R-CALF Submits Incomplete Comments Under Protest in Bizarre Rulemaking
“Bovine Spongiform Encephalopathy; Importation of Bovines and Bovine Products”
Incomplete Comments Under Protest in Bizarre Rulemaking
Billings, MT – To meet the June 14 “Bovine Spongiform Encephalopathy;
Importation of Bovines and Bovine Products” (Proposed Rule) comment deadline,
R-CALF USA submitted incomplete comments. In a note before the 172-page
comprehensive incomplete comments, R-CALF USA states, “R-CALF USA protests
USDA’s refusal to grant sufficient time for the public to thoroughly evaluate
this Proposed Rule. This Proposed Rule represents an extraordinarily bizarre and
obfuscated rulemaking.”
“This Proposed Rule by the Obama Administration represents a greater risk
to the safety of our U.S. food supply than any previous rulemaking by any
previous Administration in recent memory,” said R-CALF USA CEO Bill Bullard.
R-CALF USA begins its comments by sharing the basic structure of the Proposed
Rule. The group calls it an amalgamation of three rulemakings rolled into one.
“The first rulemaking is APHIS’ mandatory response to Federal District
Court Judge Lawrence L. Piersol’s Memorandum Opinion and Order on Motion for
Preliminary Injunction issued July 3, 2008, in a lawsuit filed against APHIS by
R-CALF USA, Herman Schumacher, Robert Mack, Ernie Mertz, Wayne Nelson, South
Dakota Stockgrowers Association, Center for Food Safety, Consumers Federation of
America, Creutzfeldt-Jacob Disease Foundation, Inc., Food & Water Watch, and
Public Citizen. In his injunction order, Judge Piersol ordered APHIS to, inter
alia, revise any provisions of APHIS’ rule entitled “Bovine Spongiform
Encephalopathy; Minimal-Risk Regions; Importation of Live Bovines and Products
Derived from Bovines,” (OTM Rule) published at 72 Fed. Reg., 53314-53379 that
APHIS deemed necessary after issuing a notice for public comments
“The second rulemaking in the amalgamated Proposed Rule is a quandary: On
the one hand APHIS claims in its first rulemaking that it did not deem it
necessary to revise any provisions in its OTM Rule pursuant to Judge Piersol’s
order. However, on the other hand, and as described below, APHIS’s second
rulemaking simultaneously makes substantive revisions to the OTM Rule, including
revisions to the very provisions APHIS claimed were essential to its affirmation
of the OTM Rule.
“The third rulemaking rolled into the Proposed Rule is an effort by APHIS
to designate certain countries eligible to export ruminants and/or ruminant
products to the United States, even if, as shown below, a country is affected by
BSE and APHIS does not know whether BSE is progressing or declining within those
countries.”
R-CALF USA continues its line of direct and honest evaluation in arguments
from A to LL, and in six appendices. Each argument lends itself to the same
conclusion – one that is written in the comments, “The Proposed OTM Rule is
inconsistent with the congressional mandate to protect the health of U.S.
livestock and the welfare of the American people by preventing the introduction
and dissemination of infectious diseases, particularly one as pernicious as
BSE.” “The Proposed Rule is unsalvageable and needs to be completely rewritten,”
concluded Bullard.
# # #
R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of
America) is a national, nonprofit organization dedicated to ensuring the
continued profitability and viability of the U.S. cattle industry. For more
information, visit www.r-calfusa.com or, call 406-252-2516.
APHIS, Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238
Via Facsimile and Federal Rulemaking Portal: www.regulations.gov
Re: R-CALF USA Comments in Docket No. APHIS-2008-0010: Bovine Spongiform
Encephalopathy; Importation of Bovines and Bovine Products, Proposed Rule
Notice: R-CALF USA protests USDA’s refusal to grant sufficient time for the
public to thoroughly evaluate this Proposed Rule. This Proposed Rule represents
an extraordinarily bazaar and obfuscated rulemaking: On the one-hand it solicits
public comment on USDA’s proposal to affirm the OTM Rule (which comprises about
one-third of the Proposed Rule), and in the same breath used to state it was not
making any changes to the OTM Rule, USDA nevertheless solicits public comments
on its proposal to change the OTM Rule. R-CALF USA made four timely requests
(now included in the record) for an extension to the comment period of not less
than 60 days. R-CALF USA’s requests included legitimate and supportable reasons
for the need for an extension of not less than 60 days, not the least of which
is the fact that USDA announced the detection of a new BSE case in California on
April 24, 2012, and USDA has not yet completed its epidemiological investigation
of that case. Further, when USDA made the public announcement regarding the
infected cow, it immediately attempted to assuage public concerns by assuring
the public that the infected animal did not enter the food supply; that the feed
ban is a primary control measure for BSE; and, it definitively stated that the
strain of BSE detected was not generally associated with an animal consuming
feed. The Proposed Rule, however, asserts that preventing BSE-infected cattle
from entering the food supply is no longer essential to protecting public
health; that requiring imported beef to be derived only from animals not subject
to a feed ban for their entire lives is not essential to protecting public
health. And, the Proposed Rule is silent on BSE transmission not caused either
by the consumption of contaminated feed or by maternal transmission. For these
and the other legitimate reasons R-CALF USA included in its four separate
requests for an extension of not less than 60 days, the public must not be
denied a right to comment on this Proposed Rule for at least 60 days following
the completion of USDA’s epidemiological investigation of the California Cow.
R-CALF United Stockgrowers of America
P.O. Box 30715
Billings, MT 59107
Fax: 406-252-3176
Phone: 406-252-2516
Website: www.r-calfusa.com
E-mail: r-calfusa@r-calfusa.com
2
R-CALF USA’s comments below are incomplete as USDA did not provide adequate
time for a careful and thorough public evaluation of this extraordinarily
unusual and complex rule.
Dear Administrator:
The Ranchers-Cattlemen Action Legal Fund – United Stockgrowers of America
(R-CALF USA) appreciates this opportunity to submit comments on the U.S.
Department of Agriculture (USDA) Animal and Plant Health Inspection Service’s
(APHIS’s) proposed rule entitled Bovine Spongiform Encephalopathy; Importation
of Bovines and Bovine Products, (Proposed Rule) published at 77 Fed. Reg.,
15848-15913 (March 16, 2012).
R-CALF USA is a non-profit cattle-producer association that represents
thousands of U.S. cattle producers in 45 states. R-CALF USA’s mission is to
ensure the continued profitability and viability of independent U.S. cattle
producers. The demographics of R-CALF USA’s membership are reflective of the
demographics of the entire U.S. cattle industry, with membership ranging from
the largest of U.S. cattle producers to the smallest. R-CALF USA’s membership
consists primarily of cow-calf operators, cattle backgrounders, and feedlot
owners. Various main street businesses are associate members of R-CALF USA. In
addition to being producers of cattle, R-CALF USA members are also beef
consumers and responsible stewards of the environment.
I. INTRODUCTION
snip...see full text 172 pages ;
Thursday, June 14, 2012
R-CALF USA Calls USDA Dishonest and Corrupt; Submits Fourth Request for
Extension
R-CALF United Stockgrowers of America
Friday, May 25, 2012
R-CALF USDA’s New BSE Rule Eliminates Important Protections Needed to
Prevent BSE Spread
Subject: Bovine Spongiform Encephalopathy; Importation of Bovines and
Bovine Products APHIS-2008-0010-0008 RIN:0579-AC68
Comment from Terry Singeltary Document ID: APHIS-2008-0010-0008 Document
Type: Public Submission This is comment on Proposed Rule: Bovine Spongiform
Encephalopathy; Importation of Bovines and Bovine Products Docket ID:
APHIS-2008-0010 RIN:0579-AC68
Topics: No Topics associated with this document View Document: More
Document Subtype: Public Comment Status: Posted Received Date: March 22 2012, at
12:00 AM Eastern Daylight Time Date Posted: March 22 2012, at 12:00 AM Eastern
Daylight Time Comment Start Date: March 16 2012, at 12:00 AM Eastern Daylight
Time Comment Due Date: May 15 2012, at 11:59 PM Eastern Daylight Time Tracking
Number: 80fdd617 First Name: Terry Middle Name: S. Last Name: Singeltary City:
Bacliff Country: United States State or Province: TX Organization Name: CJD TSE
PRION Submitter's Representative: CONSUMERS
Comment: comment submission Document ID APHIS-2008-0010-0001
Greetings USDA,
OIE et al, what a difference it makes with science, from one day to the
next. i.e. that mad cow gold card the USA once held. up until that fateful day
in December of 2003, the science of BSE was NO IMPORTS TO USA FROM BSE COUNTRY.
what a difference a day makes$ now that the shoe is on the other foot, the USDA
via the OIE, wants to change science again, just for trade $ I implore the OIE
decision and policy makers, for the sake of the world, to refuse any status quo
of the USA BSE risk assessment. if at al, the USA BSE GBR should be raise to BSE
GBR IV, for the following reasons. North America is awash with many different
TSE Prion strains, in many different species, and they are mutating and
spreading. IF the OIE, and whatever policy makers, do anything but raise the
risk factor for BSE in North America, they I would regard that to be highly
suspicious. IN fact, it would be criminal in my opinion, because the OIE knows
this, and to knowingly expose the rest of the world to this dangerous pathogen,
would be ‘knowingly’ and ‘willfully’, just for the almighty dollar, once again.
I warned the OIE about all this, including the risk factors for CWD, and the
fact that the zoonosis potential was great, way back in 2002. THE OIE in
collaboration with the USDA, made the legal trading of the atypical Nor-98
Scrapie a legal global commodity. yes, thanks to the OIE and the USDA et al,
it’s now legal to trade the atypical Nor-98 Scrapie strain all around the globe.
IF you let them, they will do the same thing with atypical BSE and CWD (both
strains to date). This with science showing that indeed these TSE prion strains
are transmissible. I strenuously urge the OIE et al to refuse any weakening to
the USA trade protocols for the BSE TSE prion disease (all strains), and urge
them to reclassify the USA with BSE GBR IV risk factor.
SEE REFERENCE SOURCES IN ATTACHMENTS
PLEASE SEE Terry S. Singeltary Sr. _Attachment_ WORD FILE ;
Monday, June 18, 2012
Johanns Introduces Legislation Banning EPA Aerial Surveillance on feedlots
just more BSe
PO-028: Oral transmission of L-type bovine spongiform encephalopathy
(L-BSE) in primate model Microcebus murinus
Nadine Mestre-Frances,1 Simon Nicot,2 Sylvie Rouland,1 Anne-Gaëlle
Biacabe,2 Isabelle Quadrio,3 Armand Perret-Liaudet,3 Thierry Baron,2 Jean-Michel
Verdier1 1IN SER M UM2; Montpellier, France; 2Anses; Lyon, France; 3Hopitaux
Civils de Lyon; Lyon, France
An atypical form of bovine spongiform encephalopathy has been identified in
cattle in Europe, North America and Japan and was designed as L-type BSE (L-BSE)
due to the lower apparent molecular mass of the unglycosylated,
protease-resistant prion protein (PrPres) detected by western blot compared with
classical BSE. Experimental evidences from studies in transgenic mice expressing
human PrP and in primate models suggest a higher risk of transmission to humans
of the L-BSE form than for classical BSE agent. However, a major unresolved
issue concerns the potential transmissibility of the L-BSE agent by oral route.
To address this question, we infected mouse lemurs (Microcebus murinus), a
non-human primate model, with L-BSE by intracerebral or oral route.
Four adult lemurs were intracerebrally (IC) inoculated with 5mg of L-BSE
infected brain homogenate of an atypical French BSE case (02-2528). Four young
and four adult animals were fed with 5 mg or 50 mg of infected brain. After
sacrifice, the brain tissues were biochemically and immunocytochemically
investigated for PrPres.
The 4 animals IC inoculated died at 19 and 22 months postinoculation (mpi).
They developed blindness, tremor, abnormal posture, incoordinated movements,
balance loss. Symptoms get worse according to the disease progression, until
severe ataxia. Severe spongiosis was evidenced into the thalamus, the striatum,
the mesencephalon, and the brainstem, whereas into the cortex the vacuolisation
was weaker. Strong deposits of PrPres were detected into the thalamus, the
striatum, and the hippocampus whereas in the cerebral cortex, PrPres was
prominently accumulated in plaques.
The orally inoculated animals showed similar clinical symptoms occurring
between 27 and 34 mpi. Disease was characterized by progressive prostration,
loss of appetite and poor appearance of the fur. Only one adult animal showed
disequilibrium. PrPres was strongly accumulated only in the striatum and
thalamus and weakly into the cortex. No plaques were evidenced. Two animals that
were orally challenged at the age of two years are still alive and healthy 34
months after inoculation. The western blot analysis showed uniform molecular
profiles, irrespective of the route or dose of infection, and included notably a
PrPres form with low apparent molecular mass (~19 kDa) similar to the PrPres in
the original cattle brain. However, the PrPres profile in lemurs was
characterized by a higher proportion of di- and mono-glycosylated species (up to
95% of the total signal) than in the bovine L-BSE inoculum (~80%). In addition,
small amounts of PrPres were detected by western blotting in the spleen of three
animals (one intra-cerebrally inoculated and two fed with 5 mg of cattle
brain).
Here, we demonstrate that the L-BSE agent can be transmitted by oral route
from cattle to young and adult mouse lemurs. In comparison to IC inoculated
animals, orally challenged lemurs were characterized by longer survival periods
as expected with this route of infection.
Friday, May 25, 2012
R-CALF USDA’s New BSE Rule Eliminates Important Protections Needed to
Prevent BSE Spread
Saturday, May 26, 2012
Are USDA assurances on mad cow case 'gross oversimplification'?
SNIP...
What irks many scientists is the USDA’s April 25 statement that the rare
disease is “not generally associated with an animal consuming infected
feed.”
The USDA’s conclusion is a “gross oversimplification,” said Dr. Paul Brown,
one of the world’s experts on this type of disease who retired recently from the
National Institutes of Health. "(The agency) has no foundation on which to base
that statement.”
“We can’t say it’s not feed related,” agreed Dr. Linda Detwiler, an
official with the USDA during the Clinton Administration now at Mississippi
State.
In the May 1 email to me, USDA’s Cole backed off a bit. “No one knows the
origins of atypical cases of BSE,” she said
The argument about feed is critical because if feed is the cause, not a
spontaneous mutation, the California cow could be part of a larger outbreak.
SNIP...
Sunday, May 27, 2012
CANADA PLANS TO IMPRISON ANYONE SPEAKING ABOUT MAD COW or ANY OTHER DISEASE
OUTBREAK
CENSORSHIP IS A TERRIBLE THING
Sunday, May 27, 2012
GAIN REPORT BSE Case in United States Will Not Affect Trade, States
Canadian Food Inspection Agency
Subject: Bovine Spongiform Encephalopathy; Importation of Bovines and
Bovine Products APHIS-2008-0010-0008 RIN:0579-AC68
Comment from Terry Singeltary Document ID: APHIS-2008-0010-0008 Document
Type: Public Submission This is comment on Proposed Rule: Bovine Spongiform
Encephalopathy; Importation of Bovines and Bovine Products Docket ID:
APHIS-2008-0010 RIN:0579-AC68
Topics: No Topics associated with this document View Document: More
Document Subtype: Public Comment Status: Posted Received Date: March 22 2012, at
12:00 AM Eastern Daylight Time Date Posted: March 22 2012, at 12:00 AM Eastern
Daylight Time Comment Start Date: March 16 2012, at 12:00 AM Eastern Daylight
Time Comment Due Date: May 15 2012, at 11:59 PM Eastern Daylight Time Tracking
Number: 80fdd617 First Name: Terry Middle Name: S. Last Name: Singeltary City:
Bacliff Country: United States State or Province: TX Organization Name: CJD TSE
PRION Submitter's Representative: CONSUMERS
Comment: comment submission Document ID APHIS-2008-0010-0001
Greetings USDA,
OIE et al, what a difference it makes with science, from one day to the
next. i.e. that mad cow gold card the USA once held. up until that fateful day
in December of 2003, the science of BSE was NO IMPORTS TO USA FROM BSE COUNTRY.
what a difference a day makes$ now that the shoe is on the other foot, the USDA
via the OIE, wants to change science again, just for trade $ I implore the OIE
decision and policy makers, for the sake of the world, to refuse any status quo
of the USA BSE risk assessment. if at al, the USA BSE GBR should be raise to BSE
GBR IV, for the following reasons. North America is awash with many different
TSE Prion strains, in many different species, and they are mutating and
spreading. IF the OIE, and whatever policy makers, do anything but raise the
risk factor for BSE in North America, they I would regard that to be highly
suspicious. IN fact, it would be criminal in my opinion, because the OIE knows
this, and to knowingly expose the rest of the world to this dangerous pathogen,
would be ‘knowingly’ and ‘willfully’, just for the almighty dollar, once again.
I warned the OIE about all this, including the risk factors for CWD, and the
fact that the zoonosis potential was great, way back in 2002. THE OIE in
collaboration with the USDA, made the legal trading of the atypical Nor-98
Scrapie a legal global commodity. yes, thanks to the OIE and the USDA et al,
it’s now legal to trade the atypical Nor-98 Scrapie strain all around the globe.
IF you let them, they will do the same thing with atypical BSE and CWD (both
strains to date). This with science showing that indeed these TSE prion strains
are transmissible. I strenuously urge the OIE et al to refuse any weakening to
the USA trade protocols for the BSE TSE prion disease (all strains), and urge
them to reclassify the USA with BSE GBR IV risk factor.
SEE REFERENCE SOURCES IN ATTACHMENTS
PLEASE SEE Terry S. Singeltary Sr. _Attachment_ WORD FILE ;
***Also, a link is suspected between atypical BSE and some apparently
sporadic cases of Creutzfeldt-Jakob disease in humans. These atypical BSE cases
constitute an unforeseen first threat that could sharply modify the European
approach to prion diseases.
Second threat
snip...
MAD COW USDA ATYPICAL L-TYPE BASE BSE, the rest of the story...
***Oral Transmission of L-type Bovine Spongiform Encephalopathy in Primate
Model
***Infectivity in skeletal muscle of BASE-infected cattle
***feedstuffs- It also suggests a similar cause or source for atypical BSE
in these countries.
***Also, a link is suspected between atypical BSE and some apparently
sporadic cases of Creutzfeldt-Jakob disease in humans.
The present study demonstrated successful intraspecies transmission of
H-type BSE to cattle and the distribution and immunolabeling patterns of PrPSc
in the brain of the H-type BSE-challenged cattle. TSE agent virulence can be
minimally defined by oral transmission of different TSE agents (C-type, L-type,
and H-type BSE agents) [59]. Oral transmission studies with H-type BSEinfected
cattle have been initiated and are underway to provide information regarding the
extent of similarity in the immunohistochemical and molecular features before
and after transmission.
In addition, the present data will support risk assessments in some
peripheral tissues derived from cattle affected with H-type BSE.
in the url that follows, I have posted
SRM breaches first, as late as 2011.
then
MAD COW FEED BAN BREACHES AND TONNAGES OF MAD COW FEED IN COMMERCE up until
2007, when they ceased posting them.
then,
MAD COW SURVEILLANCE BREACHES.
Friday, May 18, 2012
Update from APHIS Regarding a Detection of Bovine Spongiform Encephalopathy
(BSE) in the United States Friday May 18, 2012
Wednesday, May 30, 2012
PO-028: Oral transmission of L-type bovine spongiform encephalopathy
(L-BSE) in primate model Microcebus murinus
TSS
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