GAO: Mad Cow Disease: An Evaluation of a Small Feed Testing Program

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Here's the link to a PDF of a U.S. GAO letter about testing feed to

protect agains Mad Cow disease.

 

http://www.gao.gov/new.items/d06157r.pdf

 

GAO documents tend to be long-winded and very polite to criminals.

Nevertheless, what they are basically saying is that FDA laboratories

drag their feet and slow down testing so long, that by the time many

tests are completed, the feed has already been fed to other cows. In

other words, the government's program is not really providing effective

protection.

 

A nice piece of literature for anyone's meat-eating uncle or neighbor.

 

Below is an excerpt.

 

your servant,

 

Hare Krsna dasi

 

 

Conclusions

 

FDA’s June 2005 directive and the July 2005 revised assignment include

important new

controls that address many of the weaknesses we found in the feed

testing program.

However, the new directive and guidance will be useful only when FDA

ensures their full

implementation. One important requirement in the directive and

guidance—for districts

to document their follow-up activities and compliance decisions—will

allow FDA to use

the program results to supplement the agency’s other BSE oversight

activities. FDA’s

districts and laboratories believe they have implemented the feed

testing program

diligently and thoroughly, using their best professional judgment. That

notwithstanding,

until the districts’ actions are documented in a fashion that fully

explains the basis for

their compliance determinations, FDA cannot verify and hence cannot

confidently rely

on the testing program results.

 

Another important requirement in the new directive is the addition of a

30-day time limit

for districts to complete their follow-up actions and make final compliance

determinations for feed samples that identify potential violations of

the feed-ban rule.

** That new guidance notwithstanding, we remain concerned about the

overall time frame.

We found that more than 30 days elapsed between the date samples were

collected and

the date laboratories completed their analysis for nearly half the

samples, and that these

two steps took more than 100 days in some instances.** Only then would

districts have

begun their follow-up activities. However, both FDA and industry agree

that cattle feed

is consumed very quickly. **Consequently, by the time FDA completes its

follow up

activities and determines that a violation has occurred, the feed may

have been

consumed.** We believe that both the districts and the laboratories need

to carry out their

feed testing program responsibilities promptly to minimize cattle’s

exposure to

potentially contaminated feed.

 

While FDA’s new assignment instructions recognize the importance of

management

accountability, they do not include specific oversight requirements that

will address the

15 GAO-06-157R FDA Feed Testing Program

 

deficiencies we identified. Even though the feed testing program is

small, adequate

management oversight of the program is critical, because the resources

FDA spent on

the program since August 2003 came directly from the agency’s limited

BSE oversight

funding. If they exercise appropriate oversight, FDA headquarters

managers can help

ensure that future results of the feed testing program will be reliable,

and that BSE

resources will be carefully spent. In this regard, we believe that

periodic reports using

FACTS data would be useful. Other internal controls may also provide useful

management oversight, and FDA would benefit if it developed performance

indicators

and set goals for its managers to use to determine whether and to what

extent the feed

testing program is contributing to the agency’s BSE oversight efforts.

Finally, feed testing has the potential to be an important tool in FDA’s

feed-ban oversight

arsenal as technology improves, and we believe FDA would benefit by

encouraging the

development, testing, and implementation of new feed testing

technologies. PCR is a

better tool than feed microscopy, and the capabilities of PCR are being

refined and

improved. As more accurate and effective PCR and other feed testing

technologies

emerge, the value of feed testing to FDA’s BSE oversight will increase.