GAO Documents - Links, Summaries and Snippets
From a search on 1/02/04 of the GAO Web Site



Improvements in the Animal Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention Efforts
GAO-02-183 Report, Jan '02    PDF file  (1.8 Mb).  Also available as a text tile  (137 kB) or there's a  HTML version via Google
The Mad Cow issued a press release in response to this report.
 

In addiition to the summary/comments below,  I've compiled a page with additional  snippets and comments.
There's also an earlier GAO report on feed ban inadequacies which appears below- GAO/RECD-00-255 .

A Short Summary of the Report -  with my comments in italitics:

Federal actions do not sufficiently ensure that all BSE-infected animals or products are kept out or that if BSE were found, it would be detected promptly.  Some specifics:

FDA has not acted promptly to compel firms to keep prohibited proteins out of cattle feed and to label animal feed that cannot be fed to cattle.

"FDA has reported hundreds of firms out of compliance —most often for failure to meet requirements to label feed that contained prohibited proteins or for including prohibited proteins in cattle feed.  In our analysis of individual inspection forms, we found several instances in which firms were out of compliance in repeated inspections, yet  FDA had not issued a warning letter.  We also found instances in which firms were out of compliance but had not been reinspected for a year or more —and in some cases for more than 2 years....  Five firms also voluntarily recalled mislabeled or potentially contaminated feed during 1999."   "As of November 30,2001,  FDA or states had reinspected 33 of the total of 50 firms that had been issued warning letters (2 in 1999 and 48 in 2001).  Six of the firms were still out of compliance on reinspection." ....  "According to FDA, rather than taking enforcement actions, it has emphasized educating firms subject to the feed ban about the ban ’s requirements and working with those firms to establish cooperative relationships.
(ed: Education is well and good, but, they sure seem to be way too tolerant given the number of violations and, worse still, repeat violations.  )
Because of faulty FDA data, FDA does not know the full extent of industry compliance with the feed ban.
An example: Inspection forms for firms which had the inspection field blank were counted as in compliance with the ban, however, GOA found numerous instances where this was not true.  Therefore, the data on compliance above is misleading.
Consumers Cannot Tell Which Beef Products May Contain Central Nervous System Tissue
Bone-in meat cuts, such as T-bone steaks, which are stripped directly from the animal ’s vertebrae can contain such tissue as can  products such as beef stock, beef extract  and beef flavoring.   USDA officials said that they would expect to find it in these foods.

USDA has not rigorously enforced its prohibition against the presence of central nervous system tissue in meat extracted by using the advanced meat recovery system technology.  It's found about 20% of samples tested contaminated.  When its tests found central nervous system tissue in samples, USDA did not track to ensure that the processing plants relabeled the contaminated meat products as something other than meat."   (ed: what about making the processing plants fix the problem?)

The reports notes that a FDA committe recommended banning central nervous system tissue  from all human food and the FDA said it was considering this as well as a ban on the stuff in cosmetics and over-the-counter drugs. (ed: status?)

The USDA objected to the GAO's recommendation on informing consumer by stating that labeling and warning statements should be preserved "for known hazards, which BSE is not in the United States". .(ed: Now that BSE is in the US- why hasn't the USDA required such signs/labels? )

Overly Permissive Feed Ban
" the United States has a more permissive feed ban than other countries - one that allows cattle feed to contain proteins from horses and pigs.  FDA is reviewing whether these ingredients should continue to be allowed in cattle feed.  Finally,  as in most countries that are BSE-free, including the United States, cattle brains and other central nervous system tissue can be sold as human food."   Surviellance can be improved by testing " high-risk populations, such as animals that die on farms" and noted that the curent regime only tests cattle rejected at slaugther house- not rendering plants.

The report states the US is in the minority of the countries studied in that it allows at least some mammalian protein in feed for cattle (a practice the EU urged it's members to adopt on a temporary in 2000) and that the US and Canada allowed cattle feed to contain protein from horses and pigs- with the footnote: "FDA allowed these exemptions either because scientific evidence had not shown infectivity in the protein sources or because the species involved were not known to contract BSE or other TSEs." (ed: see "silent carriers" below for info)

Other interesting info from the report:

Most vCJD victims have been young —the average age at death was 28 —and half died within 13 months from the time they first showed symptoms.

The prion hypothesis is not universally accepted.  Some scientists believe a virus or other conventional agent, as yet undetected, gives rise to TSEs.   (no ref. given in report).

A nice summary of the "feed ban"

In August 1997,  FDA banned potentially BSE-infective animal proteins in feed for cattle and other ruminants.  The feed ban prohibits the use of most animal-derived proteins in cattle feed.   It also requires that,among other things,feed and feed ingredients that contain the prohibited proteins be labeled “Do not feed to cattle or other ruminants;” firms that handle both prohibited and nonprohibited feed and feed ingredients have procedures to ensure that the two are not commingled;and firms maintain records sufficient to track feed materials through their receipt and disposition for certain periods.   The ban excludes animal blood and blood products, gelatin, plate waste, milk and milk protein, and protein derived from pigs and horses (and other equines).  Renderers, feed manufacturers and blenders, and feed distributors are subject to the ban.
(ed: it's apparenty not illegal to actually feed labeled/"banned" feed to cattle or other ruminants.)
Recent research on the ability of animals to be “silent ” carriers of TSEs from another species raises questions about the advisability of including in feed for cattle, or other ruminants, proteins from animals such as pigs and horses that are currently not thought to be susceptible to BSE and other TSEs according to researchers at the National Institutes of Health   (Journal of Virology,Vol.75,No.21 (2001),pp.10106-12)




Links to Other GAO Documents

GAO-04-259T, BIOTERRORISM: A Threat to Agriculture and the Food Supply
This 11/19/03 document is congressional testimony- it mostly references/repeats some of what's in GAO-02-183 (see above).  Here are links to the report in two formats:   PDF file  (169.3KB)   Text File  (42 kB)
I've compiled a page with relevant snippets and comments.

GAO-02-47T Food Safety and Security: Fundamental Changes Needed to Ensure Safe Food
The document is Oct '01 Senate subcommitte testimony.  The GAO concludes:

I've compiled a page with relevant snippets and comments.

GAO/RECD-00-255 FOOD SAFETY Controls Can Be Strengthened to Reduce the Risk of Disease Linked to Unsafe Animal ...
Report to Sen. Durbin, 9/00.  Details inadequacies associated with the "feed ban"- e.g. 28% of feed not labeled.  For renders': 11% not aware of BSE regulation, 17% not labeling product and 16% with no system to prevent commingling.
I've compiled a page with relevant snippets and comments.

GAO-03-96 Highlights Major Management Challenges and Program Risks: Department of Agriculture
 Hightlights 66.1KB   Text file - 88.5KB  NOTE: there's not a link to the full report (if one exists) on the GAO site
This 1/03 GAO report has some info with relevance to TSE.  It calls (again...) for a single food safety agency.   It notes (again...) that " FDA physically inspects and tests only about 1 percent of all imported foods.   It is imperative that a risk-based approach be implemented to strengthen the safety of imported animals or products that could be infected with dangerous disease agents such as bovine spongiform encephalopathy (BSE), commonly known as mad cow disease".   On the positive side, the report says the 6/02 bioterrorism act "protects against the importation of adulterated food products by generally prohibiting a product from entering the country at a port of entry if the product had already been refused admission at another port of entry" and "FDA now has the authority to temporarily hold products at ports of entry if they present a threat of serious adverse health consequences"

GAO-02-754, PUBLIC HEALTH: Blood Supply Generally Adequate Despite New  Donor Restrictions
Also available as a Text File d02754  (74.4KB) .
This 7/02 GAO report, among other things,  evaluated the potential impact of the new vCJD donor restrictions on the U.S. blood supply.
The report provides the history and background on the donor restrictions and good info in Appendix II, "Risk of vCJD Infection through Blood  Transfusion Is Unknown"   Most relevant info:  " It has not been established that vCJD is transmissible through blood, and no tests to diagnose vCJD or detect vCJD in blood have been developed. Nonetheless, laboratory experiments point to a theoretical risk of transmission of vCJD through blood.  There's also a 99 report listed below on blood supply adequacy.
I've compiled a page with relevant snippets.

RCED-00-195   FOOD SAFETY Actions Needed by USDA and FDA to Ensure That Companies Promptly Carry Out Recalls
GAO United States General Accounting Office Report to Congressional Requesters August 2000
 http://www.gao.gov/new.items/rc00195.pdf - 762.3KB - GAO Reports

OGC-97-51 Substances Prohibited From Use in Animal Food or Feed; Animal Proteins Prohibited in Ruminant Feed
This GAO  General Counsel's 1/24/97 report assess FDA's compliance with the procedural steps required by the rule.  The review indicated that FDA complied.  Includes summary of FDA's cost/benefit data and history of the FDA regs.
Also available as a HTML File - 10.6KB
 

GAO/RCED-97-102  Agricultural Inspection:Improvements Needed to Minimize Threat of Foreign Pests and Diseases 5/97
PDF File (292 kB)
This 5/97 GAO report contains nothing directly related to TSE.  The reported noted that USDA's workload had increased and USDA wan't covering points of entry for pests and diesases well enough.  The  '02 GAO Feed Ban Report: noted that additional personnel were to be provided for inspections at the borders and ports of entry.

GAO/OGC-00-4  STATUS OF OPEN RECOMMENDATIONS: Improving Operations of Federal Departments and Agencies
Not much in this 3/00 annual report on status of previous GAO recommendations.  The report on the Dept. of Agriculture starts on page 54 of the PDF file   A brief summary:

Recommends (again....) the need for a single agency to address food safety via a  uniform, risk-based inspection system and lists this as an open item with this status update:
"Furthermore, in March of 1999, the President’s Council on Food Safety wrote that it supports the National Academy of Sciences’ recommendation for a unified framework for food safety programs and a scientific risk-based approach to food safety.   In addition, to increase the flexibility and efficiency of its safety inspections, the Food Safety and Inspection Service is pilot-testing having the industry do much of the meat and poultry inspections with the Food Safety and Inspection Service’s oversight."
IMHO, the above pilot test is a step towards allowing doubious "self-regulation" industry-wide.

Reguarding the previous recommendation in GAO/RCED-98-103 that the law be changed to require all food eligible for importation (not just meat and poultry) be produced under food safety systems equivalent to ours, it is stated:  "In May of 1999, legislation was introduced in the Senate that would require all imported foods be produced under equivalent safety systems..."  (what happened to the bill...).

GAO-02-808 Foot and Mouth Disease: To Protect U.S. Livestock, USDA Must  Remain Vigilant and ...
 ... Kingdom 65 Figure 6: Disposal of Animal Carcasses by Incineration in the United  Kingdom 66 Abbreviations APHIS Animal and Plant Health Inspection Service BSE bovine  spongiform encephalopathy CCRA Canada Customs and Revenue Agency CFIA Canadian Food Inspection Agency DEFRA Department for Environment, Food and Rural Affairs FAS ...
 http://www.gao.gov/new.items/d02808.pdf - 2507.2KB - GAO Reports - BSE: 1
Text File - 248.4KB

FOOD SAFETY: Experiences of Four Countries in Consolidating Their Food Safety  Systems
GAO Report to the Chairman, Permanent  Subcommittee on Investigations, Committee on Governmental Affairs, U. S. Senate April 1999
http://www.gao.gov/archive/1999/rc99080.pdf - 139.1KB - GAO Reports - BSE: 3

HEHS-99-187R Blood Supply: Availability of Blood to Meet the Nation's  Requirements
 ... contaminated tissues from cattle infected with bovine spongiform encephalopathy (BSE)  in ‘To be eligible to donate, a person should ... herds in the United Kingdom suffered an  epidemic of BSE, which peaked in 1992 and subsequently declined as the ...
 http://161.203.16.4/paprpdf2/162782.pdf - 1467.4KB - GAO Reports - BSE: 1

GAO-02-669T; Food Safety: Continued Vigilance Needed to Ensure Safety of  School Meals
 http://www.gao.gov/new.items/d02669t.pdf - 376.0KB - GAO Reports - BSE: 1

GAO-03-929, Rulemaking: OMB's Role in Reviews of Agencies' Draft Rules and the Transparency of Those Reviews
This is 9/03 GAO reports on OMB reviews of fed. agency proposed regulations/changes.  This was apparently triggered by concerns/allegations of the Bush administration using OMB to water down regulations at the behest of contributors- a somewhat similiar situation to the Cheney energy thing.
I've not yet reviewed the entire document (it's huge...), however, snippets/my comments from the highlights are below.
Text file d03929(516 kB)   Highlights PDF  (69 kB) Summary HTML

GAO was asked to (1) describe OIRA’s review process and any changes in its policies or processes in recent years, (2) provide detailed information about rules submitted by nine health, safety, or environmental agencies that were returned, withdrawn, or changed at OIRA’s suggestion, and (3) describe how OIRA decided that certain existing rules merited high priority review.

....Underlying many of these changes is a shift in how recent OIRA administrators view the office’s role in the rulemaking process—from “counselor” to “gatekeeper.” OIRA sometimes reviews drafts of rules before they are formally submitted, and OIRA has said it can have its greatest influence on agencies’ rules during this informal review period. However, OIRA contends that agencies need only document the changes made to rules during what are sometimes very brief formal review periods.  (ed. i.e. changes requested by OBM and the reasons for those changes are not required to be documented)

Because about 400 rules were changed, returned, or withdrawn during the 1-year period that GAO examined, the review focused on 85 rules from the nine health, safety, or environmental agencies with five or more such rules. OIRA significantly affected 25 of those 85 rules. The Environmental Protection Agency’s rules were most often significantly changed, and almost all of the returned rules were from the Department of Transportation. OIRA’s suggestions appeared to have at least some effect on almost all of the 25 rules’ potential costs and benefits or the agencies’ estimates of those costs and benefits.  Outside parties contacted OIRA before or during its formal review regarding 11 of the 25 rules that OIRA significantly affected.   In 7 of these 11 cases, at least some of OIRA’s recommendations were similar to those of the outside parties, but we could not determine whether those contacts influenced OIRA’s actions.  The agencies’ docket files did not always provide clear and complete documentation of the changes made during OIRA’s review or at OIRA’s suggestion, as required by the executive order. However, some agencies clearly documented these changes, sometimes including changes suggested during OIRA’s informal reviews.  OIRA did not publicly disclose how it determined that 23 of the 71 rules nominated by the public for change or elimination in 2001 merited high priority review....  The Mercatus Center at George Mason University made most of the nominations overall....   OIRA’s 2002 nomination and review process was different from the 2001 process in several respects (e.g., broader request for reforms, more responses from more commentors, prioritization of the suggestions being made by the agencies, and clearer discussion of process and criteria).

GAO recommends that the OMB Director build on recent improvements that have been made in the transparency of the OIRA review process. In particular, GAO recommends that agencies be instructed to document substantive changes made at OIRA’s suggestion to draft rules submitted for review whenever they occur,  not just changes that OIRA recommended during formal reviews. OMB said the factual foundations of our report were well grounded but disagreed with most of our recommendations, saying that the report had not demonstrated the need or desirability of changing the agency’s existing level of transparency.


GAO-03-780, COUNTRY-OF- ORIGIN LABELING: Opportunities for USDA and  Industry to Implement  Challenging Aspects of the New Law
A 8/03 GAO report to Congressional Requesters  Not much on in this report on TSE other than noting Japan's request after the Canadian BSE case.
Highlights(71 kB)  Text file d03780 147 kB

More Hits (I think....)



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