NEWS: Consumers Union challenges USDA on Mad Cow - Consumers Union 7

[Guest guest]

Consumers Union 7/27/05

 

*Consumers Union calls on USDA to release data on cattle tested for

mad-cow*

 

 

 

*/Group raises serious concerns about credibility of government

surveillance program/*

 

 

 

YONKERS, NY (July 26)-Consumers Union is raising serious questions about

the credibility of the U.S. Department of Agriculture's (USDA) expanded

voluntary mad-cow surveillance program and is asking the agency to

release details on the more than 400,000 cattle tested. In a letter sent

to Agriculture Secretary Mike Johanns today, the group cited serious

deficiencies uncovered by the Office of Inspector General in the earlier

years of the program.

 

 

 

Consumers Union specifically requested data on:

 

 

 

* The geographic location of sampled cattle (including the state where

the cow was born, raised, and slaughtered)

 

 

 

* The age of the cattle tested (CU currently supports testing of all

cattle above 20 months)

 

 

 

* The disease/high-risk status of the cattle (for example, did they

show symptoms of central nervous system disease, which are common

symptoms of mad cow.

 

 

 

"The government keeps telling Americans that they can trust that their

beef is safe from mad cow, even going so far as to say that finding BSE

is like searching for a needle in a haystack. Yet, since the agency has

so far failed to publicly disclose any information whatsoever about the

details of the program, it makes us wonder how meaningful their search

for the disease is at all," says Dr. Michael Hansen, PhD, a Senior

Scientist with Consumers Union.

 

 

 

"We want to know exactly which cattle were tested and whether or not

they really represent the most valid scientific sampling of the

highest-risk animals from across the country. If the USDA wants to truly

reassure the American people, they should answer our questions. Their

failure to do so would make us wonder what the agency is hiding," adds

Hansen.

 

 

 

Consumers Union's letter comes after the USDA's announcement last month

that a cow originally pronounced last November to be negative for mad

cow disease turned out upon re-testing to be positive.

A copy of the letter follows:

 

 

 

------

 

 

 

July 25, 2005

 

 

 

Hon. Mike Johanns

Secretary of Agriculture

US Department of Agriculture

1400 Independence Avenue, SW

Washington, DC 20250

 

 

 

Dear Secretary Johanns:

 

 

 

We are writing to you because we are concerned about the meaningfulness,

credibility and lack of transparency of the expanded BSE Surveillance

Program (hereafter referred to as the "Program") that has been carried

out by the U.S. Department of Agriculture's Animal Plant Health

Inspection Service (APHIS) beginning June 1, 2004. The Office of

Inspector General's (OIG's) Audit Report on the first phase of the BSE

Surveillance Program (e.g. 1990-2004) raises serious questions about the

quality of the data gathered under the Surveillance program.

 

 

 

We are concerned that there are potentially serious methodological

problems and/or flawed assumptions involved with the expanded BSE

Surveillance Program. These methodological problems are that sampled

brains may not be a proper geographical sample of the high-risk

population, and that the highest risk brains may not be included.

 

 

 

The failure of the USDA to release any data whatsoever about the details

of the Program, such as location of sampled cattle (state where born,

raised, slaughtered), age, and disease/high-risk status (e.g. did it

show symptoms of central nervous system [CNS] disease) heightens

concerns about whether the sampling is being conducted in a valid matter.

 

 

 

*Geographic distribution*

 

 

 

We are concerned about whether adequate geographic distribution is being

achieved in the Program. A basic problem is that participation in the

Program is voluntary. The stated goal of the USDA's expanded BSE

surveillance program is "to collect samples from as many adult cattle

from the high-risk population as possible in 12-18 months while ensuring

that there is a statistically appropriate geographical representation of

the adult cattle population in the United States". For this sampling

program to be statistically valid, the cattle chosen for testing must be

a random geographical sample of the high-risk population. To ensure a

random sample, the Program should be mandatory. The OIG's Audit Report

on the first phase of the Program (e.g. 1990-2004), found that prior to

the start of the expanded surveillance program (e.g. June 1, 2004),

sample collection was not geographically random, but rather was

"concentrated in a few slaughter establishments and renderers in a few

States." In addition the OIG noted that "APHIS has no contingency plans

if geographical targets are not obtained" . Thus, */we ask USDA to

release information on the geographical location of all the cattle that

are sampled as part of the Expanded BSE Surveillance Program./*

 

 

 

*Age*

 

 

 

The age of sampled animals is also important. Although BSE is thought

typically to infect animals at a very young age, the disease can have a

long incubation period and is usually detected in older animals

(detection is more difficult in young animals incubating the disease).

Although animals as young as 20 months (United Kingdom ) or 21 months

(Japan ) have been found to test positive for BSE, the detected disease

prevalence is higher for older animals. The Texas cow confirmed with BSE

last month was about 12 years old. Dairy cattle are at higher risk for

BSE compared to beef cattle, because, being productive for a number of

years, they are usually slaughtered at an older age than beef cattle.

Dairy cattle are also more likely to receive protein supplements in

their feed (to support their milk production) than beef cattle. Some 80%

of the BSE cases in the UK occurred in dairy cattle . Thus, we feel that

all elderly dairy cattle should be sampled for BSE. Consequently, we ask

what are the ages of all the cattle that have been sampled for BSE?

 

 

 

*High-risk cattle*

 

 

 

Another potentially serious methodological problem with the expanded

Program is whether it includes the highest risk animals. According to

USDA's 2004 Expanded Surveillance Plan, the high-risk population to be

tested should include "adult cattle showing clinical signs involving the

central nervous system (CNS), and dead and non-ambulatory cattle where

the clinical signs cannot be adequately evaluated" . But not all animals

in this high-risk population are equally high risk. The highest risk

animals are those exhibiting symptoms consistent with BSE, such as

rabies-suspect animals that test negative for rabies, and animals

exhibiting symptoms of CNS disease. In fact, when the USDA first began

the surveillance program in 1989/1990, there were only two categories of

cattle in the high-risk category: rabies-suspect but rabies-negative

cattle and cattle exhibiting CNS symptoms. It wasn't until 1993 that

USDA added downer (e.g. non-ambulatory) cows to the list of high-risk

cattle that were to be sampled for BSE testing.

 

 

 

*Rabies-negative cattle*

 

 

 

All aggressive animals are tested for rabies. If the test is negative,

then some other condition, possibly BSE, is responsible for the

aggressive behavior. Thus, rabies-negative cattle are perhaps the

highest risk cattle of all. USDA states that all rabies-suspect cattle

that test negative for rabies should be tested for BSE . However, the

OIG's Audit Report on the first phase of the Program (e.g. 1990-2004),

points out that only a small percentage of rabies-suspect,

rabies-negative cattle were actually tested for BSE. The OIG report

surveyed five state laboratories and found that only 16% of the

rabies-negative samples (94 of 586) from those states were sent for BSE

testing . The OIG noted that there was neither a requirement for

rabies-negative cattle to be tested nor a formal mechanism in place to

routinely submit such samples for testing. The OIG noted that, of 175

rabies-negative cattle tested for rabies at a laboratory in Iowa--in the

same state as USDA's National Veterinary Services Laboratory

(NVSL)--during FY 02-03, only two were sent to NVSL for testing for BSE.

Indeed, the OIG noted that as of 2004 officials from South Dakota were

not even aware that rabies-negative cattle could be sent for BSE

testing! Finally, the OIG noted that "As of June 1, 2004, APHIS has not

provided us with any detailed plans on how samples for this targeted

high-risk group will be obtained" . Since this is perhaps the highest

risk group for BSE, we must ask how many rabies-negative cattle occurred

in the U.S. from June 1, 2004 to July 1, 2005 and how many of these

rabies-negative cattle were actually tested for BSE? If not all

rabies-negative cattle, considered to be the highest-risk cattle, are

sampled, then we question how useful the data are on the rest of the

animals.

 

 

 

*Cattle with CNS symptoms*

 

 

 

Cattle that are condemned at slaughter for CNS symptoms are also

considered to be among the highest-risk cattle for BSE. According to the

OIG's report, USDA's Food Safety Inspection Service (FSIS) condemned 680

cattle for CNS symptoms between fiscal year 2002 and 2004. Of these 680

cattle 357, or 52%, were classified as adults. Using APHIS records, OIG

found that only 162 cattle condemned for CNS symptoms were tested for

BSE in this period; this represents 45% of the adult cows (162 of 357)

or 24% of all cattle (162 of 680) condemned for CNS symptoms. In April,

2004, a cow condemned for CNS symptoms at a slaughter plant (Lone Star

Beef) in San Angelo, TX was not tested for BSE, even though the FSIS

officials at the plant had asked that the animal be tested for BSE .

Apparently, an APHIS official in Austin, Texas had overruled the FSIS

officials at the plant. As a result of this incident, APHIS and FSIS

issued a joint notice in May 2004 (FSIS Notice 28-04) which stated that

henceforth all animals condemned for CNS symptoms would be tested for

BSE, regardless of the age of the animal. We thus ask how many cattle

were condemned for CNS symptoms between June 1, 2004 and July1, 2005?

How many of these cattle were actually tested for BSE?

 

 

 

*Cattle that died on the farm*

 

 

 

As the OIG report stated,

 

 

 

"Identifying truly high-risk cattle that die on the farm may be

complicated by the reluctance of producers to submit them and the

motivation [of others] to mischaracterize low risk carcasses as "high

risk" since only the latter may qualify for reimbursement. These

inherent problems can lead to an understatement of the projected maximum

BSE prevalence rates for truly high-risk cattle and a reduced chance of

detecting BSE, if it exists" (OIG, 2004: pg. 16).

 

 

 

According to USDA's 2004 Expanded Surveillance Plan, the high-risk

animals that die on the farm make up the largest component of USDA's

targeted high-risk population. According to the USDA's Expanded

Surveillance Plan, 56% of the 446,000 adult cattle in the "high risk"

group will be "adult cattle that die on farm each year due to unknown

reasons or reasons that could be consistent with BSE-related clinical

signs" . In the General Accounting Office (GAO) audit report on the FDA

and USDA actions on BSE, GAO pointed out that USDA didn't sample many

animals that died on the farm and also didn't separately track brains

from such animals; such animals were counted in the downer cow category

.. The OIG report noted that "we could not determine if samples from this

targeted group [cows that died on the farm] have been obtained in the

past" italics added. We note that the November, 2004 cow that ultimately

tested positive has now been found to be a "dead" cow--it showed up dead

at the slaughter plant and was redirected to the Champion Pet food plant

in Waco, Texas . Thus we ask How many cattle died on the farm in the

U.S. between June 1, 2004 and July 1, 2005? How many dead cattle were

actually tested for BSE?

 

 

 

*Conclusion*

 

 

 

These very important basic facts about the USDA's Expanded Surveillance

Program are essential to an assessment of the validity of the Program.

The American public, and America's trading partners, have had their

faith shaken in USDA's Surveillance Program by the disclosure of severe

shortcomings in its confirmation procedures. These shortcomings led USDA

to announce on November 22, 2004 that a cow was a confirmed negative

when seven months later proper testing showed it was, in fact, positive

for BSE. In order to maintain trust in its Surveillance Program, USDA

should immediately answer our questions and disclose to the public the

details of the Program.

 

 

 

Sincerely,

Michael Hansen, Ph.D., Senior Scientist

Jean Halloran, Director, Food Policy Initiatives

 

 

 

Contacts: Michael Hansen, 914-378-2452; Jen Shecter, 914-378-2402

 

 

 

http://www.consumersunion.org/pub/campaignmadcow/002530.html