Summary
of CU '01 Letter to FSIS re Mad Cow Disease
The letter in-toto: Letter
to the Food Safety Inspection Service of the USDA regarding Mad Cow Disease
(Thu Mar 01 2001)
It's a long and fairly technical letter by CU's Michael K. Hansen,
Ph.D to the USDA's Administrator of FSIS..
The following is my stab at a concise summary- hopefully all extracts
from the letter are in quotes. I've marked stuff that interests me
in bold.
Purpose
"We would like to discuss the steps USDA is taking to prevent
mad cow disease and related transmissible spongiform encephalopathies (TSEs)
in the United States. We believe that USDA's efforts related to swine and
cattle need to be restructured and expanded in significant ways to assure
meat safety. The following represents our views on the kind of research
and monitoring that is needed."
The following follows the basic outline of the letter
Swine
-
Requests that a '79 study of pigs with a CNS illness at a packing
plant be reopened to determine if TSE was the cause. Said one pig
in the study had visible spongiform damage of brain and cited a scientist
as saying it suggested a TSE. Other pigs were noted as having similar
motive symptoms.
-
Requests more pre-mortem studies- i.e. look at packing plants for pigs
having symptoms of pig in '79 study and have inspectors observe pig at
plants while they are in motion.
-
Repeat another previous study and survey of older pigs and those with
neurological symptoms.
-
"Finally, USDA should ensure that a proper feeding experiment be done to
see if pigs can get BSE through the oral route. Experiments in the United
Kingdom have shown that pigs are susceptible to BSE. Pigs inoculated
via intracranial, intravenous and intraperitoneal routes with BSE develop
a TSE (Dawson et al., 1990). A feeding experiment is currently
underway in the UK to see if BSE can be orally transmitted to pigs; as
of March, 1997, some 6.5+ years after the start of the experiment, none
of the pigs fed BSE brain have come down with a TSE. Unfortunately,
the design of this experiment severely limits what we will learn from it...the
pigs were not fed BSE brain continuously."
-
"....there are two epidemiological studies that have linked the consumption
of pork to a human TSE, Creutzfeldt-Jakob disease (CJD). Both studies
are discussed in our comments to FDA on their proposed draft feeding rule
(copy included) so we will only summarize them here." 1/3 of
the striken had eaten brains "... there was evidence of dosage
dependency with the pork products, i.e.the more you ate the greater the
risk of contracting CJD"
-
"....a number of studies suggest that CJD may
be misdiagnosed as Alzheimer's disease or other senile dementia and
that a small percentage of the Alzheimer's cases are actually CJD."
Details:
-
A study at the University of Pittsburgh, in which autopsies were done on
54 demented patients diagnosed as having probable or possible Alzheimer's
or some other dementia (but not CJD), found 3 cases (or 5.5%) of CJD
among the 54 studied (Boller et al., 1989).
-
A Yale study found that of 46 patients diagnosed with Alzheimer's , 6 (or
13%)
were CJD at autopsy (Manuelidis and Manuelidis, 1989). Since
there are over two million cases of Alzheimer's disease currently in the
United States, if even a small percentage of them turned out to be CJD,
there could be a hidden CJD epidemic.
Cattle
-
"CU believes that USDA's BSE Surveillance program is flawed in both
design and execution. The program is based on the assumption that a
native bovine TSE does not exist in the US and that the major threat comes
from a British-style BSE. A good deal of indirect evidence, involving studies
on transmissible mink encephalopathy as well as on scrapie transmitted
to cattle, suggests that a native bovine TSE occurs in the US and may
be hiding among the "downer cow" population.
-
Discusses Transmissible mink encephalopathy (TME) Suggests
that TME may result from consumption of "downer cows." Cites a '63 simultaneous
TME outbreak on 2 farms and states:
"Suspecting a possible feed-based source of contamination, based on
the 1961 outbreak, the scientists went through the two farms' feed records.
A striking finding was that, from July through October 1962, meat "from
beef carcasses unfit for human consumption (so-called 'downer' cows)"
that came from Farm A was fed to minks on both Farms A and B. As the scientists
noted, "Since mink on both farms developed the disease almost simultaneously,
we believe this feed component has to be incriminated" (Hartsough and Burger,
1966a: 389)"
Also cites a study in '85 of another TME outbreak which, "produced
a number of lines of evidence that linked "downer" cows to TME".
Also notes an experiment which injected TME infected mink brain material
into calves - within they had "...a fatal spongiform encephalopathy. They
did not act like "mad cows" in Britain; rather they just got a bit lethargic
and fell over, i.e. they exhibited symptoms of "downer cow."
Scrapie-infested cattle studies Describes a '79 study which
inoculated cattle with scrapie to see if cattle were susceptible to it.
10 cows were injected with scrapie-infested brain homogenates and feed
it. After 2-4 years, 3 cows had the appearance of downer cattle and
did not have the symptoms of BSE. Their brains did not appear spongy
and c diagonse of scrapie could not be confirmed. In '90, after a
new test for the suspected agent responsible for scrapie, came out, remains
of the brains tested as positive. The scientist concluded that
the evidence suggested that a bovine TSE was present at a low level in
US cattle and that "downer cows" should be tested:
BSE Surveillance Program
-
"In sum, the indirect evidence from the TME studies, as well as from the
scrapie-inoculated cattle studies, points to the existence of a native
bovine TSE in downer cows in the U.S. This native BSE could arise spontaneously
in cattle; it seems unlikely that all cases are linked to scrapie"......"By
1990, even NIH (in the person of Dr. Clarence Gibbs) was calling for testing
of downer cows for the presence of the mutant prion using an immunohistochemical
probe" ..... "The same year, USDA set up an advisory
committee called the Scrapie/BSE consultants committee." .... "This
committee designed and began the BSE monitoring program done by the USDA"
-
At first, the monitoring program did not look at the brains of downer cattle
athough one committee member requested it do so. The member requested
also USDA funds to examine downer cattle and was turned down. Downers
were first included in the program in '96. "As of January 23, 1997,
some 5,342 cattle brains had been tested. Yet only a couple hundred of
the brains came from downer cows".
-
Recommends the USDA look for not only BSE, but for a native bovine TSE
which is different in physical cattle symptoms and in brain appearance.
Specifically, it recommends use of a cited immunohistochemical probe..
Also recommended focusing on The USDA could also focus, " ....on states
which make the largest use of rendered ruminant protein in their cattle
feed and that have some of the oldest cows. This would mean focusing on
the larger dairy states such as Wisconsin, California and New York.
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