Letter from dairy industy veterinarian supporting effort to ban downed animal slaughter

July 10, 2003

Amy Sandra Lee
Legislative Assistant
Congressman Gary Ackerman (NY-05)
2243 RHOB
Washington DC 20515
202-225-2601

Dear Congressman Ackerman and Ms Lee:

This letter is in support of your effort to amend the Agriculture Appropriations bill requiring that no funds are used by the USDA to test downed animals for human consumption. The amendment would preclude USDA inspectors from inspecting non-ambulatory animals at the slaughter house and therefore would effectively stop downed animals from entering the USDA-inspected food chain.

The downer animal issue has two main parts: food safety and animal welfare. Dr. John Maas and Dr. C. Stull at the University of California, Davis, presented data at the Livestock Conservation Institute 1996 annual meeting from a survey of downer dairy cattle and showed that 14% of the down cows were Salmonella positive at the slaughter house. One cow with Salmonella septicemia was passed by the inspector and entered the food chain, exemplifying the difficulty of properly identifying animals with zoonotic pathogens by antemortem inspection.

An emerging issue is the risk of prion diseases such as Bovine Spongiform Encephalitis (BSE) entering the human food chain. Downer cattle are considered by many to be a risk group for having BSE. In fact, the surveillance of BSE in the US is centered on testing tissues from down cattle sent to slaughter. It is argued that the BSE surveillance program could be compromised by preventing down cattle from going to slaughter inspection, but the fact is that only a small percentage of down cows are tested for BSE: in California, only about 5% of the down cattle are tested for BSE. If down cattle are a potential risk of having BSE then we certainly do not want them entering slaughter houses. More appropriate surveillance for BSE could be obtained by focusing on ambulatory cattle with central nervous system signs.

The welfare problems with non-ambulatory livestock involve the dragging of large animals during transport and the lack of feed and water for most of the down cattle. The American Veterinary Medical Association (AVMA) and the American Association of Bovine Practitioners (AABP) have both recently adopted position statements on non-ambulatory livestock that recommend euthanizing downer livestock that are not likely to recover rather than subjecting the moribund animals to dragging and transport to a slaughter house. The position statements are included as an addendum to this letter.

An indication of consumer attitudes regarding the downer livestock issue can be found in the fact that the USDA does not allow downer cattle included in USDA food programs and restaurants like McDonald's will buy beef only from slaughter houses that do not accept down cattle.

Dr. Pamella Hullinger, a veterinarian with the California Department of Agriculture, has looked into the economics of down cows. She developed information from federally inspected cull cow slaughter plants in California in 1996 to 1997 and determined that, at best, dairy farmers gained $28.70 per down cow sold to slaughter. It is clearly in the best interest of the livestock farmer to market ambulatory cattle rather than down cattle. Experience has shown that when markets stop accepting down cattle, the farmers get better at preventing severe injuries and begin selling cattle before they become so sick that they cannot walk.

In summary:

· Down cattle present increased risk to food security;
· Down livestock are often treated inhumanely;
· Only a small percentage of down cattle are tested for BSE and downer cattle may not be the most appropriate group of animals for a BSE surveillance program;
· If one accepts that down cattle have a higher risk of having BSE then prudent food security would preclude down cattle from going to slaughter houses;
· The economic return for selling down cows is far less than preventing them;
· Humane euthanasia of downer livestock is the goal of the AVMA and the AABP;
· The USDA and restaurants like McDonald's recognize that consumers do not want down cattle dragged to market and entering the food chain;
· Legislation preventing down cows from being marketed is in the best interest of the livestock and consumers.

Thank you for initiating this important legislation.

Sincerely,

James P. Reynolds DVM, MPVM