To: Commissioner
U.S. Food and Drug Administration
Dockets Management Branch
Room 1-23
12420 Parklawn Drive
Rockville, MD 20857

From: Lester Friedlander, DVM

Subject: Docket Number 98P-0151/CP1 Disallowing the use of non-ambulatory animals for human food.

I urge the Food and Drug Administration to act on Docket Number 98P-0151/CP1 and stop the slaughter of downed animals for the human food supply. I was a USDA, FSIS Veterinarian from January, 1985 to April, 1995.

I was the Supervisory Veterinary Medical Officer (SVMO) for the largest culled cow slaughter in the United States. I have literally seen thousands of non-ambulatory cattle (Downers), being slaughtered, which in my professional judgement should have been condemned.

Due to the very liberal policy on non-ambulatory animals and the ineffective inspection process, they are generally passed to be slaughtered. USDA-FSIS does not use any scientific or microbiological testing to determine their true condition.

If these downers pass for human food they are ground up for the federal school lunch program or often sold to fast food restaurants. In either event our children's health is jeopardized.

The USDA claims that animals with Central Nervous System (CNS) are kept out of the food supply. As somebody who has trained close to one hundred (100) veterinarians in the USDA and received the veterinary trainer of the year award, I can tell you that CNS animals are not carefully examined nor prevented from entering the food supply.

In the absence of a clear policy prohibiting the use of downer animals for human food, I am concerned that CNS and other potentially transmissible diseases will be passed on to human consumers.