BSE update: Unknown risk at work
Many aspects of feed and food safety policy with respect to BSE remain dynamic.
The USA has recorded only three cases of bovine spongiform encephalopathy in US cattle and only one apparent native-born case'. Moreover, by almost all accounts, the feed industry has achieved extremely high compliance with the 1997 federal Ruminant Feed Ban and subsequent rules updates. Nonetheless, the political pressure to ban all potential risk materials from cattle in all feeds has continued unabated.
Many aspects of feed and food safety policy with respect to BSE remain dynamic because both the science and forensics of the disease continue to unearth mysteries. Much remains unknown about the epidemiology of BSE, its risk to healthy cattle, and its capacity to slip through the species barrier. The unknown about BSE continues to be a strong motivator of legislative and administrative policy.
Washington, DC-based feed industry consultant Steve Kopperud recently noted that US Representative Maurice Hinchey (D, NY), a member of the House Appropriations Committee, proposed an ag spending bill amendment for a new kind of BSE study. The amendment would authorize a major study on the effect of banning all cattle risk materials in all feeds on the infectivity and the risk to humans of contracting variant Creutzfeld Jakob Disease (vCJD). This BSE-like brain-wasting disease, first identified in the UK a decade ago, was remarkable for its sudden appearance and rapid onset in young people. Its victims possibly had consumed beef from cattle with BSE. For more, see http://www.afia.org/447483ed5f060.html and http://www.ninds.nih.gov/disorders/cjd/detail_cjd.htm.The most recent BSE case in the US has been especially frustrating. The cow from Alabama that tested positive for BSE in March was confirmed to be more than 10 years old and born before FDA's existing BSE rule. But, the back trail of this cow has petered out despite one of the federal government's most intensive veterinary investigations. The cold trail has increased pressure to accelerate the National Animal Identification System, which US Department of Agriculture Secretary Mike Johanns has said is having "good participation", with farmers enrolling in voluntary state programs that make use of unique 15-digit codes in RFID tags. The current USDA plan calls for all premises to be registered and 100% of newborn animals to be identified by January 2009. See also FM on Site' in this issue.
Kopperud also notes that lawmakers have increased pressure to allow meat-processing companies to privately test for BSE despite USDA's refusal to allow all companies to conduct their own tests. Representative Todd Tiahrt (R, KS) has argued that individual US companies should be allowed to test animals destined for export markets, in order to satisfy the requests of overseas buyers. Also, Senator Charles Grassley (R, IA) has sent a letter to Secretary Johanns urging the USDA to reverse its position. Those against the change have pointed out that allowing some companies to test for BSE would force all to do so.
In any case, some foreign buyers of US beef want to conduct their own BSE testing. The Japanese want to be able to conduct their own checks and surprise inspections of US packing plants, which Kopperud reports, it appears the US authorities will accept in order to reopen the beef trade to Japan.
Meanwhile, FDA's enforcement activities regarding the ruminant feed ban continue to report very high levels of compliance with the Ruminant Feed Ban, with more than 44,000 inspection reports in hand by the end of April. State officials conducted more than two-thirds, with the remainder conducted by FDA officials. The reports detail three possible levels of compliance official action indicated' (OAI, significant violations requiring regulatory sanctions and re-inspection), voluntary action indicated' (VAI, usually technical violations and minor lapses of recordkeeping, specifying voluntary correction), or no action indicated' (NAI, with no further action necessary).
Among 430 active FDA-licensed feed mills, which were permitted to make medicated feed products and were handling RUPP, there were no OAI reports and only five (1.2%) VAI reports. Similarly, among 2,176 active feed mills not licensed by the FDA but still handling prohibited materials, there also were no OAI reports and only 36 (1.7%) VAI reports. Reporting was comparable for 162 active protein blenders, with no OAI reports and 3 (1.9%) VAI reports.
Both OAI and VAI report incidences were higher among other categories of feed manufacturers and individual firms could be reported under more than one category. However, among 5,103 active firms handling materials prohibited from use in ruminant feed, 5 firms (0.1%) were classified as OAI and 126 firms (2.5%) were classified as VAI. For details, see http://www.fda.gov/cvm/BSE0506.htm.