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February 11, 2003
Docket No. 01-068-1
Regulatory Analysis and Development
PPD, APHIS
Station 3C71
4700 River Road Unit 118
Riverdale, MD 20737-1231
To Whom It May Concern,
I am writing on behalf of Farm Sanctuary regarding
Docket Number 01-068-1 and APHIS’s proposed rulemaking,
which seeks to minimize the risk of BSE spreading in
the United States. Our interest and concern in this
matter lies primarily with the handling and disposition
of nonambulatory livestock.
We concur with key issues stated in the Federal Register
notice, which was published on January 21, 2003. We
agree:
“...surveillance data from European countries
in which BSE has been detected indicate that downer
cattle have a greater incidence of BSE.”
“If BSE enters the United States, downer cattle
testing programs are likely first to reveal it.”
We strongly agree with the veracity of the following
assessment, and we are extremely concerned by it:
“Downer cattle presented for slaughter that pass
antemortem inspecting may be slaughtered, and if passed
on postmortem inspection, the meat and meat products
from such cattle can be used for human food. However,
surveillance for BSE in Europe has shown that downer
cattle infected with BSE often cannot be found by looking
for the typical clinical signs associated with BSE,
because the signs of BSE often cannot be differentiated
from the signs of many other diseases and conditions
affecting downer cattle. Thus, if BSE were present in
the United States, downer cattle infected with BSE could
potentially be offered for slaughter and, if the clinical
signs of the disease were not detected, pass antemortem
inspection. These cattle could then be slaughtered for
human or animal food...”
The Federal Register notice properly acknowledges the
increasing difficulty faced by livestock producers seeking
to dispose of dead animals. In the past, renderers paid
farmers for animal carcasses, but now, renderers charge
to dispose of them. The Federal Register concludes,
“This causes producers to seek cheaper means of
disposal.” We are gravely concerned that one way
producers are likely to “dispose” of dying,
downer cattle is to send them to USDA slaughterhouses
where they are being used for human food.
The likelihood of downed cattle entering USDA slaughterhouses
is greatest in large dairy producing states since the
dairy industry has long been recognized as the primary
source of downed animals. California is the nation’s
number one dairy state, and it is therefore notable
that the California Department of Food and Agriculture
(CDFA) has found a 20 % decline in the number of dead
stock collected by renderers in the state. CDFA reports
that 686,434 dead stock were rendered in California
between 1999-2000, while 553,974 were rendered between
and 2000-2001. How many of the 100,000 plus livestock
removed from the rendering process during this time
in California found their way into USDA slaughterhouses
and into the human food supply?
In 1993, Dr. Richard Marsh of the University of Wisconsin,
Madison published research findings about outbreaks
of transmissible mink encephalopathy (TME). Marsh believed
the TME outbreaks resulted when meat from downed cows
was fed to minks. He concluded that his findings “suggest
the presence of a BSE-like disease in the United States”.
Given that nonambulatory livestock are most likely
to be infected with BSE, that USDA is unable to adequately
detect BSE in cattle inspected at USDA slaughterhouses,
that published scientific evidence suggests we may have
a form of BSE in the U.S., and given that with increasing
controls on the rendering industry there may an increased
incentive to send dying, downer cows to slaughter, we
urge that USDA slaughterhouses immediately stop accepting
and approving meat from downed animals for human food.
Thank you for your concern and attention to this matter.
Sincerely,
Gene Baur (formerly Bauston) , President
Farm Sanctuary, Inc.
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