HSUS VS USDA ET AL BAN DOWNER CALVES FOR HUMAN CONSUMPTION (*veal)
BEFORE THE UNITED STATES
DEPARTMENT OF AGRICULTURE
FOOD SAFETY AND INSPECTION SERVICE
THE HUMANE SOCIETY OF THE UNITED STATES
Petitioner.
v.
HONORABLE TOM VILSACK, SECRETARY,
UNITED STATES DEPARTMENT OF AGRICULTURE
JEROLD R. MANDE DEPUTY UNDER SECRETARY FOR FOOD SAFETY
Respondent.
Gina Tomaselli Peter A. Brandt The Humane Society of the United States 2100
L Street, NW Washington, DC 20037 Telephone: (202) 452-1100 Facsimile: (202)
778-6132
I. INTRODUCTION
This petition is submitted on behalf of The Humane Society of the United
States ("The HSUS") to request closure of a regulatory loophole that facilitates
the cruel mistreatment of calves too weak, sick or injured to stand and walk.1
Specifically, Petitioner requests that the United States Department of
Agriculture, Food Safety and Inspection Service (USDA), repeal a provision in
section 309.13(b) of the Code of Federal Regulations that allows veal calves who
are unable to rise from a recumbent position because they are thought to be
"tired or cold" to be "set apart and held" for treatment and potential slaughter
for human consumption.
Although USDA has repeatedly made clear the need for an absolute,
unqualified prohibition against the slaughter of non-ambulatory “downer”
cattle,2 the current regulations undermine that humane policy with a regulatory
exemption that allows establishments to “set aside” and later slaughter veal
calves who are deemed too tired or cold to rise or walk.3 This provision
directly contravenes both USDA’s publicly stated goal of
1 Requirements for the Disposition of Cattle that Become Non-Ambulatory
Disabled Following Ante-Mortem Inspection, 74 Fed. Reg. 11,463 (March 18, 2009)
(to becodified at 9 C.F.R. pt. 309) (“The Humane Methods of Slaughter Act of
1978 (HMSA) (Section 1901, 1902, and 1906) requires that livestock, including
non-ambulatory disabled cattle, be humanely handled in connection with
slaughter. Because the HMSA and regulations require that non-ambulatory disabled
cattle be humanely handled, FSIS has determined that it is not necessary to
amend this regulation because humane handling requires that such cattle be
promptly euthanized.”)(emphasis added) (hereinafter 2009 Final Rule). 2 See
Press release, United States Department of Agriculture, Agriculture SecretaryEd
Schafer Announces Plan to End Exceptions to Animal Handling Rule (May 20,2008),
available at http://www.usda.gov/wps/portal/!ut/p/_s.7_0_A/7_0_1OB?contentidonly=true&contentid=2008/05/0131.xml
(last visited Oct. 21, 2009) (hereinafter Schafer Press Release);see generally,
2009 Final Rule, 74 Fed. Reg. at 11,463. 3 9 C.F.R. § 309.13(b).
1
eliminating all exceptions to the downer cattle rule,4 and the overarching
purposes of the Humane Methods of Slaughter Act (HMSA),5 which USDA has
specifically interpreted to require “prompt[] euthan[asia]” of all
non-ambulatory cattle.6
As explained below, USDA has ample legal authority under the Humane Methods
of Slaughter Act and the Federal Meat Inspection Act (FMIA)7 to include veal
calves within the prohibition against the slaughter for human consumption of
non-ambulatory cattle and to require that they be promptly euthanized.
As graphically demonstrated by a recent investigation into practices at the
Bushway Packing plant in Grand Isle, Vermont, veal calves too sick, weak or
injured to stand at slaughterhouses endure horrific abuse. Non-ambulatory calves
were regularly and repeatedly kicked and shocked in their necks, faces, and
torsos in an effort to force them to move off arriving trucks, to holding pens,
or to the slaughter line. Moreover, this egregious cruelty took place in front a
Food Safety and Inspection Service (FSIS) inspector, who routinely failed to
take any remedial action or halt the abuse. Both the conduct of the
slaughterhouse employees and the inaction on the part of the inspector were
facilitated by USDA regulations, which, as explained below, are confusing and
burdensome. Moreover, these regulations inadvertently incentivize
slaughterhouses to move downed calves by inhumane methods
and allow these calves, who likely suffer from illness, injury, or
debilitating
and irreversible weakness, to be kept alive and in agony
indefinitely.8
The HMSA clearly states that “handling in connection with
slaughtering” does not “comply with the public policy of the United
States
unless it is humane.”9 Because USDA has interpreted that Act as
mandating
prompt euthanasia for mature cattle too sick or injured to stand, and
because
the same humane-spirited reasons and the same legal standard apply to
calves, Petitioner respectfully requests that the agency grant this
petition
and require that prone immobilized calves, as well as mature cattle,
be
humanely and immediately euthanized.
4 See generally, Schafer Press Release, supra note 2.
5 7 U.S.C. §1901 et seq. (2006).
6 2009 Final Rule, 74 Fed. Reg. 11,463, 11,464-65 (emphasis added).
7 21 U.S.C. 601 et. seq. (2006).
2
II. INTERESTS OF THE PETITIONERS
Petitioner The Humane Society of the United States (HSUS) is a
nonprofit
organization that promotes the protection of all animals. The HSUS
maintains its headquarters in Washington, DC and is the largest
animal
protection organization in the United States, with more than eleven
million
members and constituents. The HSUS actively advocates against
practices
8 The regulation that allows non-ambulatory calves to be “set apart” and
“held” provides no time frame for how long the calves may be kept alive nor does
it have any requirement that after a certain amount of time they must be killed
if they cannotrise or walk. See 9 C.F.R. § 309.13(b). This is especially
problematic asnoncompliance reports reveal that such calves are regularly denied
water, contrary to USDA regulation 9 C.F.R. § 313.2(e), thus subjecting them to
further unnecessarysuffering. See, e.g., United States Department of
Agriculture, Food Safety and Inspection Service, Noncompliance Record No.
25-2002-2775 (Nov. 21, 2002) (noting failure to provide water and that “some
feeble attempts have been made at providing water to the outside pen. None of
them assure there is water accessible at all times.”) (see Attach. 1); NR No.
0011-2005-5699 (June 30, 2005) (observing that calves who had no access to water
in 90 degree weather were “foaming at the mouth and gaspingfor breath”) (see
Attach. 2); NR No. 0005-2003-2775 (Feb. 19, 2003) (see Attach. 3);NR No.
0012-2006-6525 (March 9, 2006) (calves, cattle and 150 goats either had empty
water containers or frozen solid water) (see Attach. 4); NR No. 3-2004-3564
(Feb. 23, 2004) (see Attach. 5). 9 7 U.S.C. § 1902 (see Attach. 6).
3
that injure or abuse farm animals and promotes more humane slaughter of
animals killed for human consumption. Furthermore, The HSUS offers information
regarding the inhumane treatment of animals on a wide spectrum of topics,
including the effects of the stress and inhumane treatment that occur in
slaughterhouses.
III. ACTION REQUESTED
Pursuant to the Right to Petition Government Clause contained in the First
Amendment of the United States Constitution,10 the Administrative Procedure
Act,11 and USDA’s implementing regulations,12 Petitioner submits this petition
for rulemaking under the Humane Methods of Slaughter Act requesting that the
Secretary take action to comply with the express intent of Congress to protect
the welfare of all livestock held at slaughterhouses. The requested relief is
also appropriate under the Federal Meat Inspection Act, which requires the
Secretary to maintain the safety of our nation’s meat supply.13 Specifically,
Petitioner requests that USDA:
1. Remove the exemption allowing non-ambulatory veal calves to be set aside
and eventually slaughtered for human consumption; and
2. Require that all non-ambulatory veal calves be immediately and humanely
euthanized.
10 U.S. Const. amend. I. 11 5 U.S.C. § 553(e). 12 7 C.F.R. §1.28. 13 21
U.S.C. § 601 et. seq.
4
snip...
Although USDA has determined that cattle younger than 30 months do not
present a serious risk of BSE,137 calves in fact pose a greater threat of
diseases like E. coli and Salmonella. Studies have shown that fecal samples from
calves are more likely to test positive for Shiga-like-toxin-producing E. coli
such as E. coli O157:H7 than adult cows.138 In one study, 8% of adult cows and
19% of heifers and calves tested positive.139 Other research revealed that the
prevalence of E. coli O157:H7 in calves can be up to 20.0% prior to weaning, and
often increases after weaning.140 Shedding of E. coli O157:H7 in fecal material
also lasts longer in calves than in adults.141 When E. coli
endotoxin was experimentally administered to calves, they became recumbent
within 15-25 minutes,142 highlighting the correlation between disease and a
calf’s non-ambulatory status.
Separation and Direct Plating Methods, 74 Applied and Envtl. Microbiology
6,289,
(2008) (see Attach. 33).
133 KD Childs et al., Molecular Characterization of Escherichia coli
O157:H7 Hide
Contamination Routes: Feedlot to Harvest, 69 J. of Food Prot. 1,240 (2006)
(see
Attach. 34).
134 McDonough, supra note 87.
135 Centers for Disease Control and Prevention, Questions & Answers:
Sickness
Caused by E. coli (Dec. 10, 2006), available at
http://www.cdc.gov/ecoli/qa_ecoli_sickness.htm
(last visited Oct. 22, 2009).
136 S Razzaq, Hemolytic Uremic Syndrome: An Emerging Health Risk, 74 Am.
Fam.
Phys. 991, 991 (Sept. 15, 2006), available at
http://www.aafp.org/afp/20060915/991.pdf
(last visited Oct. 20, 2009).
137 2004 Interim Final Rule, 69 Fed. Reg. 1862.
138 See, e.g., JG Wells et al, Isolation of Escherichia Coli Serotype
O157:H7 and Other
Shiga-like-toxin-producing E. Coli from Dairy Cattle, 29 J. of Clinical
Microbiology
985 (1991) (see Attach. 35).
139 Id.
140 EFSA Scientific Report, supra note 100, at 65.
141 WC Cray, Jr. & HW Moon, Experimental Infection of Calves and Adult
Cattle with
Escherichia Coli O157:H7, 61 Applied Envt’l Microbiology 1586 (1995) (see
Attach.
36).
29
snip...
VII. CONCLUSION
Petitioner urges USDA to initiate rulemaking to remove this exemption and
require that all cattle—including veal calves—who are or become non-ambulatory
be euthanized promptly and humanely. The HMSA’s humane handling goals, the
FMIA’s food safety goals, and USDA’s own policies and conclusions regarding
non-ambulatory cattle demand the removal of the exemption. Allowing calves who
are too sick or injured to stand or walk to be kept alive indefinitely and
forced or dragged through the slaughter line is extremely inhumane, wastes
public resources, reduces confidence in USDA’s inspection system, and is
ultimately detrimental to the veal industry itself.
The primary justification for USDA’s decision to remove the re-inspection
provision following the Hallmark scandal was to “ensure effective implementation
of …humane handling requirements.”257 It would thus be arbitrary and capricious
for USDA, after having determined that the case-bycase reinspection provision
for mature cattle was ineffective, diverted agency resources, and encouraged
inhumane treatment, to fail to remove the veal calf set aside provision, which
similarly is inefficient, incentivizes abuse, and, if complied with, wastes an
inordinate amount of time and resources.
257 2008 Proposed Rule, 73 Fed. Reg. at 50,891; see also 2009 Final Rule,
74 Fed. Reg. at 11,464 (asserting that “a change in the regulation [was] needed
to ensure more effective and efficient implementation of inspection procedure
and compliance withhumane handling requirements.”).
66
__________________
____________________
Respectfully submitted,
/s/
Gina Tomaselli Litigation FellowThe Humane Society of the United States
2100 L St. N.W. Washington, DC 20037
/s/
Peter A. Brandt Senior Attorney, Farm Animals The Humane Society of the
United States 2100 L St. N.W. Washington, DC 20037
USDA et al are wrong about BSE TSE PRION aka mad cow disease. ignoring the
other strains of the BSE TSE prion, the other strains of TSE prion in other
species, ignoring the transmission studies, it all changed after December 2003.
it was like turning the light on and off. it’s all about trade$$$ mad cow is out
of the barn. body count still not high enough. incubation time still
fooling. mutation of strains, and different virulence there from will catch up.
science is show this now.
the BSE TSE junk science the USDA et al should be a warning to Countries
all around the world. but, as long as the OIE is in bed with the USDA et al, the
Countries around the world will have to eat what you get, and hope for the best
there from. my opinion. with that said, regardless, it is a good thing that
these Government officials have come forward and ask to ban downer veal calves.
I must say, when they banned downer cows, I thought that included downer calves
too. I should have known better. stupid me. ...tss
Tuesday, February 11, 2014
Tuesday, February 11, 2014
*** California Firm Recalls Various Meat Products Produced Without the Benefit
of Full Inspection Class I Recall 002-2014 and 013-2014 Health Risk: High Jan
13, 2014 and Feb 8, 2014
>>> Although USDA has determined that cattle younger than 30
months do not present a serious risk of BSE,137
Monday, May 12, 2008
BSE YOUNGEST AGE STATISTICS UNDER 30 MONTHS
We can confirm that of the 100 cases, 49 were under 30 months of age, of
these the youngest case was 20 months old.
BSE Youngest Japan 21 months, 23 months
The implications of the Swiss result for Britain, which has had the most
BSE, are complex. Only cattle aged 30 months or younger are eaten in Britain, on
the assumption, based on feeding trials, that cattle of that age, even if they
were infected as calves, have not yet accumulated enough prions to be
infectious. But the youngest cow to develop BSE on record in Britain was 20
months old, showing some are fast incubators. Models predict that 200-300 cattle
under 30 months per year are infected with BSE and enter the food chain
currently in Britain. Of these 3-5 could be fast incubators and carrying
detectable quantities of prion.
YOUNGEST AND OLDEST CASES BY YEAR OF ONSET (FOR PASSIVE SURVEILLANCE
CASES)
AND BY YEAR OF SLAUGHTER (FOR ACTIVE SURVEILLANCE CASES) - GREAT BRITAIN
ONLY.
NB The last case in an animal aged 30 months or less was in 1996
Year of onset Age (mths) youngest case (n) Age (mths) 2nd youngest case
(n) Age (yrs.mths) 2nd oldest case (n) Age (yrs.mths) oldest case (n)
1986 30 33 5.03 5.07
1987 30 31 9.09 10
1988 24 27 10.02 11.01(2)
1989 21 24(4) 12(2) 15.04
1990 24(2) 26 13.03 14
1991 24 26(3) 14.02 17.05
1992 20 26 15.02 16.02
1993 29 30(3) 14.1 18.1
1994 30(2) 31(2) 14.05 16.07
1995 24 32 14.09 15.04
1996 29 30 15.07 17.02
1997 37(7) 38(3) 14.09 15.01
1998 34 36 14.07 15.05
1999 39(2) 41 13.07 13.1
2000 40 42 17.08 19.09
2001 45 48 16.01 20.08
2002 47 48(2) 18.04 22.07
2003 46 49 18.07(2) 20.06
2004 49 52 17.04 22.07
2005 36 38 18.01 19.04
2006 48 58 17.05 19.09
2007 62 66(2) 17.03 19
2008 65 69 19.04 20.07
2009 72 86 16.08 18.03
2010 64 72 16.05 17
2011 135 143 12.07 17.11
2012 75 N/A N/A 20.9
2013 77 138 11.06 12.10
Data valid to 31 January 2014
Figures in brackets indicate the number of cases of that age (if more than
one).
6 of
see full text ;
I applaud the great efforts of the HSUS on their undercover work on this
and other cases, but in my opinion, USDA ET AL are wrong on the science of BSE
and risk factor there from from young animals, especially with veal (*** see BSE
Inquiry CJD report on veal and BSE), and the department of justice missed the
boat on the NSLP deadstock downer cow program, where for 4 years, the NSLP fed
deadstock downer cows to our children all across the Nation, the most high risk
cattle for mad cow disease and other deadly pathogens, then hid this fact under
a recall for animal abuse...these are the sad facts as I have come to know
them...who will watch our children for the next 50 years $$$
============================================================================================================
*** Individuals
reported to eat veal on average at least once a year appear to be at 13 TIMES
THE RISK of individuals who have never eaten veal.
*** There is, however, a very wide confidence interval around this estimate. There is no strong evidence that eating veal less than once per year is associated with increased risk of CJD (p = 0.51).
*** The association between venison eating and risk of CJD shows similar pattern, with regular venison eating associated with a 9 FOLD INCREASE IN RISK OF CJD (p = 0.04).
*** There is some evidence that risk of CJD INCREASES WITH INCREASING FREQUENCY OF LAMB EATING (p = 0.02).
*** There is, however, a very wide confidence interval around this estimate. There is no strong evidence that eating veal less than once per year is associated with increased risk of CJD (p = 0.51).
*** The association between venison eating and risk of CJD shows similar pattern, with regular venison eating associated with a 9 FOLD INCREASE IN RISK OF CJD (p = 0.04).
*** There is some evidence that risk of CJD INCREASES WITH INCREASING FREQUENCY OF LAMB EATING (p = 0.02).
*** In conclusion,
an analysis of dietary histories revealed statistical associations between
various meats/animal products and INCREASED RISK OF CJD. When some account was
taken of possible confounding, the association between VEAL EATING AND RISK OF
CJD EMERGED AS THE STRONGEST OF THESE ASSOCIATIONS STATISTICALLY. ...
=============================================================================================================
CREUTZFELDT JAKOB DISEASE SURVEILLANCE IN THE
UNITED KINGDOM THIRD ANNUAL REPORT AUGUST 1994
Consumption of venison and veal was much less widespread among both cases and controls. For both of these meats there was evidence of a trend with increasing frequency of consumption being associated with increasing risk of CJD. (not nvCJD, but sporadic CJD...tss) These associations were largely unchanged when attention was restricted to pairs with data obtained from relatives. ...
Table 9 presents the results of an analysis of these data.
*** There is STRONG evidence of an association between ‘’regular’’ veal eating and risk of CJD (p = .0.01).
*** Individuals reported to eat veal on average at least once a year appear to be at 13 TIMES THE RISK of individuals who have never eaten veal.
There is, however, a very wide confidence interval around this estimate. There is no strong evidence that eating veal less than once per year is associated with increased risk of CJD (p = 0.51).
The association between venison eating and risk of CJD shows similar pattern, with regular venison eating associated with a 9 FOLD INCREASE IN RISK OF CJD (p = 0.04).
There is some evidence that risk of CJD INCREASES WITH INCREASING FREQUENCY OF LAMB EATING (p = 0.02).
The evidence for such an association between beef eating and CJD is weaker (p = 0.14). When only controls for whom a relative was interviewed are included, this evidence becomes a little STRONGER (p = 0.08).
snip...
It was found that when veal was included in the model with another exposure, the association between veal and CJD remained statistically significant (p = < 0.05 for all exposures), while the other exposures ceased to be statistically significant (p = > 0.05).
snip...
In conclusion, an analysis of dietary histories revealed statistical associations between various meats/animal products and INCREASED RISK OF CJD. When some account was taken of possible confounding, the association between VEAL EATING AND RISK OF CJD EMERGED AS THE STRONGEST OF THESE ASSOCIATIONS STATISTICALLY. ...
snip...
In the study in the USA, a range of foodstuffs were associated with an increased risk of CJD, including liver consumption which was associated with an apparent SIX-FOLD INCREASE IN THE RISK OF CJD. By comparing the data from 3 studies in relation to this particular dietary factor, the risk of liver consumption became non-significant with an odds ratio of 1.2 (PERSONAL COMMUNICATION, PROFESSOR A. HOFMAN. ERASMUS UNIVERSITY, ROTTERDAM). (???...TSS)
snip...see full report ;
Consumption of venison and veal was much less widespread among both cases and controls. For both of these meats there was evidence of a trend with increasing frequency of consumption being associated with increasing risk of CJD. (not nvCJD, but sporadic CJD...tss) These associations were largely unchanged when attention was restricted to pairs with data obtained from relatives. ...
Table 9 presents the results of an analysis of these data.
*** There is STRONG evidence of an association between ‘’regular’’ veal eating and risk of CJD (p = .0.01).
*** Individuals reported to eat veal on average at least once a year appear to be at 13 TIMES THE RISK of individuals who have never eaten veal.
There is, however, a very wide confidence interval around this estimate. There is no strong evidence that eating veal less than once per year is associated with increased risk of CJD (p = 0.51).
The association between venison eating and risk of CJD shows similar pattern, with regular venison eating associated with a 9 FOLD INCREASE IN RISK OF CJD (p = 0.04).
There is some evidence that risk of CJD INCREASES WITH INCREASING FREQUENCY OF LAMB EATING (p = 0.02).
The evidence for such an association between beef eating and CJD is weaker (p = 0.14). When only controls for whom a relative was interviewed are included, this evidence becomes a little STRONGER (p = 0.08).
snip...
It was found that when veal was included in the model with another exposure, the association between veal and CJD remained statistically significant (p = < 0.05 for all exposures), while the other exposures ceased to be statistically significant (p = > 0.05).
snip...
In conclusion, an analysis of dietary histories revealed statistical associations between various meats/animal products and INCREASED RISK OF CJD. When some account was taken of possible confounding, the association between VEAL EATING AND RISK OF CJD EMERGED AS THE STRONGEST OF THESE ASSOCIATIONS STATISTICALLY. ...
snip...
In the study in the USA, a range of foodstuffs were associated with an increased risk of CJD, including liver consumption which was associated with an apparent SIX-FOLD INCREASE IN THE RISK OF CJD. By comparing the data from 3 studies in relation to this particular dietary factor, the risk of liver consumption became non-significant with an odds ratio of 1.2 (PERSONAL COMMUNICATION, PROFESSOR A. HOFMAN. ERASMUS UNIVERSITY, ROTTERDAM). (???...TSS)
snip...see full report ;
Thursday, October 10, 2013
*** CJD REPORT 1994 increased risk for consumption of veal and venison and lamb
http://creutzfeldt-jakob-disease.blogspot.com/2013/10/cjd-report-1994-increased-risk-for.html
*** CJD REPORT 1994 increased risk for consumption of veal and venison and lamb
http://creutzfeldt-jakob-disease.blogspot.com/2013/10/cjd-report-1994-increased-risk-for.html
Thursday, November 28, 2013
Department of Justice Former Suppliers of Beef to National School Lunch
Program Settle Allegations of Improper Practices and Mistreating Cows
seems USDA NSLP et al thought that it would be alright, to feed our
children all across the USA, via the NSLP, DEAD STOCK DOWNER COWS, the most high
risk cattle for mad cow type disease, and other dangerous pathogens, and they
did this for 4 years, that was documented, then hid what they did by having a
recall, one of the largest recalls ever, and they made this recall and masked
the reason for the recall due to animal abuse (I do not condone animal abuse),
not for the reason of the potential for these animals to have mad cow BSE type
disease (or other dangerous and deadly pathogens). these TSE prion disease can
lay dormant for 5, 10, 20 years, or longer, WHO WILL WATCH OUR CHILDREN FOR THE
NEXT 5 DECADES FOR CJD ???
Saturday, September 21, 2013
Westland/Hallmark: 2008 Beef Recall A Case Study by The Food Industry
Center January 2010 THE FLIM-FLAM REPORT
DID YOUR CHILD CONSUME SOME OF THESE DEAD STOCK DOWNER COWS, THE MOST HIGH
RISK FOR MAD COW DISEASE ???
this recall was not for the welfare of the animals. ...tss
you can check and see here ;
(link now dead, does not work...tss)
try this link ;
Sunday, November 13, 2011
California BSE mad cow beef recall, QFC,
CJD, and dead stock downer livestock
and I applaud HSUS work to save the chimps...
Wednesday, April 24,
2013
Chimpanzees Released After 30 Years Of Testing, Brace Yourself For Smiles
http://transmissiblespongiformencephalopathy.blogspot.com/2013/04/chimpanzees-released-after-30-years-of.html
Chimpanzees Released After 30 Years Of Testing, Brace Yourself For Smiles
http://transmissiblespongiformencephalopathy.blogspot.com/2013/04/chimpanzees-released-after-30-years-of.html
Wednesday, February 12, 2014
*** USDA/APHIS NOTICE: Final Rule Regarding Imports and BSE Effective March
4, 2014
LOL $$$
FDA PART 589 -- SUBSTANCES PROHIBITED FROM USE IN ANIMAL FOOD OR FEED
VIOLATIONS OFFICIAL ACTION INDICATED OIA UPDATE DECEMBER 2013 UPDATE
OAI 2012-2013
OAI (Official Action Indicated) when inspectors find significant
objectionable conditions or practices and believe that regulatory sanctions are
warranted to address the establishment’s lack of compliance with the regulation.
An example of an OAI classification would be findings of manufacturing
procedures insufficient to ensure that ruminant feed is not contaminated with
prohibited material. Inspectors will promptly re-inspect facilities classified
OAI after regulatory sanctions have been applied to determine whether the
corrective actions are adequate to address the objectionable conditions.
ATL-DO 1035703 Newberry Feed & Farm Ctr, Inc. 2431 Vincent St. Newberry
SC 29108-0714 OPR DR, FL, FR, TH HP 9/9/2013 OAI Y
DET-DO 1824979 Hubbard Feeds, Inc. 135 Main, P.O. Box 156 Shipshewana IN
46565-0156 OPR DR, FL, OF DP 8/29/2013 OAI Y
ATL-DO 3001460882 Talley Farms Feed Mill Inc 6309 Talley Rd Stanfield NC
28163-7617 OPR FL, TH NP 7/17/2013 OAI N
NYK-DO 3010260624 Sherry Sammons 612 Stoner Trail Rd Fonda NY 12068-5007
OPR FR, OF NP 7/16/2013 OAI Y
DEN-DO 3008575486 Rocky Ford Pet Foods 21693 Highway 50 East Rocky Ford CO
81067 OPR RE, TH HP 2/27/2013 OAI N
CHI-DO 3007091297 Rancho Cantera 2866 N Sunnyside Rd Kent IL 61044-9605 OPR
FR, OF HP 11/26/2012 OAI Y
*** DEN-DO 1713202 Weld County Bi Products, Inc. 1138 N 11th Ave Greeley CO
80631-9501 OPR RE, TH HP 10/12/2012 OAI N
Ruminant Feed Inspections Firms Inventory (excel format)
PLEASE NOTE, the VAI violations were so numerous, and unorganized in dates
posted, as in numerical order, you will have to sift through them for
yourselves. ...tss
snip...see full text ;
Sunday, December 15, 2013
FDA PART 589 -- SUBSTANCES PROHIBITED FROM USE IN ANIMAL FOOD OR FEED
VIOLATIONS OFFICIAL ACTION INDICATED OIA UPDATE DECEMBER 2013 UPDATE
Saturday, December 15, 2012
Bovine spongiform encephalopathy: the effect of oral exposure dose on
attack rate and incubation period in cattle -- an update 5 December 2012
Tuesday, February 11, 2014
*** California Firm Recalls Various Meat Products Produced Without the
Benefit of Full Inspection Class I Recall 002-2014 and 013-2014 Health Risk:
High Jan 13, 2014 and Feb 8, 2014
Sunday, February 2, 2014
*** The Presence of Disease-Associated Prion Protein in Skeletal Muscle of
Cattle Infected with Classical Bovine Spongiform Encephalopathy
NOTE Pathology
Monday, February 10, 2014
Enhanced Virulence of Sheep-Passaged Bovine Spongiform Encephalopathy Agent
Is Revealed by Decreased Polymorphism Barriers in Prion Protein Conversion
Studies
Monday, February 3, 2014
Evaluation of the zoonotic potential of transmissible mink encephalopathy
TSE Prion disease
Research Project: TRANSMISSION, DIFFERENTIATION, AND PATHOBIOLOGY OF
TRANSMISSIBLE SPONGIFORM ENCEPHALOPATHIES
Sunday, February 2, 2014
The Presence of Disease-Associated Prion Protein in Skeletal Muscle of
Cattle Infected with Classical Bovine Spongiform Encephalopathy
NOTE Pathology
Saturday, December 21, 2013
**** Complementary studies detecting classical bovine spongiform
encephalopathy infectivity in jejunum, ileum and ileocaecal junction in
incubating cattle ****
Saturday, December 15, 2012
*** Bovine spongiform encephalopathy: the effect of oral exposure dose on
attack rate and incubation period in cattle -- an update 5 December 2012
Saturday, August 14, 2010
***BSE Case Associated with Prion Protein Gene Mutation (g-h-BSEalabama)
and VPSPr PRIONPATHY
*** (see mad cow feed in COMMERCE IN ALABAMA...TSS)
However, a BSE expert said that consumption of infected material is the
only known way that cattle get the disease under natural conditons.
***“In view of what we know about BSE after almost 20 years experience,
contaminated feed has been the source of the epidemic,” said Paul Brown, a
scientist retired from the National Institute of Neurological Diseases and
Stroke.
BSE is not caused by a microbe. It is caused by the misfolding of the
so-called “prion protein” that is a normal constituent of brain and other
tissues. If a diseased version of the protein enters the brain somehow, it can
slowly cause all the normal versions to become misfolded. It is possible the
disease could arise spontaneously, though such an event has never been recorded,
Brown said.
*** 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.”
However, a BSE expert said that consumption of infected material is the
only known way that cattle get the disease under natural conditons.
“In view of what we know about BSE after almost 20 years experience,
contaminated feed has been the source of the epidemic,” said Paul Brown, a
scientist retired from the National Institute of Neurological Diseases and
Stroke.
BSE is not caused by a microbe. It is caused by the misfolding of the
so-called “prion protein” that is a normal constituent of brain and other
tissues. If a diseased version of the protein enters the brain somehow, it can
slowly cause all the normal versions to become misfolded. It is possible the
disease could arise spontaneously, though such an event has never been recorded,
Brown said.
Wednesday, December 4, 2013
*** Bovine Spongiform Encephalopathy; Importation of Bovines and Bovine
Products; Final Rule Federal Register / Vol. 78 , No. 233 /
Wednesday, December 4, 2013
Saturday, November 2, 2013
*** APHIS Finalizes Bovine Import Regulations in Line with International
Animal Health Standards while enhancing the spread of BSE TSE prion mad cow type
disease around the Globe
Wednesday, September 25, 2013
Inspections, Compliance, Enforcement, and Criminal Investigations BSE TSE
PRION 2013
Monday, September 02, 2013
Atypical BSE: role of the E211K prion polymorphism
Research Project: TRANSMISSION, DIFFERENTIATION, AND PATHOBIOLOGY OF
TRANSMISSIBLE SPONGIFORM ENCEPHALOPATHIES
Location: Virus and Prion Research Unit
Tuesday, March 05, 2013
A closer look at prion strains Characterization and important implications
Prion
7:2, 99–108; March/April 2013; © 2013 Landes Bioscience
Wednesday, February 20, 2013
World Organization for Animal Health Recommends United States' BSE Risk
Status Be Upgraded
Statement from Agriculture Secretary Tom Vilsack:
Thursday, February 14, 2013
The Many Faces of Mad Cow Disease Bovine Spongiform Encephalopathy BSE and
TSE prion disease
Thursday, February 14, 2013
Unique Properties of the Classical Bovine Spongiform Encephalopathy Strain
and Its Emergence From H-Type Bovine Spongiform Encephalopathy Substantiated by
VM Transmission Studies
Monday, February 11, 2013
APHIS USDA Letter to Stakeholders: Trade Accomplishments and failures (BSE,
SCRAPIE, TSE, PRION, AKA MAD COW TYPE DISEASE)
Comments on technical aspects of the risk assessment were then submitted to
FSIS.
Comments were received from Food and Water Watch, Food Animal Concerns
Trust (FACT), Farm Sanctuary, R-CALF USA, Linda A Detwiler, and Terry S.
Singeltary.
This document provides itemized replies to the public comments received on
the 2005 updated Harvard BSE risk assessment. Please bear the following points
in mind:
Owens, Julie
From: Terry S. Singeltary Sr. [flounder9@verizon.net]
Sent: Monday, July 24, 2006 1:09 PM
To: FSIS RegulationsComments
Subject: [Docket No. FSIS-2006-0011] FSIS Harvard Risk Assessment of Bovine
Spongiform Encephalopathy (BSE) Page 1 of 98
FSIS, USDA, REPLY TO SINGELTARY
U.S.A. 50 STATE BSE MAD COW CONFERENCE CALL Jan. 9, 2001
Tuesday, June 4, 2013
INTERPRETING RESULTS OF FSIS VERIFICATION SAMPLING OF DOMESTIC BEEF PRODUCT
DERIVED FROM ADVANCED MEAT RECOVERY SYSTEMS (AMR01/FAMR01) FSIS Notice
38-12
Thursday, May 30, 2013
World Organization for Animal Health (OIE) has upgraded the United States'
risk classification for mad cow disease to "negligible" from "controlled", and
risk further exposing the globe to the TSE prion mad cow type disease
U.S. gets top mad-cow rating from international group and risk further
exposing the globe to the TSE prion mad cow type disease
Tuesday, July 17, 2012
O.I.E. BSE, CWD, SCRAPIE, TSE PRION DISEASE Final Report of the 80th
General Session, 20 - 25 May 2012
IN SHORT, AND 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,
WHAT about the sporadic CJD TSE proteins ?
WE now know that some cases of sporadic CJD are linked to atypical BSE and
atypical Scrapie, so why are not MORE concerned about the sporadic CJD, and all
it’s sub-types $$$
Creutzfeldt-Jakob Disease CJD cases rising North America updated report
August 2013
*** Creutzfeldt-Jakob Disease CJD cases rising North America with Canada
seeing an extreme increase of 48% between 2008 and 2010 ***
Sunday, October 13, 2013
*** CJD TSE Prion Disease Cases in Texas by Year, 2003-2012
Sunday, January 19, 2014
*** National Prion Disease Pathology Surveillance Center Cases Examined1 as
of January 8, 2014 ***
*** Saturday, November 2, 2013 ***
Exploring the risks of a putative transmission of BSE to new species
Wednesday, September 25, 2013
Presence of subclinical infection in gene-targeted human prion protein
transgenic mice exposed to atypical BSE
I ask Professor Kong ; Thursday, December 04, 2008 3:37 PM
Subject: RE: re--Chronic Wating Disease (CWD) and Bovine Spongiform
Encephalopathies (BSE): Public Health Risk Assessment ''IS the h-BSE more
virulent than typical BSE as well, or the same as cBSE, or less virulent than
cBSE? just curious.....'' Professor Kong reply ;
.....snip
''As to the H-BSE, we do not have sufficient data to say one way or
another, but we have found that H-BSE can infect humans. I hope we could publish
these data once the study is complete. Thanks for your interest.''
Best regards, Qingzhong Kong, PhD Associate Professor Department of
Pathology Case Western Reserve University Cleveland, OH 44106 USA END...TSS
Thursday, December 04, 2008 2:37 PM
"we have found that H-BSE can infect humans."
personal communication with Professor Kong. ...TSS
BSE-H is also transmissible in our humanized Tg mice. The possibility of
more than two atypical BSE strains will be discussed.
Supported by NINDS NS052319, NIA AG14359, and NIH AI 77774.
please see below from PRION2013 ;
*** This study imply the possibility that the novel BSE prions with high
virulence in cattle will be emerged during intraspecies transmission.
AD.56: The emergence of novel BSE prions by serial passages of H-type BSE
in bovinized mice
Kentaro Masujin, Naoko Tabeta, Ritsuko Miwa, Kohtaro Miyazawa, Hiroyuki
Okada, Shirou Mohri and Takashi Yokoyama National Institute of Animal Health;
Tsukuba, Japan
H-type bovine spongiform encephalopathy (BSE) is an atypical form of BSE,
and has been detected in several European countries, and North America.
Transmission studies of H-type BSE led to the emergence of the classical BSE
(C-BSE) phenotypes during passages in inbred wild type and bovinized
PrP-overexpressing transgenic mice. In this study, we conducted serial passages
of Canadian H-type BSE isolate in bovinized PrP-overexpressing transgenic mice
(TgBoPrP). H-type BSE isolate was transmitted to TgBoPrP with incubation periods
of 320 ± 12.2 d at primary passage. The incubation period of 2nd and 3rd passage
were constant (~= 220 d), no clear differences were observed in their biological
and biochemical properties. However, at the forth passage, 2 different BSE
phenotypes were confirmed; one is shorter survival times (109 ± 4 d) and the
other is longer survival times. TgBoPrP mice with longer incubation period
showed the H-type phenotype of PrPsc profile and pathology. However, those of
shorter incubation period were different phenotypes from previously existed BSE
prions (C-BSE, L-type BSE, and H-type BSE).
*** This study imply the possibility that the novel BSE prions with high
virulence in cattle will be emerged during intraspecies transmission.
please see ;
Thursday, August 15, 2013
The emergence of novel BSE prions by serial passages of H-type BSE in
bovinized mice
Sunday, September 1, 2013
*** Evaluation of the Zoonotic Potential of Transmissible Mink
Encephalopathy
We previously described the biochemical similarities between PrPres derived
from L-BSE infected macaque and cortical MM2 sporadic CJD: those observations
suggest a link between these two uncommon prion phenotypes in a primate model
(it is to note that such a link has not been observed in other models less
relevant from the human situation as hamsters or transgenic mice overexpressing
ovine PrP [28]). We speculate that a group of related animal prion strains
(L-BSE, c-BSE and TME) would have a zoonotic potential and lead to prion
diseases in humans with a type 2 PrPres molecular signature (and more
specifically type 2B for vCJD)
snip...
Together with previous experiments performed in ovinized and bovinized
transgenic mice and hamsters [8,9] indicating similarities between TME and
L-BSE, the data support the hypothesis that L-BSE could be the origin of the TME
outbreaks in North America and Europe during the mid-1900s.
Monday, October 10, 2011
EFSA Journal 2011 The European Response to BSE: A Success Story
snip...
EFSA and the European Centre for Disease Prevention and Control (ECDC)
recently delivered a scientific opinion on any possible epidemiological or
molecular association between TSEs in animals and humans (EFSA Panel on
Biological Hazards (BIOHAZ) and ECDC, 2011). This opinion confirmed Classical
BSE prions as the only TSE agents demonstrated to be zoonotic so far ***but the
possibility that a small proportion of human cases so far classified as
"sporadic" CJD are of zoonotic origin could not be excluded. Moreover,
transmission experiments to non-human primates suggest that some TSE agents in
addition to Classical BSE prions in cattle (namely L-type Atypical BSE,
Classical BSE in sheep, transmissible mink encephalopathy (TME) and chronic
wasting disease (CWD) agents) might have zoonotic potential.
snip...
see follow-up here about North America BSE Mad Cow TSE prion risk factors,
and the ever emerging strains of Transmissible Spongiform Encephalopathy in many
species here in the USA, including humans ;
Thursday, August 12, 2010
Seven main threats for the future linked to prions
First threat
The TSE road map defining the evolution of European policy for protection
against prion diseases is based on a certain numbers of hypotheses some of which
may turn out to be erroneous. In particular, a form of BSE (called atypical
Bovine Spongiform Encephalopathy), recently identified by systematic testing in
aged cattle without clinical signs, may be the origin of classical BSE and thus
potentially constitute a reservoir, which may be impossible to eradicate if a
sporadic origin is confirmed.
***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...
Thursday, January 23, 2014
Medical Devices Containing Materials Derived from Animal Sources (Except
for In Vitro Diagnostic Devices) [Docket No. FDA–2013–D–1574]
Monday, February 03, 2014
CREUTZFELDT-JAKOB DISEASE T.S.E. PRION U.K. UPDATE As at 3rd February 2014
http://vcjd.blogspot.com/2014/02/creutzfeldt-jakob-disease-tse-prion-uk.html
CREUTZFELDT-JAKOB DISEASE T.S.E. PRION U.K. UPDATE As at 3rd February 2014
http://vcjd.blogspot.com/2014/02/creutzfeldt-jakob-disease-tse-prion-uk.html
Saturday, February 01, 2014
vCJD With Extremely Low Lymphoreticular Deposition of Prion Protein MAY NOT HAVE BEEN DETECTABLE
http://vcjd.blogspot.com/2014/02/vcjd-with-extremely-low-lymphoreticular.html
vCJD With Extremely Low Lymphoreticular Deposition of Prion Protein MAY NOT HAVE BEEN DETECTABLE
http://vcjd.blogspot.com/2014/02/vcjd-with-extremely-low-lymphoreticular.html
Thursday, January 2, 2014
*** CWD TSE Prion in cervids to hTGmice, Heidenhain Variant Creutzfeldt-Jacob Disease MM1 genotype, and iatrogenic CJD ???
http://transmissiblespongiformencephalopathy.blogspot.com/2014/01/cwd-tse-prion-in-cervids-to-htgmice.html
*** CWD TSE Prion in cervids to hTGmice, Heidenhain Variant Creutzfeldt-Jacob Disease MM1 genotype, and iatrogenic CJD ???
http://transmissiblespongiformencephalopathy.blogspot.com/2014/01/cwd-tse-prion-in-cervids-to-htgmice.html
Friday, January 10, 2014
*** vpspr, sgss, sffi, TSE, an iatrogenic by-product of gss, ffi, familial type prion disease, what it ???
http://transmissiblespongiformencephalopathy.blogspot.com/2014/01/vpspr-sgss-sffi-tse-iatrogenic-by.html
*** vpspr, sgss, sffi, TSE, an iatrogenic by-product of gss, ffi, familial type prion disease, what it ???
http://transmissiblespongiformencephalopathy.blogspot.com/2014/01/vpspr-sgss-sffi-tse-iatrogenic-by.html
Monday, January 13, 2014
*** Prions in Variably Protease-Sensitive Prionopathy: An Update Pathogens 2013
Pathogens 2013, 2, 457-471; doi:10.3390/pathogens2030457
http://prionopathy.blogspot.com/2014/01/prions-in-variably-protease-sensitive.html
*** Prions in Variably Protease-Sensitive Prionopathy: An Update Pathogens 2013
Pathogens 2013, 2, 457-471; doi:10.3390/pathogens2030457
http://prionopathy.blogspot.com/2014/01/prions-in-variably-protease-sensitive.html
Wednesday, January 15, 2014
*** INFECTION PREVENTION AND CONTROL OF CJD, VCJD AND OTHER HUMAN PRION DISEASES IN HEALTHCARE AND COMMUNITY SETTINGS Variably Protease-Sensitive Prionopathy (VPSPr) January 15, 2014
http://transmissiblespongiformencephalopathy.blogspot.com/2014/01/infection-prevention-and-control-of-cjd.html
*** INFECTION PREVENTION AND CONTROL OF CJD, VCJD AND OTHER HUMAN PRION DISEASES IN HEALTHCARE AND COMMUNITY SETTINGS Variably Protease-Sensitive Prionopathy (VPSPr) January 15, 2014
http://transmissiblespongiformencephalopathy.blogspot.com/2014/01/infection-prevention-and-control-of-cjd.html
Monday, December 02, 2013
*** A parliamentary inquiry has been launched today into the safety of blood, tissue and organ screening following fears that vCJD – the human form of ‘mad cow’ disease – may be being spread by medical procedures
http://creutzfeldt-jakob-disease.blogspot.com/2013/12/a-parliamentary-inquiry-has-been.html
*** A parliamentary inquiry has been launched today into the safety of blood, tissue and organ screening following fears that vCJD – the human form of ‘mad cow’ disease – may be being spread by medical procedures
http://creutzfeldt-jakob-disease.blogspot.com/2013/12/a-parliamentary-inquiry-has-been.html
=================================================================
Wednesday, December 11, 2013
*** Detection of Infectivity in Blood of Persons with Variant and ***Sporadic Creutzfeldt-Jakob Disease ***
*** Detection of Infectivity in Blood of Persons with Variant and ***Sporadic Creutzfeldt-Jakob Disease ***
=========================================================================
Tuesday, October 29, 2013
*** VARIANT CJD PRESENTS DIFFERENTLY IN OLDER PATIENTS
http://creutzfeldt-jakob-disease.blogspot.com/2013/10/variant-cjd-presents-differently-in.html
Thursday, February 06, 2014
Commons Science and Technology Committee announce new inquiry on blood, tissue and organ screening Parliament exposure vcjd and blood risk while still ignoring recent risks factors of sporadic CJD
http://vcjd.blogspot.com/2014/02/commons-science-and-technology.html
Commons Science and Technology Committee announce new inquiry on blood, tissue and organ screening Parliament exposure vcjd and blood risk while still ignoring recent risks factors of sporadic CJD
http://vcjd.blogspot.com/2014/02/commons-science-and-technology.html
Tuesday, February 11, 2014
*** Novant Health Forsyth Medical Center Information on potential CJD
exposure
layperson
Terry S. Singeltary Sr.
just made a promise to mom, never forget, and never let them forget. mom
DOD 12/14/97 confirmed hvCJD. ...TSS
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