED DEAD STOCK DOWNER COW SCHOOL LUNCH PROGRAM)
http://downercattle.blogspot.com/2009/11/seac-effect-of-age-on-pathogenesis-of.html
Tuesday, November 17, 2009
SEAC NEW RESULTS ON IDIOPATHIC BRAINSTEM NEURONAL CHROMATOLYSIS (IBNC) FROM THE VETERINARY LABORATORIES AGENCY (VLA) SEAC 103/1
http://bse-atypical.blogspot.com/2009/11/seac-new-results-on-idiopathic.html
2009 UPDATE ON ALABAMA AND TEXAS MAD COWS 2005 and 2006
http://bse-atypical.blogspot.com/2006/08/bse-atypical-texas-and-alabama-update.html
Monday, October 19, 2009
Atypical BSE, BSE, and other human and animal TSE in North America Update October 2009
http://bse-atypical.blogspot.com/2009/10/atypical-bse-bse-and-other-human-and.html
Tuesday, November 10, 2009
Surveillance On the Bovine Spongiform Encephalopathy and rabies in Taiwan and USA
http://usdavskorea.blogspot.com/2009/11/surveillance-on-bovine-spongiform.html
Monday, November 16, 2009
CANADA, USA, specified risk materials (SRMs), Environment, Fertilizer, AND Politics, just more BSe
http://madcowspontaneousnot.blogspot.com/2009/11/canada-usa-specified-risk-materials.html
Thursday, November 05, 2009
Incidence and spectrum of sporadic Creutzfeldt-Jakob disease variants with mixed phenotype and co-occurrence of PrPSc types: an updated classification
http://creutzfeldt-jakob-disease.blogspot.com/2009/11/incidence-and-spectrum-of-sporadic.html
Sunday, August 10, 2008
A New Prionopathy OR more of the same old BSe and sporadic CJD
http://creutzfeldt-jakob-disease.blogspot.com/2008/08/new-prionopathy-or-more-of-same-old-bse.html
Monday, October 26, 2009
MAD COW DISEASE, AND U.S. BEEF TRADE
MAD COW DISEASE, CJD, TSE, SOUND SCIENCE, COMMERCE, AND SELLING YOUR SOUL TO THE DEVIL
http://usdameatexport.blogspot.com/2009/10/mad-cow-disease-and-us-beef-trade.html
IN A NUT SHELL ;
(Adopted by the International Committee of the OIE on 23 May 2006)
11. Information published by the OIE is derived from appropriate declarations made by the official Veterinary Services of Member Countries. The OIE is not responsible for inaccurate publication of country disease status based on inaccurate information or changes in epidemiological status or other significant events that were not promptly reported to the Central Bureau,
http://www.oie.int/eng/Session2007/RF2006.pdf
Docket APHIS-2006-0026 Docket Title Bovine Spongiform Encephalopathy; Animal Identification and Importation of Commodities Docket Type Rulemaking Document APHIS-2006-0026-0001 Document Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions, Identification of Ruminants and Processing and Importation of Commodities Public Submission APHIS-2006-0026-0012 Public Submission Title Comment from Terry S Singletary
http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=09000064801e47e1
Docket APHIS-2006-0041 Docket Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived from Bovines Commodities Docket Type Rulemaking Document APHIS-2006-0041-0001 Document Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived From Bovines Public Submission APHIS-2006-0041-0028 Public Submission Title Comment from Terry S Singletary
Comment 2006-2007 USA AND OIE POISONING GLOBE WITH BSE MRR POLICY
THE USA is in a most unique situation, one of unknown circumstances with human and animal TSE. THE USA has the most documented TSE in different species to date, with substrains growing in those species (BSE/BASE in cattle and CWD in deer and elk, there is evidence here with different strains), and we know that sheep scrapie has over 20 strains of the typical scrapie with atypical scrapie documented and also BSE is very likely to have passed to sheep. all of which have been rendered and fed back to animals for human and animal consumption, a frightening scenario. WE do not know the outcome, and to play with human life around the globe with the very likely TSE tainted products from the USA, in my opinion is like playing Russian roulette, of long duration, with potential long and enduring consequences, of which once done, cannot be undone. These are the facts as I have come to know through daily and extensive research of TSE over 9 years, since 12/14/97. I do not pretend to have all the answers, but i do know to continue to believe in the ukbsenvcjd only theory of transmission to humans of only this one strain from only this one TSE from only this one part of the globe, will only lead to further failures, and needless exposure to humans from all strains of TSE, and possibly many more needless deaths from TSE via a multitude of proven routes and sources via many studies with primates and rodents and other species.
MY personal belief, since you ask, is that not only the Canadian border, but the USA border, and the Mexican border should be sealed up tighter than a drum for exporting there TSE tainted products, until a validated, 100% sensitive test is available, and all animals for human and animal consumption are tested. all we are doing is the exact same thing the UK did with there mad cow poisoning when they exported it all over the globe, all the while knowing what they were doing. this BSE MRR policy is nothing more than a legal tool to do just exactly what the UK did, thanks to the OIE and GW, it's legal now. and they executed Saddam for poisoning ???
go figure. ...
http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=09000064801f8151
Docket APHIS-2006-0041 Docket Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived from Bovines Commodities Docket Type Rulemaking Document APHIS-2006-0041-0001 Document Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived From Bovines Public Submission APHIS-2006-0041-0028.1 Public Submission Title Attachment to Singletary comment
January 28, 2007
Greetings APHIS,
I would kindly like to submit the following to ;
BSE; MRR; IMPORTATION OF LIVE BOVINES AND PRODUCTS DERIVED FROM BOVINES [Docket No. APHIS-2006-0041] RIN 0579-AC01
http://www.regulations.gov/fdmspublic/ContentViewer?objectId=09000064801f8152&disposition=attachment&contentType=msw8
Subject: Importation of Whole Cuts of Boneless Beef from Japan [Docket No. 05-004-1] RIN 0579-AB93 TSS SUBMISSION
Date: August 24, 2005 at 2:47 pm PST
August 24, 2005
Importation of Whole Cuts of Boneless Beef from Japan [Docket No. 05-004-1] RIN 0579-AB93 TSS SUBMISSION
Greetings APHIS ET AL,
My name is Terry S. Singeltary Sr.
I would kindly like to comment on [Docket No. 05-004-1] RIN 0579-AB93 ;
PROPOSED RULES
Exportation and importation of animals and animal products:
Whole cuts of boneless beef from-
Japan,
48494-48500 [05-16422]
http://www.regulations.gov/fdmspublic/ContentViewer?objectId=0900006480086ebc&disposition=attachment&contentType=msw6
Docket No. 03-080-1 -- USDA ISSUES PROPOSED RULE TO ALLOW LIVE ANIMAL IMPORTS FROM CANADA
https://web01.aphis.usda.gov/BSEcom.nsf/0/b78ba677e2b0c12185256dd300649f9d?OpenDocument&AutoFramed
PLEASE SEE FULL TEXT HERE ;
Docket No. 03-080-1 -- USDA ISSUES PROPOSED RULE TO ALLOW LIVE ANIMAL IMPORTS FROM CANADA
http://madcowfeed.blogspot.com/2008/07/docket-no-03-080-1-usda-issues-proposed.html
Thursday, November 12, 2009
BSE FEED RECALL Misbranding of product by partial label removal to hide original source of materials 2009
http://madcowfeed.blogspot.com/2009/11/bse-feed-recall-misbranding-of-product.html
Friday, September 4, 2009
FOIA REQUEST ON FEED RECALL PRODUCT 429,128 lbs. feed for ruminant animals may have been contaminated with prohibited material Recall # V-258-2009
http://madcowfeed.blogspot.com/2009/09/foia-request-on-feed-recall-product.html
Saturday, August 29, 2009
FOIA REQUEST FEED RECALL 2009 Product may have contained prohibited materials Bulk Whole Barley, Recall # V-256-2009
http://madcowfeed.blogspot.com/2009/08/foia-request-feed-recall-2009-product.html
http://madcowtesting.blogspot.com/
Saturday, October 24, 2009
SaBTO Advisory Committee on the Safety of Blood, Tissues and Organs 2nd Public Meeting 27 October 2009
http://seac992007.blogspot.com/2009/10/sabto-advisory-committee-on-safety-of.html
Wednesday, November 04, 2009
Detection of PrPsc in Blood from Sheep Infected with the Scrapie and Bovine Spongiform Encephalopathy Agents
http://vcjdtransfusion.blogspot.com/2009/11/detection-of-prpsc-in-blood-from-sheep.html
HUMAN and ANIMAL TSE Classifications i.e. mad cow disease and the UKBSEnvCJD only theory
http://www.regulations.gov/search/Regs/contentStreamer?objectId=090000648027c28e&disposition=attachment&contentType=pdf
Wednesday, November 18, 2009
BSE RISK USA UPDATE NOVEMBER 2009
http://bseusa.blogspot.com/2009/11/bse-risk-usa-update-november-2009.html
Sunday, April 12, 2009
BSE MAD COW TESTING USA 2009 FIGURES
Month Number of Tests
Feb 2009 -- 1,891
Jan 2009 -- 4,620
http://www.aphis.usda.gov/newsroom/hot_issues/bse/surveillance/ongoing_surv_results.shtml
http://madcowtesting.blogspot.com/2009/04/bse-mad-cow-testing-usa-2009-figures.html
PLEASE SEE MY FULL COMMENT SUBMISSION IN THE PDF ATTACHMENT, OR GO HERE
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/docket-no-fda2002n0031-formerly-docket.html
http://prionunitusaupdate2008.blogspot.com/2009/04/r-calf-and-usa-mad-cow-problem-dont.html#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.com/2009/04/r-calf-and-usa-mad-cow-problem-dont.html
http://prionunitusaupdate2008.blogspot.com/2009/04/cjd-foundation-sides-with-r-calfers-no.html#comments
MY comments/questions are as follows ; 1. SINCE the first Harvard BSE Risk Assessment was so flawed and fraught with error after the PEER REVIEW assessment assessed this fact, how do you plan on stopping this from happening again, will there be another peer review with top TSE Scientist, an impartial jury so-to-speak, to assess this new and updated Harvard BSE/TSE risk assessment and will this assessment include the Atypical TSE and SRM issues ?
*** Suppressed peer review of Harvard study October 31, 2002 ***
http://www.fsis.usda.gov/oa/topics/BSE_Peer_Review.pdf
***
http://www.scribd.com/doc/1490709/USDA-200600111
***
http://www.fsis.usda.gov/OPPDE/Comments/2006-0011/2006-0011-1.pdf
***
http://www.regulations.gov/search/Regs/contentStreamer?objectId=090000648027c28e&disposition=attachment&contentType=pdf
***
http://www.fsis.usda.gov/OPPDE/Comments/2006-0011/2006-0011-1.pdf
***
Response to Public Comments on the Harvard Risk Assessment of ... RESPONSE TO COMMENTS FROM TERRY S. SINGELTARY SR. Comment #1: SINCE the first Harvard BSE Risk Assessment was so flawed and fraught ...
http://www.fsis.usda.gov/PDF/BSE_Risk_Assess_Response_Public_Comments.pdf
TSS
11/18/2009 03:50PM
Yes, the ball is still in play – although a distant memory for some – with regard to the litigation filed in 2007 by R-CALF USA and 10 other plaintiffs against the U.S. Department of Agriculture’s (USDA’s) decision to allow into the U.S. older Canadian cattle born after March 1, 1999, and beef from Canadian cattle of all ages. Canada continually has had a significant problem with bovine spongiform encephalopathy (BSE), also known as mad cow disease, and the agency’s latest legal notice suggests that ‘the people’s agency’ is about to kowtow to global interests instead of honoring its congressional mandate to protect U.S. citizens.
On July 3, 2008, a South Dakota federal judge essentially ordered USDA to go back to the drawing board on its over-30-month rule (OTM Rule) and instructed the agency to open a new public comment period on the matter. He then required USDA to report the developments to him on a quarterly basis.
USDA, in its Oct. 5, 2009, status submission to the court, reported that more than 4,800 pages of comments were received and that those comments are currently in “intra-departmental clearance,” and afterward will be submitted to the Office of Management and Budget (OMB). The agency estimates OMB will finish its review no later than Jan. 5, 2010, the date USDA’s next status report to the court is due.
On Nov. 17, 2009, R-CALF USA and 39 other groups sent a letter to Agriculture Secretary Tom Vilsack to express their serious concerns about the agency’s status submission.
One such concern is that USDA says it is preparing a docket to initiate rulemaking that would comprehensively amend the BSE regulations, and the criteria it will propose “would be closely aligned with those of the World Organization for Animal Health” (OIE). This new proposed rule is expected to be published in the Federal Register for comment late this year or early in 2010, according to USDA. The 40-member coalition states that such alignment with weaker OIE standards would not achieve the agency’s congressional mandate to protect against the introduction and spread of animal diseases, “particularly from such a pernicious animal disease as BSE that is invariably fatal and that also afflict humans.”
In its letter to Vilsack, the group points out that he has inherited the weakest, most ineffective and liberal BSE import policies when compared to every other major beef-consuming market in the world, and that as past Senators, President Obama and Vice President Biden – as parties to a Senate Resolution of Disapproval declaring that USDA’s OTM Rule shall have no force or effect – had objected to the very rules that exist now.
In fact, at the time when the Resolution of Disapproval passed, only four cases of BSE had been detected in Canadian-born cattle, and no post-feed ban BSE cases had been detected. Since then, 17 cases of BSE have been discovered in Canadian-born cattle. Eleven of these 17 BSE-infected cattle were born after Canada’s 1997 feed ban, and 10 of these 11 infected post-feed ban cattle were eligible, under USDA’s current rules, for export to the United States because they were born after March 1, 1999.
The letter states in part: “We respectfully request that you promulgate BSE rules that restore for U.S. livestock, livestock producers, and the people of the United States the highest possible level of protection against the introduction and spread of animal diseases. Valid science, consumer confidence, and sound economics require the BSE import rules to be tightened according to pre-outbreak norms. This departure from the past Administration’s destructive policies will improve consumer confidence in the beef supply, balance trade flows, remedy the severe financial destruction of the U.S. cattle industry, and substantially decrease the risk of livestock and human disease exposure.
Additionally, the group points out that: “The proper policy is to bring United States’ BSE regulations in line with past standards, which were more closely aligned to the current standards of our trading partners. Animal health, as well as food and product safety, should be held in higher regard by your Administration than trade facilitation. Public support for such a change is clear. The industry need is clear. Consumer confidence would increase. The United States’ current trade imbalances would become more balanced. Risks to animal and human health would be drastically reduced.”
“Current trade policy is losing support, in large part, because food and product safety standards are negated by government efforts to facilitate cross-border trade at all costs, and this trade-trumping-safety policy problem includes, but also goes beyond, cattle and beef,” said R-CALF USA CEO Bill Bullard. “Because of USDA’s past and current persistence in adopting unproven and inapt international standards – rather than continuing pre-BSE disease standards proven to protect consumers of U.S. beef and U.S. citizens, including U.S. cattle producers and their livestock – the U.S. cattle industry is unnecessarily burdened by a flood of unsafe imports. The result is a large trade deficit in cattle and beef that is forcing thousands upon thousands of independent cattle producers out of business each year.”
National organizations that signed on to the letter include: American Grassfed Association; Coalition for a Prosperous America; Consumer Federation of America; CJD (Creutzfeldt-Jakob Disease) Foundation; Farm and Ranch Freedom Alliance; Food & Water Watch; Freedom21, Inc.; International Texas Longhorn Association; National Association of Farm Animal Welfare; National Farmers Union; Organic Consumers Association; Organization for Competitive Markets; R-CALF USA; Sovereignty International, Inc.; The Cornucopia Institute; Western Organization of Resource Councils.
State, regional and county organizations that signed on to the letter include: Buckeye Quality Beef Association (Ohio); Cattle Producers of Washington; Citizens for Private Property Rights, Missouri; Colorado Independent CattleGrower's Association; Independent Cattlemen of Nebraska; Independent Beef Association of North Dakota; Independent Cattlemen of Wyoming; Kansas Cattlemen’s Association; Kansas Farmers Union; Mississippi Livestock Markets Association; Missouri Farmers Union; Nebraska Farmers Union; Nevada Live Stock Association; New England Farmers Union; Northeast Organic Farming Association/Massachusetts Chapter, Inc.; Ohio Farmers Union; Oregon Livestock Producers Association; Ozarks Property Rights Congress, Missouri; PCC Natural Markets (Puget Consumers Co-Op); SmallHolders of Massachusetts; South Dakota Farmers Union; South Dakota Stockgrowers Association; Spokane County Cattlemen, Washington; and, the Stevens County Cattlemen, Washington.
http://www.cattlenetwork.com/R-CALF--40-Groups-Disagree-With-USDA-s-Latest-BSE-Court-Submission/2009-11-18/Article.aspx?oid=941864&fid=CN-LATEST_NEWS_
November 17, 2009
The Honorable Tom Vilsack Secretary of Agriculture U.S. Department of Agriculture 1400 Independence Ave., S.W. Washington, D.C. 20250
Re: Serious Concerns Regarding APHIS’ October 5, 2009 Status Report in R-CALF USA, et al. vs. USDA, et al.
Dear Secretary Vilsack:
On Oct. 5, 2009, the U.S. Department of Agriculture (USDA) provided notice to the United States District Court, District of South Dakota, Northern Division, that states the agency is preparing a docket to initiate rulemaking to amend its bovine spongiform encephalopathy (BSE) regulations regarding the importation of bovines and bovine products. The notice specifically states, “The proposed criteria for country classification and commodity import would be closely aligned with those of the World Organization for Animal Health.”1
We, the undersigned organizations, are deeply concerned with this proposed action and believe USDA is exhibiting a serious lack of judgment by attempting to align U.S. safety measures with the incessantly weak and demonstrably ineffective BSE standards established by the international World Organization for Animal Health (OIE). This proposed action would, if taken, abrogate your agency’s responsibility under the Animal Health Protection Act to protect U.S. livestock and the people of the United States from the introduction into and spread within the United States of animal diseases, particularly from such a pernicious animal disease as BSE that is invariably fatal and that also afflict humans.2 Your Administration must reverse, not perpetuate, the previous Administration’s dangerous policy of preempting sound animal health and human health protections to facilitate trade – a policy that not only has increased domestic health hazards, but also has caused serious economic harm to domestic industries.
USDA’s own risk assessment predicts, with a high level of certainty, that current regulations will cause the introduction and spread of fatal BSE within the United States. 3 The risk assessment further predicts that the people of the United States will be exposed to additional risk for the disease. These regulations, implemented by the prior Administration, defy USDA’s animal health protection mandate while stating, throughout their respective preambles, that the U.S. and Canada, as well as the rules themselves, are in conformity to OIE standards.4 The OIE standards cannot reasonably be expected to protect U.S. livestock and the people of the United States from the introduction and spread of BSE as required by the Animal Health Protection Act.
The OIE standards are not deemed credible. They have not been followed by any of the United States’ major export customers with which the United States maintains a positive trade balance. This situation has not changed in the past six years.5 Current trade policy is losing support, in large part, because food and product safety standards are negated by government
The Honorable Tom Vilsack November 17, 2009 Page 2
efforts to facilitate cross-border trade at all costs. The trade-trumping-safety policy problem includes, but also goes beyond, cattle and beef. Because of USDA’s past and current persistence in adopting unproven and inapt international standards – rather than continuing pre-BSE disease standards proven to protect consumers of U.S. beef and U.S. citizens, including U.S. cattle producers and their livestock – the U.S. cattle industry is unnecessarily burdened by a flood of unsafe imports. The result is a large trade deficit in cattle and beef that is forcing thousands upon thousands of independent cattle producers out of business each year.
The only countries that have scientifically demonstrated a reduction in the incidence of BSE are those that continue to require more BSE testing, stricter feed bans, and more stringent specified risk materials removal practices than the OIE requires.6 Canada, on the other hand, is the only BSE-affected country with multiple cases of BSE detected in animals born after a feed ban that does not require standards far more stringent than those established by the OIE. It is not surprising, therefore, that OIE reports show that Canada is the only BSE-affected country other than Portugal to have experienced an increased incidence of BSE between 2007 and 2008.7
President Barack Obama and Vice President Joseph Biden, Jr., have previously demonstrated their strong opposition to USDA’s final rule that reopened our borders to Canadian cattle and beef after BSE was detected in Canada. Then-Senators Obama and Biden voted in favor of a Senate Resolution of Disapproval declaring that USDA’s rule shall have no force or effect.8 The BSE problem in Canada has grown substantially worse since that Senate Resolution. At the time of their votes, only four cases of BSE had been detected in Canadian-born cattle, and no post-feed ban BSE cases were discovered. Since that time, seventeen (17) cases of BSE have been discovered in Canadian-born cattle. Eleven (11) of these seventeen (17) BSE-infected cattle were born after Canada’s 1997 feed ban. Ten (10) of these eleven (11) infected post-feed ban cattle were eligible, under USDA’s current rules, for export to the United States because they were born after March 1, 1999.9
The proper policy is to bring United States’ BSE regulations in line with past standards, which were more closely aligned to the current standards of our trading partners. Animal health, as well as food and product safety, should be held in higher regard by your Administration than trade facilitation. Public support for such a change is clear. The industry need is clear. Consumer confidence would increase. The United States’ current trade imbalances would become more balanced. Risks to animal and human health would be drastically reduced.
The U.S. is the largest beef consuming market in the world and the largest beef producing country in the world. 10 You have inherited the weakest, most ineffective and liberal BSE import policies when compared to every other major beef consuming market in the world. President Obama and Vice President Biden previously objected to the very rules that exist now. We respectfully request that you promulgate BSE rules that restore for U.S. livestock, livestock producers, and the people of the United States the highest possible level of protection against the introduction and spread of animal diseases. Valid science, consumer confidence, and sound economics require the BSE import rules to be tightened according to pre-outbreak norms. This departure from the past Administration’s destructive policies will improve consumer
The Honorable Tom Vilsack November 17, 2009 Page 3
confidence in the beef supply, balance trade flows, remedy the severe financial destruction of the U.S. cattle industry, and substantially decrease the risk of livestock and human disease exposure.
Sincerely,
National Organizations: American Grassfed Association Coalition for a Prosperous America Consumer Federation of America CJD Foundation Farm and Ranch Freedom Alliance Food & Water Watch Freedom21, Inc. International Texas Longhorn Association National Association of Farm Animal Welfare National Farmers Union Organic Consumers Association Organization for Competitive Markets R-CALF USA Sovereignty International, Inc. The Cornucopia Institute Western Organization of Resource Councils State, Regional and County Organizations: Buckeye Quality Beef Association (Ohio) Cattle Producers of Washington Citizens for Private Property Rights, Missouri Colorado Independent CattleGrower's Association Independent Cattlemen of Nebraska Independent Beef Association of North Dakota Independent Cattlemen of Wyoming Kansas Cattlemen’s Association Kansas Farmers Union Mississippi Livestock Markets Association Missouri Farmers Union Nebraska Farmers Union Nevada Live Stock Association New England Farmers Union Northeast Organic Farming Association/Massachusetts Chapter, Inc. Ohio Farmers Union Oregon Livestock Producers Association Ozarks Property Rights Congress, Missouri PCC Natural Markets (Puget Consumers Co-op) The Honorable Tom Vilsack November 17, 2009 Page 4 SmallHolders of Massachusetts South Dakota Farmers Union South Dakota Stockgrowers Association Spokane County Cattlemen, Washington Stevens County Cattlemen, Washington For More information or to contact individual organizations, please contact R-CALF USA at 406-252-2516 or r-calfusa@r-calfusa.com.
cc: Members of Congress
U.S. Centers for Disease Control and Prevention State Animal Health Officials
1 Defendant’s [USDA’s] Status Report, R-CALF USA et al. vs. USDA, et al., U.S. District Court, District of South Dakota, Northern Division, CIV-07-1023, Oct. 5, 2009. 2 See 7 U.S.C. § 8301 (1) (“the prevention, detection, control and eradication of diseases and pests of animals are essential to protect . . . animal health [and] the health and welfare of the people of the United States.”); see also 7 U.S.C. § 8303 (a) (1) (The Secretary of Agriculture “may prohibit or restrict . . . the importation or entry of any animal . . . if the Secretary determines that the prohibition or restriction is necessary to prevent the introduction into or dissemination within the United States of any pest or disease of livestock.”). 3 See 72 Fed. Reg., 1109, col. 2; 72 Fed. Reg., 53347, col. 1 (USDA’s risk modeling for its over-30-month rule (OTM Rule) predicts the U.S. would import between 19 and 105 BSE-infected cattle from Canada, which would subsequently produce BSE infections in 2 to 75 U.S.-born cattle over a 20-year period). 4 See, e.g., 72 Fed. Reg., 53331, col. 1 (USDA justifies a key decision in its rulemaking by stating it is “entirely consistent with the science and with OIE guidelines.”); see also id., 53341 (“Our proposed changes are consistent with the OIE guidelines for trade in live animals from a controlled risk region.”); see also id., 53342 (For the reasons discussed above, we disagree that this rule is inconsistent with OIE guidelines.”); see also 70 Fed. Reg., 510, col. 3 (“BSE incidence and surveillance in Canada are well within the OIE guidelines for BSE minimal Risk.”); see also id., 464, col. 2 (“our proposed standards for minimal-risk regions were based on the OIE guidelines for BSE minimal-risk regions, using those guidelines as a reference.”); see also, id., 476, col. 3 (“Canada again exceeds OIE guidelines. . .”); see also id., 471, col. 3 (“Although Canada does not precisely meet the OIE guideline for duration of a feed ban, its control measures in other areas (such as surveillance and import restrictions) more than compensate for this.”). 5 See Global Beef Trade: Effects of Animal Health, Sanitary, Food Safety, and Other Measures on U.S. Exports, U.S. International Trade Commission, USITC Publication No. 4033, September 2008, at 4-9 (Japan, with a 37.2% share of U.S. exports in 2003 disallows beef from cattle over 20 months and disallows ground beef; Korea, with a 21.2% share of U.S. exports in 2003 disallows beef from cattle over 30 months of age; Mexico, with a19.6% share of U.S. exports in 2003 disallows beef from cattle over 30 months of age.). 6 See, e.g., Appendix A – APHIS’ consideration of Japan in Light of the World Organization for Animal Health’s (OIE) Guidelines, Analysis of Bovine Spongiform Encephalopathy (BSE) Risk to the U.S. Cattle Population from Importation of Whole Cuts of Boneless Beef from Japan, Veterinary Services, Animal and Plant Health Inspection Services, U.S. Dept. of Agriculture, at 5 (“Since October 2001, all cattle slaughtered in Japan undergo an ELISA screening test, followed by a confirmation test. . .”), (Japan prohibits ruminant derived meat-and-bone meal in animal feed and requires separate feed manufacturing production lines used exclusively for cattle feed.); see also id., at 16 (Japan implemented a complete ban on the use of mammalian protein, including blood products); see also Export Requirements for Japan, U.S. Dept. of Agriculture Food Safety and Inspection Service, JA-179, Oct. 23, 2009 (Japan requires the removal of the spinal cord and spinal column from animals less than 21 months of age.). 7 See Annual incidence rate of bovine spongiform encephalopathy (BSE) in OIE Member Countries that have reported cases, excluding the United Kingdom, OIE, downloaded Oct. 28, 2009, available at http://www.oie.int/eng/info/en_esbincidence.htm. 8 With the help of now President Obama and Vice President Biden, the U.S. Senate in the 109th Congress passed S.J. Res. 4 by a vote of 52 to 46. The Senate Resolution provided for congressional disapproval of USDA’s final rule to The Honorable Tom Vilsack November 17, 2009 Page 5
designate Canada as a minimal-risk country and to allow imports of cattle and beef from cattle that originate in a BSE-affected country, namely Canada. 9 See BSE (Bovine Spongiform Encephalopathy, or Mad Cow Disease), Centers for Disease Control and Prevention, U.S. Department of Health and Human Services, available at http://www.cdc.gov/ncidod/dvrd/bse/index.htm. 10 See Livestock and Poultry: World Markets and Trade, U.S. Dept. of Agriculture, Foreign Agricultural Service, Circular Series April 2009, at 7 (U.S. beef and veal production and U.S. beef and veal consumption far surpass any other country in the world, e.g., the U.S. produced over 12 million metric tons while second place Brazil produced less than 9.1 million metric tons in 2008, and the U.S. consumed over 12 million metric tons while second place EU- 27 consumed less than 8.5 million metric tons during the same year.).
http://www.r-calfusa.com/BSE/091117-40%20Organizations
Tuesday, November 17, 2009
SEAC EFFECT OF AGE ON THE PATHOGENESIS OF TRANSMISSIBLE SPONGIFORM ENCEPHALOPATHIES SEAC 103/2 (USDA CERTIFIED DEAD STOCK DOWNER COW SCHOOL LUNCH PROGRAM)
http://downercattle.blogspot.com/2009/11/seac-effect-of-age-on-pathogenesis-of.html
Tuesday, November 17, 2009
SEAC NEW RESULTS ON IDIOPATHIC BRAINSTEM NEURONAL CHROMATOLYSIS (IBNC) FROM THE VETERINARY LABORATORIES AGENCY (VLA) SEAC 103/1
http://bse-atypical.blogspot.com/2009/11/seac-new-results-on-idiopathic.html
2009 UPDATE ON ALABAMA AND TEXAS MAD COWS 2005 and 2006
http://bse-atypical.blogspot.com/2006/08/bse-atypical-texas-and-alabama-update.html
Monday, October 19, 2009
Atypical BSE, BSE, and other human and animal TSE in North America Update October 2009
http://bse-atypical.blogspot.com/2009/10/atypical-bse-bse-and-other-human-and.html
Tuesday, November 10, 2009
Surveillance On the Bovine Spongiform Encephalopathy and rabies in Taiwan and USA
http://usdavskorea.blogspot.com/2009/11/surveillance-on-bovine-spongiform.html
Monday, November 16, 2009
CANADA, USA, specified risk materials (SRMs), Environment, Fertilizer, AND Politics, just more BSe
http://madcowspontaneousnot.blogspot.com/2009/11/canada-usa-specified-risk-materials.html
Thursday, November 05, 2009
Incidence and spectrum of sporadic Creutzfeldt-Jakob disease variants with mixed phenotype and co-occurrence of PrPSc types: an updated classification
http://creutzfeldt-jakob-disease.blogspot.com/2009/11/incidence-and-spectrum-of-sporadic.html
Sunday, August 10, 2008
A New Prionopathy OR more of the same old BSe and sporadic CJD
http://creutzfeldt-jakob-disease.blogspot.com/2008/08/new-prionopathy-or-more-of-same-old-bse.html
Monday, October 26, 2009
MAD COW DISEASE, AND U.S. BEEF TRADE
MAD COW DISEASE, CJD, TSE, SOUND SCIENCE, COMMERCE, AND SELLING YOUR SOUL TO THE DEVIL
http://usdameatexport.blogspot.com/2009/10/mad-cow-disease-and-us-beef-trade.html
IN A NUT SHELL ;
(Adopted by the International Committee of the OIE on 23 May 2006)
11. Information published by the OIE is derived from appropriate declarations made by the official Veterinary Services of Member Countries. The OIE is not responsible for inaccurate publication of country disease status based on inaccurate information or changes in epidemiological status or other significant events that were not promptly reported to the Central Bureau,
http://www.oie.int/eng/Session2007/RF2006.pdf
Docket APHIS-2006-0026 Docket Title Bovine Spongiform Encephalopathy; Animal Identification and Importation of Commodities Docket Type Rulemaking Document APHIS-2006-0026-0001 Document Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions, Identification of Ruminants and Processing and Importation of Commodities Public Submission APHIS-2006-0026-0012 Public Submission Title Comment from Terry S Singletary
http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=09000064801e47e1
Docket APHIS-2006-0041 Docket Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived from Bovines Commodities Docket Type Rulemaking Document APHIS-2006-0041-0001 Document Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived From Bovines Public Submission APHIS-2006-0041-0028 Public Submission Title Comment from Terry S Singletary
Comment 2006-2007 USA AND OIE POISONING GLOBE WITH BSE MRR POLICY
THE USA is in a most unique situation, one of unknown circumstances with human and animal TSE. THE USA has the most documented TSE in different species to date, with substrains growing in those species (BSE/BASE in cattle and CWD in deer and elk, there is evidence here with different strains), and we know that sheep scrapie has over 20 strains of the typical scrapie with atypical scrapie documented and also BSE is very likely to have passed to sheep. all of which have been rendered and fed back to animals for human and animal consumption, a frightening scenario. WE do not know the outcome, and to play with human life around the globe with the very likely TSE tainted products from the USA, in my opinion is like playing Russian roulette, of long duration, with potential long and enduring consequences, of which once done, cannot be undone. These are the facts as I have come to know through daily and extensive research of TSE over 9 years, since 12/14/97. I do not pretend to have all the answers, but i do know to continue to believe in the ukbsenvcjd only theory of transmission to humans of only this one strain from only this one TSE from only this one part of the globe, will only lead to further failures, and needless exposure to humans from all strains of TSE, and possibly many more needless deaths from TSE via a multitude of proven routes and sources via many studies with primates and rodents and other species.
MY personal belief, since you ask, is that not only the Canadian border, but the USA border, and the Mexican border should be sealed up tighter than a drum for exporting there TSE tainted products, until a validated, 100% sensitive test is available, and all animals for human and animal consumption are tested. all we are doing is the exact same thing the UK did with there mad cow poisoning when they exported it all over the globe, all the while knowing what they were doing. this BSE MRR policy is nothing more than a legal tool to do just exactly what the UK did, thanks to the OIE and GW, it's legal now. and they executed Saddam for poisoning ???
go figure. ...
http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=09000064801f8151
Docket APHIS-2006-0041 Docket Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived from Bovines Commodities Docket Type Rulemaking Document APHIS-2006-0041-0001 Document Title Bovine Spongiform Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products Derived From Bovines Public Submission APHIS-2006-0041-0028.1 Public Submission Title Attachment to Singletary comment
January 28, 2007
Greetings APHIS,
I would kindly like to submit the following to ;
BSE; MRR; IMPORTATION OF LIVE BOVINES AND PRODUCTS DERIVED FROM BOVINES [Docket No. APHIS-2006-0041] RIN 0579-AC01
http://www.regulations.gov/fdmspublic/ContentViewer?objectId=09000064801f8152&disposition=attachment&contentType=msw8
Subject: Importation of Whole Cuts of Boneless Beef from Japan [Docket No. 05-004-1] RIN 0579-AB93 TSS SUBMISSION
Date: August 24, 2005 at 2:47 pm PST
August 24, 2005
Importation of Whole Cuts of Boneless Beef from Japan [Docket No. 05-004-1] RIN 0579-AB93 TSS SUBMISSION
Greetings APHIS ET AL,
My name is Terry S. Singeltary Sr.
I would kindly like to comment on [Docket No. 05-004-1] RIN 0579-AB93 ;
PROPOSED RULES
Exportation and importation of animals and animal products:
Whole cuts of boneless beef from-
Japan,
48494-48500 [05-16422]
http://www.regulations.gov/fdmspublic/ContentViewer?objectId=0900006480086ebc&disposition=attachment&contentType=msw6
Docket No. 03-080-1 -- USDA ISSUES PROPOSED RULE TO ALLOW LIVE ANIMAL IMPORTS FROM CANADA
https://web01.aphis.usda.gov/BSEcom.nsf/0/b78ba677e2b0c12185256dd300649f9d?OpenDocument&AutoFramed
PLEASE SEE FULL TEXT HERE ;
Docket No. 03-080-1 -- USDA ISSUES PROPOSED RULE TO ALLOW LIVE ANIMAL IMPORTS FROM CANADA
http://madcowfeed.blogspot.com/2008/07/docket-no-03-080-1-usda-issues-proposed.html
Thursday, November 12, 2009
BSE FEED RECALL Misbranding of product by partial label removal to hide original source of materials 2009
http://madcowfeed.blogspot.com/2009/11/bse-feed-recall-misbranding-of-product.html
Friday, September 4, 2009
FOIA REQUEST ON FEED RECALL PRODUCT 429,128 lbs. feed for ruminant animals may have been contaminated with prohibited material Recall # V-258-2009
http://madcowfeed.blogspot.com/2009/09/foia-request-on-feed-recall-product.html
Saturday, August 29, 2009
FOIA REQUEST FEED RECALL 2009 Product may have contained prohibited materials Bulk Whole Barley, Recall # V-256-2009
http://madcowfeed.blogspot.com/2009/08/foia-request-feed-recall-2009-product.html
http://madcowtesting.blogspot.com/
Saturday, October 24, 2009
SaBTO Advisory Committee on the Safety of Blood, Tissues and Organs 2nd Public Meeting 27 October 2009
http://seac992007.blogspot.com/2009/10/sabto-advisory-committee-on-safety-of.html
Wednesday, November 04, 2009
Detection of PrPsc in Blood from Sheep Infected with the Scrapie and Bovine Spongiform Encephalopathy Agents
http://vcjdtransfusion.blogspot.com/2009/11/detection-of-prpsc-in-blood-from-sheep.html
HUMAN and ANIMAL TSE Classifications i.e. mad cow disease and the UKBSEnvCJD only theory
http://www.regulations.gov/search/Regs/contentStreamer?objectId=090000648027c28e&disposition=attachment&contentType=pdf
Wednesday, November 18, 2009
BSE RISK USA UPDATE NOVEMBER 2009
http://bseusa.blogspot.com/2009/11/bse-risk-usa-update-november-2009.html
Sunday, April 12, 2009
BSE MAD COW TESTING USA 2009 FIGURES
Month Number of Tests
Feb 2009 -- 1,891
Jan 2009 -- 4,620
http://www.aphis.usda.gov/newsroom/hot_issues/bse/surveillance/ongoing_surv_results.shtml
http://madcowtesting.blogspot.com/2009/04/bse-mad-cow-testing-usa-2009-figures.html
PLEASE SEE MY FULL COMMENT SUBMISSION IN THE PDF ATTACHMENT, OR GO HERE
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/docket-no-fda2002n0031-formerly-docket.html
http://prionunitusaupdate2008.blogspot.com/2009/04/r-calf-and-usa-mad-cow-problem-dont.html#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.com/2009/04/r-calf-and-usa-mad-cow-problem-dont.html
http://prionunitusaupdate2008.blogspot.com/2009/04/cjd-foundation-sides-with-r-calfers-no.html#comments
MY comments/questions are as follows ; 1. SINCE the first Harvard BSE Risk Assessment was so flawed and fraught with error after the PEER REVIEW assessment assessed this fact, how do you plan on stopping this from happening again, will there be another peer review with top TSE Scientist, an impartial jury so-to-speak, to assess this new and updated Harvard BSE/TSE risk assessment and will this assessment include the Atypical TSE and SRM issues ?
*** Suppressed peer review of Harvard study October 31, 2002 ***
http://www.fsis.usda.gov/oa/topics/BSE_Peer_Review.pdf
***
http://www.scribd.com/doc/1490709/USDA-200600111
***
http://www.fsis.usda.gov/OPPDE/Comments/2006-0011/2006-0011-1.pdf
***
http://www.regulations.gov/search/Regs/contentStreamer?objectId=090000648027c28e&disposition=attachment&contentType=pdf
***
http://www.fsis.usda.gov/OPPDE/Comments/2006-0011/2006-0011-1.pdf
***
Response to Public Comments on the Harvard Risk Assessment of ... RESPONSE TO COMMENTS FROM TERRY S. SINGELTARY SR. Comment #1: SINCE the first Harvard BSE Risk Assessment was so flawed and fraught ...
http://www.fsis.usda.gov/PDF/BSE_Risk_Assess_Response_Public_Comments.pdf
TSS
Labels: atypical bse, Canada, cjd, mad cow disease, prion, r-calf, USA
posted by Terry S. Singeltary Sr. at
4:41 PM
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