U.S. Violates World Health Organization Guidelines for Mad Cow Disease

[Guest guest]

U.S. Violates World Health Organization Guidelines for Mad Cow Disease:

A Comparison of North American and European Safeguards

 

by Michael Greger, M.D. for the Organic Consumers Association

<http://www.organicconsumers.org/madcow.htm>

June 4, 2003

 

The National Cattlemen's Beef Association describes government and

industry efforts to safeguard the American public from mad cow

disease as " swift, " " decisive " and " aggressive. " [1] The US Secretary

of Agriculture adds " diligent, " [2] " vigilant " and " strong. " [3] The

world's authority on these diseases disagrees.

 

Dr. Stanley Prusiner is the scientist who won the Nobel Prize in

Medicine for his discovery of prions, the infectious agents thought

to cause bovine spongiform encephalopathy (BSE), or mad cow disease.

The word Dr. Prusiner uses to describe the efforts of the U.S.

government and the cattle industry is " terrible. " [4] What are these

" stringent protective measures " [5] that the Cattlemen's Association

is talking about, and how do they compare to global standards and

internationally recognized guidelines?

 

In 1996, in response to the revelation that young people in Britain

were dying from variant Creutzfeldt Jakob Disease (vCJD), the human

equivalent of mad cow disease, the World Health Organization (WHO)

issued seven " Recommendations. " Numbers 5-7 were observations and/or

recommendations for further research. The first four recommendations,

however, were concrete proscriptions to reduce the likelihood of mad

cow disease spreading to human populations.[6] To this day, the

United States government continues to violate each and every one of

these four guidelines.

 

#1. Stop Feeding Infected Animals to Other Animals

 

The number one recommendation of the World Health Organization was

that no " part or product " of any animal showing signs of a

transmissible spongiform encephalopathy (TSE), or mad cow-like

disease, should be fed to any animal.[7] " All countries, " the

guideline reads, " must ensure the slaughter and safe disposal of

TSE-affected animals so that TSE infectivity cannot enter any food

chain. " [8] Yet, in the U.S., it remains legal to feed deer and elk

known to be infected with a transmissible spongiform encephalopathy

called chronic wasting disease to livestock such as pigs and

chickens.[9]

 

Although science has yet to investigate whether pigs and chickens are

susceptible to " mad deer " prions, there is a concern that even if

these animals don't develop clinical symptoms of the disease, they

could become so-called " silent carriers. " Dr. Richard Race is a

Senior Investigator with the National Institutes of Health.[10] In

2001, he published a landmark paper showing that even species thought

to be resistant to particular strains of prions could invisibly

harbor the disease and pass it on to other animals.[11] He also found

that these deadly prions were somehow able to adapt to the new

species, becoming even more lethal and replicating faster and

faster.[12]

 

At a 2002 symposium on chronic wasting disease, Dr. Race expressed

concern that U.S. cattle could be invisibly harboring chronic wasting

disease and passing it on to humans.[13] The reason Dr. Race is so

concerned is because chronic wasting disease seems unique in that

it's the only prion disease thought to be spread by casual

contact[14] between deer through exposure to, or exchange of, bodily

fluids such as saliva.[15] And, the best available research suggests

that CWD prions can infect humans as well, perhaps even as readily as

mad cow disease can.[16] Dr. Race wonders if people could become

silent carriers as well.[17] And, " If these people are subclinical

carriers, " Race asked, " do they represent a threat to other

people? " [18] All transmissible spongiform encephalopathies are

invariably fatal.[19] Consumer advocates argue that these prions

should not be allowed to enter into the food chain.[20]

 

In May 2003, the Food and Drug Administration finally drafted up

proposed voluntary " suggestions " for the rendering industry,

recommending that deer and elk infected with chronic wasting disease,

or at high risk for the disease, be excluded from animal feed.[21]

However, even if this proposal is enacted, it represents only

non-binding, non-enforceable " guidance " recommendations for the

industry. The FDA made these same kinds of " guidance " recommendations

to pharmaceutical companies over a decade ago, discouraging the use

of bovine-derived materials from countries with mad cow disease in

manufacturing their vaccines,[22] only to learn 7 years later that

major pharmaceutical manufacturers simply ignored the guidelines.[23]

 

Europe's Scientific Steering Committee met in 2003 and agreed that

the United States should comply with the World Health Organization

guidelines and ban the feeding of animals infected with chronic

wasting disease to other animals.[24] The United States seems to

remain the only country that knowingly allows prion infected animals

to be fed to other animals, including those destined for the dinner

plate.

 

#2. All Countries Need to Establish Adequate Testing and Surveillance

 

The World Health Organization's second guideline was for all

countries to establish adequate testing and surveillance for mad cow

disease according to the standards set down by the Office

International des Epizooties (OIE), World Animal Health

Organization.[25] The beef industry and the USDA claim that the level

of U.S. testing " far exceeds " these international testing

standards.[26] If one goes to the USDA website and clicks on " for the

latest info on BSE Surveillance, " for example, one can read that " OIE

recommends a surveillance level of 433 samples per year. " [27] And

that, in 2002 alone, the U.S. tested almost 20,000 cattle for the

disease.[28] But if one reads the actual recommendations,[29] one can

see that the USDA isn't telling the whole story.

 

The oft-cited " 433 " figure[30-32] is indeed found in Article 3.8.4.2.

of the OIE's International Animal Health Code.[33] But it just

represents the required minimum number of cattle showing suspicious

signs that should be examined each year.[34] For examples, these are

cows that show " excitability, " or " persistent kicking when

milked. " [35] The Animal Health Code then directly goes on to

recommend, in Article 3.8.4.3, that " Cattle that have died or have

been killed for reasons other than routine slaughter (including

'fallen' stock and emergency slaughter) should be examined. " [36] This

is where the United States (and Canada) fall seriously short.

 

The combination of these two populations, " fallen stock and emergency

slaughter cattle, " is essentially equivalent to the U.S.

nonambulatory, or " downer " cattle population.[37] Every year, an

estimated 195,000[38] to a million[39] cattle collapse in the U.S.

for largely unknown reasons and are too sick or injured to rise.[40]

Even though these downed animals are not even fit enough to stand, an

investigation of USDA slaughterhouse records showed that most of them

are still ruled fit enough for human consumption.[41] Quoting from a

USDA document released in 2002, " Thus, if BSE were present in the

U.S., downer cattle infected with BSE could potentially be offered

for slaughter and, if the clinical signs of the disease were not

detected, pass ante-mortem inspection. These cattle could then be

slaughtered for human food. " [42]

 

Based on findings in Europe,[43] and evidence of at least a rare form

of mad cow disease already striking downer cows in the U.S.,[44]

downer cattle are considered to be a particularly high risk

population. The OIE recommends they be tested for mad cow

disease.[45] Over the past ten or so years, though, the USDA has

tested less than 2% of the downer cattle in United States.[46] And,

those tests were almost exclusively limited to animals that were sent

to slaughter.[47] The U.S. tests even fewer of the downer cattle on

farms and ranches that never make it to the slaughterhouse,

considered the single highest risk cattle population in the United

States.[48] These dead, dying or downed cattle can still then be fed

to other livestock.[49] It's no wonder that Dr. Prusiner, the world's

expert on prion disease, describes the number of tests done by USDA

as " appalling. " [50]

 

When asked what level of testing in the U.S. he'd be comfortable

with, Prusiner replied, " " Well, I'd like to see every downer cattle,

every fallen cow tested. That's a beginning. And then after that, at

some point, I'd like to see every cow tested, just as they do in

Japan. Every single cow is being tested in Japan. " [51] In Europe,

100% of all adult downer cattle are tested,[52] as well as 100% of

all healthy cows over a certain age that are slaughtered for human

consumption.[53] If the animal isn't tested, then by law, the animal

must be destroyed.[54]

 

The United States and Europe have similar cattle populations,[55] yet

Europe tests almost a million cattle every month.[56] France, which

has only a fraction of the U.S. cattle population, tests more cattle

in a single week then the U.S. has tested in a decade.[57] According

to Europe's latest annual report, Europe is testing cattle at a rate

of almost two thousand times that of the United States.[58] Yes, the

beef industry argues, but they have the disease, and we don't.

 

The beef industry's position is an illustration of circular

reasoning: We don't rigorously test, because we haven't found any

cases.[59] In the Summer of 2000, the Scientific Steering Committee

of the European Union, an internationally recognized group of BSE

experts, conducted and published elaborate risk assessments for a

wide variety of countries.[60] They concluded that the risk status of

a country like Austria ( " Unlikely, but not excluded " ),[61] was

identical to that of the United States.[62] This didn't stop Austria,

though, from learning from the rest of Europe's example and testing

all cattle slaughtered for human consumption over a certain age.[63]

Though they too declared their country " BSE-free, " [64] within months

of initiating their testing program they discovered their first

case.[65]

 

The meat industry, however, opposes more testing.[66] Dan Murphy, the

spokesperson for the American Meat Institute, responded to criticism

by stating, " Further testing would cost taxpayers more money, could

slow production and would yield no benefits. " [67] He reiterated,

" It's a matter of asking the question, 'Where would the benefit

be?' " [68] I'm sure Don Simms has an answer for Mr. Murphy. His

teenage son lies twitching in a hospital bed in Belfast. Jonathan

Simms, once healthy, strong and athletic, is in a coma, wasting away

on the verge of death from mad cow disease, like so many dozens of

teens before him.[69]

 

Dan Murphy argues that the U.S. government " already tests the animals

that are at risk. " [70] He likened expanding the testing program to a

larger number of animals " to testing elementary students for

Alzheimer's disease. " [71] But again, the United States tests only a

minuscule percentage of the animals at most risk--the downer

cattle.[72]

 

Beyond high risk populations, though, Dan Murphy is correct when he

implies that the U.S. cattle population is younger than that in

Britain. Less than half of American dairy cows make it past their

fourth birthday, before being retired into hamburger meat.[73] In

fact the majority of U.S. cattle are slaughtered before they reach

age two.[74] While this may mean that the prion load in an infected

animal may be less at slaughter (since prions accumulate with age),

it also means mad cow disease may be harder to detect in the United

States.[75]

 

On that fated Oprah show, the spokesperson for the National

Cattlemen's Beef Industry assured consumers that no animal could ever

enter a U.S. slaughterhouse displaying BSE symptoms.[76] As the

European Commission's risk assessment of the U.S. points out, though,

the " young age at slaughter makes it unlikely that fully developed

clinical cases would occur (and could be detected)... " [77] Younger

cattle could be infected and infectious, but be slaughtered for human

consumption before they started showing symptoms.[78] In fact, that

first case of mad cow disease in Austria was detected in a cow who

presented no clinical signs.[79] The only reason that the infected

Austrian cow was prevented from entering the human food supply is

because, even though they had no recorded cases[80] and even though

the country was deemed as low risk as the United States,[81] Austria

instituted a surveillance program that tested every cow slaughtered

for human food over 30 months of age.[82] The chief reason that the

present mad cow surveillance program has not confirmed cases in the

U.S. could be because the surveillance program is inadequate.[83]

 

Another country that was ruled just as unlikely as the United States

to have mad cow disease was Canada.[84] Saying Canada has mad cow

disease is not far from saying the United States does, because the

cattle industries of both countries are fully integrated across an

open border.[85] Every year, the U.S. imports over a million head of

cattle[86] and billions of pounds of beef from Canada.[87] How can

the U.S. still call itself BSE-free when over three quarters[88] of

Canadian cattle exports end up in the United States? Mad cow disease

has been detected in North America.

 

Dr. Bruno Oesch of Zurich University recently told the BBC that US

consumers may well have been eating infected beef for some time

now.[89] The New Scientist, a weekly British science digest, reports

that, based on the Canadian case, it is " likely " that the mad cow

disease is also present in the United States.[90] So the question of

whether or not the U.S. had in the past been meeting international

testing standards for BSE-free countries may now be moot. Now that

mad cow disease has been found in a downer cow in North America, is

the USDA drafting plans to at least step up its surveillance of

downer cattle? According to a spokesperson for the USDA, " at the

moment, no changes [in the U.S. testing program] are being

discussed. " [91]

 

 

#3. Stop feeding bovine brains, eyes, spinal cords or intestines to

people or livestock

 

 

The third key recommendation of the World Health Organization is that

" Countries should not permit tissues that are likely to contain the

BSE agent to enter any food chain, human or animal. " [92] Basically,

this means excluding cattle brains, eyes, spinal cord and intestine

(from small intestine to rectum) from the human food supply, and from

all animal feed.[93] Unfortunately, the U.S. still feeds those

potentially risky tissues to people, pigs, pets and poultry.

 

High risk tissues in human food

 

Although beef brains, guts, eyes and spinal cords are available to

consumers as " variety meats, " they are labeled as such and therefore

represent only a small fraction of the American public's exposure to

these organs.[94] People are more likely to consume potentially

infectious tissues such as spinal cord disguised within all-American

favorites, like hot dogs and hamburgers.

 

After a cow is slaughtered and the standard cuts of beef removed, one

is left with a bloody skeleton with a few scraps of meat still

attached. To recover any last shreds of meat, the bones, prebroken or

whole, may be placed in a giant vice-like device that crushes the

carcass into bone " cakes. " [95] Out through a sieve at the bottom runs

a " batter-like " [96] paste of " spread-like consistency " referred to as

mechanically separated meat.[97] The potentially highly infectious

spinal cord and fluid may be forced out of the backbone and spewed in

the final product.[98] Mechanically separated beef has been " used as

a meat ingredient in the formulation of quality meat food

products " [99] in the United States since the 1970's.[100] Examples of

such " quality meat food products " include hot dogs, sausages and

burgers.[101] By law, hot dogs can contain up to 20% of this

mechanically separated beef.[102]

 

Although food containing mechanically separated beef must be labeled

as such, there are no labels on food in restaurants.[103] So people

could be exposed to spinal cord tissue in hot dogs, sausages,

hamburgers, and ground meat products when dining out.[104] Although

Europe heeded the World Health Organization's warnings and banned

such meat recovery systems years ago, these devices remain one of the

best opportunities for prion-infected tissues to enter the human food

supply in North America.[105]

 

In 1994, meat processors began using a new technology, called

advanced meat recovery (AMR), to help " increase yields and

profitability. " [106] These systems also extrude meat from the remains

of the carcass under pressure, but without crushing the bones.[107]

The American Meat Institute describes the process: " Just as fruit

processors use machines to remove fruit from peels thoroughly and

efficiently, meat companies use similar equipment to remove meat from

some hard to trim bones. " [108]

 

The end-product varies from a ground beef-like texture to the

consistency of thick tomato sauce.[109] Prior to 1994, only cattle

skeletal muscle, tongue, diaphragm, heart, and esophagus could be

labeled as beef.[110] But by the end of that year, the USDA had

already amended the definition of " meat " to include the product of

advanced meat recovery machinery.[111] This meant that unlike

mechanically separated meat, AMR meat was considered 100% beef and

could be labeled as such.[112] With no special labeling requirements,

adoption of AMR machinery spread rapidly throughout the industry,

largely replacing mechanical separation equipment.[113]

 

Today, the majority of cattle are now processed using AMR.[114] Over

twenty thousand tons of AMR beef is produced every year in the U.S.,

valued at over $100 million.[115] AMR beef typically ends up as a

hidden ingredient in hamburgers, hot dogs, sausages, and beef jerky,

as well as part of ground beef in meatballs, pizza toppings and taco

fillings.[116] The danger, once again, is that if the spinal cord

isn't removed before entering one of these machines, it is bound to

be incorporated into the meat that is produced.[117]

 

Companies are supposed to remove the animals' brains and spinal cords

before processing the carcasses through the AMR machinery, but

getting out all of the spinal cord can be challenging. " It requires

special tools and skills, " says Glenn Schmidt, a meat scientist at

Colorado State University. " The workers have to reach down to the

neck region of the carcass to remove the spinal cord by scraping or

suction, and sometimes they don't get all of it. " [118]

 

In 1997, the consumer advocacy organization Public Citizen obtained

USDA inspection records through the Freedom of Information Act

showing that a significant percentage of AMR samples were turning up

contaminated with central nervous system (CNS) tissue (brain or

spinal cord).[119] Instead of simply requiring that spinal columns be

removed from carcasses before being placed in advanced meat recovery

systems, the USDA responded by merely directing its inspectors to

continue testing samples of AMR meat for the presence of central

nervous tissue.[120]

 

Despite their promise to initiate testing, the USDA took fewer than

60 samples over the next 3 years, yet still found spinal cord in a

number of them.[121] The first major study of AMR meat was published

in 2001.[122] Colorado State University researchers found that " well

over 50% " of the samples of AMR beef from neck bones were

contaminated with CNS tissue.[122] Then they went to 7 major

suppliers of large fast food chains across the country to sample

hamburger patties. Six out of seven suppliers had detectable CNS

tissue in their burgers.[123]

 

The USDA again responded only with promises to do more testing.[124]

The results of the USDA's tests were made public in 2002.[125]

Eighty-eight percent of the meat processors (30 out of 34) were

producing AMR beef which contained unacceptable nervous tissue, and

almost all of the samples (96.5%) contained bone marrow,[126] which

may also be infectious.[127]

 

In 2001, the World Health Organization, in consultation with the

World Animal Health Organization and the Food and Agriculture

Organization of the United Nations, reiterated the need for countries

to remove and destroy all tissues proven capable of transmitting mad

cow disease, such as spinal cord.[128] And, the only way to guarantee

that AMR beef, or mechanically separated " beef, " is free of spinal

cord is to require meat processors to remove the entire spinal column

before sending cattle carcasses through their machinery.[129] So that

year, the consumer advocacy group Center for Science in the Public

Interest (CSPI) petitioned the USDA to do just that.[130] The

petition was supported by the American Public Health Association, the

Consumer Federation of America, the Government Accountability

Project, the National Consumers League, and Safe Tables Our

Priority.[131]

 

The petition was opposed by the National Cattlemen's Beef

Association,[132] the National Renderers Association,[133] the

National Meat Association,[134], the Pork Producers Council, the

sheep industry, the milk producers, the Turkey Federation, and eight

other industry trade groups.[135] After all, about 50 percent of AMR

meat comes from the neck bones and spine which contain the spinal

cord.[136] U.S. meat industry analysts claim that any public health

measure to remove these bones would simply be too costly for the

industry.[137]

 

The meat industry has invested at least $40 million in AMR machines

since their introduction in 1994, some of which that can process

9,000 lbs. of bones per hour.[138] Industry analysts place the final

figure of complying with any proposed USDA regulation that bans neck

bones and backbones at close to $200 million dollars.[138] The

European Commission considers the removal of cattle brains, eyes,

spinal cord and intestines from the human food supply as " the single

biggest contribution that can be made to reducing the risk to

humans. " [139] Rather than learning from the outbreak in Europe

though, the U.S. livestock industry seems to oppose even the most

minimal tightening of U.S. feed regulations.[140]

 

The meat industry argues that voluntary compliance is enough.[141]

Seven years of testing by USDA inspectors, however, has demonstrated

otherwise.[142] This same inability to rely on industry efforts was

discovered in Britain. British meat processors also weren't able to

completely remove the spinal cord, so the law was changed to simply

remove the entire spine prior to processing.[143]

 

However, here in the United States, the USDA continues to allow

tissues in the American beef supply which are so potentially

dangerous that the Food and Drug Administration has excluded them

from cattle feed.[144] As CSPI's Director of Food Safety put it,

" U.S. cattle aren't allowed to eat cattle spinal cord - and neither

should people, " especially children--AMR beef is still allowed in the

National School Lunch Program.[145] Thanks to CSPI,[146] at least AMR

beef from downer cattle is now excluded from the school lunch

program.[147] And, for years the government has excluded mechanically

separated meat from baby food, but only because the product might

mottle an infant's teeth as a result of increased fluoride

intake[148] from all the crushed bone particles that get extruded

into the paste.[149]

 

And, even if Americans just stick to steak, they may not be shielded

from risk. The " T " in a T-bone steak is a vertebra from the animal's

spinal column, and as such may contain a section of the actual spinal

cord.[150] Other potentially contaminated cuts include porterhouse,

standing rib roast, prime rib with bone, bone-in rib steak, and (if

they contain bone) chuck blade roast and loin.[151] These cuts may

include spinal cord tissue and/or so-called dorsal root ganglia,

swellings of nerve roots coming into the meat from the spinal cord

which have been proven to be infectious as well.[152]

 

Even boneless cuts may not be risk-free, though. In the

slaughterhouse, the bovine carcass is typically split in half down

the middle with a band saw, sawing right through the spinal column.

This has been shown to aerosolize the spinal cord and contaminate the

surrounding meat.[153] A study in Europe found contamination with

spinal cord material on 100% of the split carcasses examined.[154]

Similar contamination of meat derived from cattle cheeks can occur

from brain tissue, if the cheek meat is not removed before the skull

is fragmented or split.[155] The World Health Organization has

pointed out that American beef can be contaminated with brain and

spinal cord tissue in another way as well.[156]

 

Except for Islamic halal and Jewish kosher slaughter (which involve

slitting the cow's throat while the animal is still conscious),

cattle slaughtered in the United States are first stunned unconscious

with an impact to the head before being bled to death. Medical

science has known for over 60 years that people suffering head trauma

can end up with bits of brain embolized into their bloodstream; so

Texas A & M researchers wondered if fragments of brain could be found

within the bodies of cattle stunned for slaughter. They checked and

reportedly exclaimed, " Oh, boy did we find it. " [158] They even found

a 14 cm piece of brain in one cow's lung.[159] They concluded, " It is

likely that prion proteins are found throughout the bodies of animals

stunned for slaughter. " [160]

 

There are different types of stunning devices, however, which likely

have different levels of risk associated with them. The Texas A & M

study was published in 1996 using the prevailing method at the time,

pneumatic-powered air injection stunning.[161] The device is placed

in the middle of the animal's forehead and fired, shooting a 4 inch

bolt through the skull and injecting compressed air into the cranial

vault which scrambles the brain tissue. The high pressure air not

only " produces a smearing of the head of the animal with liquefied

brain, " [162] but has been shown over and over to blow brain back into

the circulatory system, scattering whole plugs of brain into a number

of organs[163] and smaller brain bits likely into the muscle meat as

well.[164]

 

Although this method of stunning has been used in the United States

for over 20 years,[165] the meat industry, to their credit, has been

phasing out these particularly risky air injection-type stunners. The

Deputy Director of Public Citizen argues that this industry

initiative should be given the force of federal regulation and

banned,[166] as they have been throughout Europe.[167]

 

The stunning devices that remain in widespread use drive similar

bolts through the skull of the animal, but without air

injection.[168] Operators then may or may not pith the animals by

sticking a rod into the stun hole to further agitate the deeper brain

structures to reduce or eliminate reflex kicking during shackling of

the hind limbs.[169] Even without pithing, which has been shown to be

risky, these stunners currently in use in the U.S. today may still

force brain into the bloodstream of some of these animals.[170-173]

 

In one experiment, for example, researchers applied a marker onto the

stunner bolt. The marker was later detected within the muscle meat of

the stunned animal. They conclude: " This study demonstrates that

material present in... the CNS of cattle during commercial captive

bolt stunning may become widely dispersed across the many animate and

inanimate elements of the slaughter-dressing environment and within

derived carcasses including meat entering the human food chain. " [174]

Even non-penetrative " mushroom-headed " stunners which just rely on

concussive force to the skull to render the animal unconscious may

not be risk free. People in automobile accidents with non-invasive

head trauma can still end up with brain embolization,[175] and these

bolts move at over 200 miles per hour.[176] The researchers at Texas

A & M conclude, " Reason dictates that any method of stunning to the

head will result in the likelihood of brain emboli in the lungs or,

indeed, other parts of the body. " [177]

 

And, finally, even if consumers of American beef just stick to

boneless cuts from ritually slaughtered animals who just happen to

have had their spinal columns safely removed, the muscle meat itself

may be infected with prions. The National Cattlemen's Beef

Association continues to assure consumers that beef is safe because

the deadly prions aren't found in muscle meat.[178] Even putting

aside contamination issues, it seems they are simply behind the

times. In 2002, Stanley Prusiner, the Nobel laureate who discovered

prions, proved in mice, at least, that muscle cells themselves were

capable of forming prions.[179] He describes the levels of prions in

muscle as " quite high, " and describes the studies relied upon by the

Cattlemen's Association as " extraordinarily inadequate. " [180]

Follow-up studies in Germany published May, 2003 confirm Prusiner's

findings, showing that an animal who are orally infected may indeed

end up with prions contaminating muscles throughout their body.[181]

 

This newly discovered muscle infectivity highlights how little we

know about these diseases. For example, the American Meat Institute

released a fact sheet on BSE stressing that while the new variant of

Creutzfeldt Jakob Disease (vCJD) was known to be caused by eating

infected cattle parts, the more common classic form of CJD, the

so-called " sporadic " form, had nothing to do with mad cow disease.

The November 2002 fact sheet emphatically stated, " There is

absolutely no evidence to suggest that CJD is caused by any food,

including beef.[182] But by the next month, December 2002, there was

evidence.[183]

 

The surprising new finding linking mad cow disease with classic CJD

has been used to explain the rising numbers of those stricken with

the classic form of CJD in Europe.[184] We don't the incidence of

this fatal disease in North America, because the disease isn't

tracked here like it is in Europe.[185] We do know though, that when

researchers have actually gone back and looked at the brains of

presumed Alzheimer's deaths--where Alzheimer's was indicated on the

death certificate--anywhere from between 3%[186-187] to 25%[188-190]

had actually died of Creutzfeldt Jakob Disease. According to the CDC,

Alzheimer's Disease is now the 8th leading cause of death in the

United States,[191] affecting as many as 4 million Americans.[192]

Despite the fact that an unknown number of Americans are already

dying from this disease, the beef industry continues to ignore the

evidence.[193]

 

The uncertainties inherent to this mysterious class of diseases make

it even more important for the U.S. to follow the directives of the

World Health Organization, and the lead of affected countries around

the world, to implement concrete, practical measures to safeguard the

American public.

 

High risk tissues in animal feed

 

In another direct violation of the World Health Organization

recommendations and international standards,[194] the tissues with

the highest potential for risk, cattle brains and spinal cord, are

rendered directly into animal feed that continues to be fed legally

to pigs[195] and chickens[196] in North America.[197-198] The major

concern in feeding rendered cattle remains to other animals is that

the cattle remains may directly, or indirectly, find their way back

into cattle feed, which could potentially spark a British style

outbreak of mad cow disease.

 

In the United States, slaughterhouse waste from cattle is rendered,

or melted down, into " meat and bone meal " which is used in animal

feed, to help " animals grow bigger and faster. " [199] Over 18 million

pounds of meat and bone meal are produced every day in the United

States.[200] Up until May 20th, 2003, the U.S. imported an extra

100,000 lbs. from Canada every day as well.[201] While rendering can

destroy conventional pathogens like viruses and bacteria, none of the

rendering methods used in the U.S.[202] or Canada[203] have been

shown to significantly destroy prion infectivity.

 

Almost all fattening beef cattle, all dairy calves and all adult

dairy cows raised conventionally are fed meat and bone meal in the

United States.[204] In fact, conventional dairy cows eat about a

pound of meat and bone every day in North America.[205-206] Since the

partial 1997 FDA feed ban, however, this meat and bone meal is not

supposed to come from ruminants--other cattle, sheep or deer.

Unfortunately, these regulations have been poorly enforced. In 2001,

the Food and Drug Administration published the results of a national

survey of rendering plants and feed mills. Up to a quarter of the

plants were found in violation of the 1997 feed regulations years

after the so-called " ban " went into effect.[207]

 

Ruminant meat and bone meal, even derived from downer cattle too sick

to walk or stand, can still be sold in North America. As pointed out

by Dr. Michael Hansen from the Consumers Union, " All they said is

that you've got to label it, 'Do not feed to cattle and other

ruminants.'[208] Farmers can walk in a feed store and still buy it.

Nobody asks, 'Are you feeding it to cattle or pigs?' " [209] As tough

as it is to enforce the feed-labeling compliance among renderers and

feed mills, it's virtually impossible to effectively monitor

America's thousands of livestock producers.

 

Even in Britain, the country most affected by mad cow disease,

inspections showed that it was impossible to enforce the feed ban. If

ruminant bone meal was available, and it was cheap, British farmers

continued to illegally feed it to their cattle. The U.K. even had to

ban the use of mammalian meat and bone meal as agricultural

fertilizer to keep it out of the stores.[210] Meanwhile in the United

States, violations of the 1997 feed regulations continue to this

day.[211]

 

Even with 100% compliance with the feed regulations, however, cattle

remains are still legally fed to pigs, for example, which have been

found to be susceptible to BSE prions.[212] Then the pig remains can

be fed back to cattle.[213] Or cattle remains can be fed to chickens,

and then the poultry litter can be fed back to cows.[214] In these

ways, prions may be indirectly cycled back into cattle feed.

 

Poultry litter is the mixture of excrement, spilled feed, dirt,

feathers, etc. that gets scooped from the floors of poultry sheds

every year.[215] Because poultry litter can be as much as eight times

cheaper than alfalfa,[216] the cattle industry feeds an estimated one

million tons of poultry litter to cattle every year.[217] Although

excrement from other animals is fed to livestock in the U.S., chicken

droppings are considered more nutritious for cows, compared to hog

feces or cattle dung.[218] A thousand chickens can make enough waste

to feed a growing calf year round.[219]

 

Although a single cow can eat as much as 3 tons of poultry waste a

year,[220] the manure in the feed does not seem to affect the taste

of the milk or the meat.[221] Taste panels have found little

difference in the tenderness, juiciness and flavor of beef made from

steers fed up to 50% poultry litter. In fact, beef made from steers

fed bird droppings may be even more juicy and tender.[222] Cows are

typically not fed more than 80% litter, since it's not as

palatable[223] and may not fully meet protein and energy needs.[224]

 

Under the 1997 feed regulations, the FDA specifically allowed the

feeding of chicken litter to cattle to continue, even if the chickens

had just been fed meat and bone meal made from cattle remains.[225]

Not only would the passage of infected feed through the chicken's

intestinal tract be unlikely to reduce prion infectivity, some of the

feed inevitably spills on the floor and mixes into the poultry litter

that's fed to cattle.[226] So in this way, the cannibalistic practice

of feeding cows to cows continues legally in the United States.

 

The industry realizes that this practice might not stand up to public

scrutiny. They understand the practice carries " certain

stigmas, " [227] " presents special consumer issues, " [228] and poses

" potential public relations problems. " [229] They seem puzzled as to

why the public so " readily accepts organically grown vegetables "

grown with composted manure, while there seems to be " apparent

reluctance on the part of the public " to accept the feeding of

poultry litter to cattle.[230] " We hope, " says one industry

executive, " common sense will prevail. " [231]

 

Writes the editor of Beef magazine, " The Public Sees It As 'Manure.'

We can call it what we want and argue its safety, feed value,

environmental attributes, etc., but outsiders still see it simply as

'chicken manure.' And, the most valid and convincing scientific

argument isn't going to counteract a gag reflex. " [Joe Roybal. Beef,

Dec 1, 1997] The industry's reaction, then, has been to silence the

issue.

 

According to Beef magazine, public relations experts within the

National Cattlemen's Beef Association warned beef producers that

discussing the issue publicly would only, " bring out more adverse

publicity. " [232] When the Kansas Livestock Association dared to bring

public attention to the issue by passing a resolution urging the

discontinuation of the practice, for example, irate producers in

neighboring states threatened a boycott of Kansas feedyards.[233]

 

The beef industry argues that this practice is safe because poultry

litter is processed to eliminate pathogens before being fed to

cattle.[234] This typically involves heating the litter to about 140

degrees Fahrenheit,[235] which is less than your typical sauna.[236].

Prions have been shown even to survive incineration[237], at

temperatures hot enough to melt lead.[238]

 

The National Cattlemen's Beef Association and 14 other industry

groups petitioned the FDA in 2003 to continue to allow the feeding of

poultry litter to cattle.[239] As one industry executive said, the

National Cattlemen's Beef Association has a history of working to

prevent " unnecessary " federal regulations from " encumbering the

cattle business. " [240]

 

In compliance with World Health Organization guidelines, Europe has

forbidden the feeding of all slaughterhouse and animal waste to

livestock[241] The American Feed Industry Association called such a

ban " a radical proposition. " [242] The American Meat Institute also

disagreed stating, " no good is accomplished by... prejudicing

segments of society against the meat industry. " [243] The reason the

industry may be so recalcitrant is that approximately 60% of the meat

and bone meal produced in the United States is of ruminant

origin.[244] But as far back as 1993, Gary Weber, a spokesperson for

the National Cattlemen's Beef Association, admitted that the industry

could indeed find economically feasible alternatives to feeding

rendered animal protein to other animals, but that the Cattlemen's

Association did not want to set a precedent of being ruled by

" activists. " [245]

 

Gary Weber was the beef industry spokesperson who appeared on the

infamous Oprah Winfrey show in 1996. Clearly alarmed and disturbed by

the fact that cows in the U.S. are fed the remains of other cattle,

Oprah swore she would never eat another burger again. After Oprah

tried to remind the audience that cows were supposed to be

herbivores, Dr. Weber defended the practice by stating, " Now keep in

mind, before you--you view the ruminant animal, the cow, as simply a

vegetarian--remember that they drink milk. " [246] Besides the obvious

absurdity of the statement, it's not even entirely accurate. In

modern agribusiness, humans drink the milk. The calves get milk

" replacer. "

 

#4. Stop Weaning Calves on Cow's Blood

 

The last key recommendation of the World Health Organization was that

" All countries should ban the use of ruminant tissues in ruminant

feed. " [247] The USDA boasts, " To stop the way the [mad cow] disease

is thought to spread, in 1997, FDA prohibited the use of most

mammalian protein in the manufacture of animal feed intended for cows

and other ruminants. " [248] The pivotal word being " most. "

 

Like all mammals, cows can only produce milk after they've had a

baby. And, most newborn calves in the United States are separated

from their mothers within 12 hours--many immediately after birth--so

that the mother's milk can be marketed for human consumption.[249]

Though many dairy farmers still wean their calves on whole milk, the

majority of dairy producers use milk replacer, which is basically a

blend of water with a source of protein and some source of fat, as a

cheaper alternative to milk.[250] Outbreaks of mad cow disease in

Denmark,[251] Germany[252] and Japan[253] have already been

tentatively tied to milk replacer which used beef tallow as a source

of fat.

 

The protein source in milk replacer is most often milk protein

(whey), but dairy farmers also suckle their calves with milk replacer

made from cattle blood protein.[254] The number one advantage given

for using blood as a protein source in milk replacer is that it is

cheaper than whey.[255] The chief disadvantage of blood-based milk

replacer, according to Jim Quigley, vice president of product

development for the Animal Protein Corporation, is simply its

" different color. " Milk replacer containing blood concentrate

typically has a " chocolate brown " color which can leave a dark

residue on the bottles, buckets and utensils used to feed the

liquid.[256] " For some producers, " Quigley remarks, " the difference

is difficult to accept at first, since the product does not look

'like milk.' " But the " Calves don't care, " he is quick to add.[257]

 

The calves may not care, but Stanley Prusiner does. When asked if the

Nobel Laureate was concerned that the U.S. was feeding cattle blood

to calves, Dr. Prusiner replied, " Yeah, I think that we shouldn't be

using anything from ruminants in cattle feed; I think that's clear. "

[258] The reason Prusiner is so concerned is that there is

experimental proof that prions can indeed be transmitted through

blood.

 

The medical director for the US Public Health Service reviewed the

blood infectivity literature and found 15 published studies showing

prion transmission through blood.[259] A sixteenth study, published

in 2002, showed that blood taken even from an asymptomatic animal

that was silently incubating BSE could still transmit the infection

via a blood transfusion.[260] Reviewing the published science, the

European Commission concluded, " There is little doubt that. humans or

animals could be exposed to the BSE agent by consuming blood

products... " [261]

 

The European Commission specifically condemned the practice of

" intraspecies recycling of ruminant blood and blood products " --the

practice of feeding cow's blood to calves.[262] Even excluding the

fact that brain emboli may pass into the trough that collects the

blood once an animal's throat is slit,[263] the report concludes, " As

far as ruminant blood is concerned, it is considered that the best

approach to protect public health at present is to assume that it

could contain low levels of infectivity. " [264] Yet calves in the U.S.

to this day are still drinking up to 3 cups of " red blood cell

protein " concentrate every day.[265]

 

The American Protein Corporation, based in Ames, Iowa, is the single

largest blood spray-dryer in the world.[266] They advertise blood

products that can even be fed " through the drinking water " to calves

and pigs[267] Indeed, the majority of pigs in the U.S. are raised in

part on spray-dried blood meal.[268] According to the National

Renderers Association, although young pigs may find spray-dried blood

meal initially unpalatable, they eventually get used to it.[269]

 

In response to public concerns, the industry formed the Spray Dried

Blood and Plasma Producers Association to defend the practice.[270]

The association was founded on the commitment to " producing safe,

high quality blood products to use in feeds for commercial livestock

and companion animals. " [271] The industry points out that blood meal

is one of the richest sources of protein available to the feed

industry and is produced using only " clean, fresh animal blood. " [272]

" We are winning this battle [for consumer confidence], " the president

of the American Feed Industry Association recently wrote, " but it

continues to be slow and precarious when it should be a

slam-dunk. " [273]

 

Conclusion

 

Since 1996, the World Health Organization has recommended that all

countries stop feeding prion infected animals to other animals, yet

the U.S. government continues to allow deer infected with chronic

wasting disease to be rendered into animal feed,[274] and the

industry continues to oppose any proposed change in the law.[275]

 

Since 1996, the World Health Organization has recommended that all

countries test their downer cattle for mad cow disease, yet the U.S.

government continues to test but a tiny fraction of this high risk

population. The beef industry calls U.S. surveillance " aggressive "

and doesn't think more testing is necessary[276]. The world's

authority on these diseases just calls it " appalling. " [277]

 

Since 1996, the World Health Organization has recommended that all

countries remove beef products containing risky organs like spinal

cord from the human food supply. The U.S. government continues to

refuse to implement such a measure, and the industry continues to

oppose it, referring to such products as nothing but " wholesome. " [278]

 

Since 1996, the World Health Organization has recommended that all

countries stop feeding risky cattle organs like brains to all

livestock. The U.S. government is considering it. The American Meat

Institute, and 14 other industry groups remain vocally opposed.[279]

 

And, Since 1996, the World Health Organization has recommended that

all countries stop feeding any remains of cows to cows, yet the U.S.

government still allows dairy farmers to feed calves gallons worth of

cow blood and fat collected at the slaughterhouse.[280] Industry

representatives continue to actively support this practice.[281]

 

In 2002, the USDA requested feedback on a number of options for

further preventive measures, including a total ban on allowing the

brains and spinal cords from downer cattle in the human food

supply.[282] The spokesperson for the American Meat Institute

explained that the meatpacking industry would take a " significant

hit " financially if the USDA enacted such a proposal.[283]

 

The American Meat Institute explained that spinal cords pose no

health risk, " because the U.S. is BSE-free. " [284] Despite grossly

inadequate surveillance for the disease, when asked if we have BSE in

U.S. cattle, the American Meat Institute in 2002 emphatically

replied, " No, BSE is a foreign animal disease. " They stressed that,

" The fact that we share no physical borders with any affected nations

has been a key means of protecting our cattle. " [285]

 

Now that mad cow disease has been discovered in North America, the

USDA should immediately enact measures to prevent human exposure by

issuing an emergency interim rule to ban products that may contain

the agent that causes mad cow disease.[286] So far, though, according

to an agency spokesperson, the USDA isn't even discussing plans to

increase testing for the disease.[287]

 

Years ago, once mad cow disease started appearing up in Europe, David

Byrne, the European Commissioner for Health and Consumer Protection,

immediately called for a comprehensive Europe-wide surveillance

program to test every cow slaughtered for human consumption over a

certain age. Commenting on the program he said, " One of the major

lessons I have learned in dealing with BSE is that the political

establishment must be fully transparent with the public on the issue.

There must be no hidden agendas. No distortions. No false assurances.

Transparency, information and open dialogue must guide our

actions. " [288] The United States could learn from Europe's experience.

 

Michael Greger, MD, is a graduate of the Cornell University School of

Agriculture and the Tufts University School of Medicine. Dr. Greger

has been publicly speaking about mad cow disease since 1993. In

1997 he was invited as an expert witness to defend Oprah Winfrey

in the infamous meat defamation trial. He has contributed to many

books and articles on the subject and continues to lecture extensively.

Dr. Greger can be contacted at 857-928-2778, or mhg1

 

Any part of this report may be reproduced subject to acknowledgment.

 

Jonathan Simms is still fighting for his life.

You can watch " Johnny's Story, " a special BBC presentation, at

<http://news.bbc.co.uk/media/video/39254000/rm/_39254221_johnnysstory_vi.ram>.

 

May 31st was Jonathan's Birthday.

 

For the list of references, please email mhg1,

or go to http://www.organicconsumers.org/madcow.htm

--

Michael Greger, M.D.

mhg1

857-928-2778