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USDA Misleading American Public about Beef Safety

December 24, 2003 by Michael Greger, M.D.
It is not surprising that the U.S. has mad cow disease given our flaunting of World Health Organization recommendations.[1] What is surprising, however, is that we actually found a case given the inadequacy of our surveillance program, a level of testing that Nobel laureate Stanley Prusiner, probably the world's leading expert on these diseases, calls simply "appalling."[2] Europe and Japan follow World Health Organization guidelines[3] and test every downer cow for mad cow disease[4]; the U.S. has tested less than 2% of downers over the last decade.[5] Most of the U.S. downer cows, too sick or injured to even walk, end up on our dinner plates.[6]

In Canada, authorities were able to reassure the public that at least the downer cow they discovered infected with BSE--Bovine Spongiform Encephalopathy, or mad cow disease--was excluded from the human food chain and only rendered into animal feed.[7] U.S. officials don't seem to be able to offer the same reassurance, as the mad cow we discovered may very well have been ground into hamburger.[8] How then, can the USDA and the beef industry insist that the American beef supply is still safe? They argue that the infectious prions that cause the disease are only found in the brain and nervous tissue, not the muscles, not the meat.

For example, on NBC's Today, USDA Secretary Veneman insisted "the fact of the matter is that all scientific evidence would show, based upon what we know about this disease, that muscle cuts -- that is, the meat of the animal itself -- should not cause any risk to human health. "[9] The National Cattlemen's Beef Association echoed "Consumers should continue to eat beef with confidence. All scientific studies show that the BSE infectious agent has never been found in beef muscle meat or milk and U.S. beef remains safe to eat. "[10] This can be viewed as misleading and irresponsible on two counts.

First, American do eat bovine central nervous system tissue. The United States General Accounting Office (GAO) is the investigative watchdog arm of Congress. In 2002, the GAO released their report on the weaknesses present in the U.S. defense against mad cow disease. Quoting from that congressional report, "In terms of the public health risk, consumers do not always know when foods and other products they use may contain central nervous system tissue... Many edible products, such as beef stock, beef extract, and beef flavoring, are frequently made by boiling the skeletal remains (including the vertebral column) of the carcass..."[12] According to the consumer advocacy organization Center for Science in the Public Interest, spinal cord contamination may also be found in U.S. hot dogs, hamburgers, pizza toppings, and taco fillings.[13] In fact, a 2002 USDA survey showed that approximately 35 percent of high risk meat products tested positive for central nervous system tissues.[14]

The GAO report continues: "In light of the experiences in Japan and other countries that were thought to be BSE free, we believe that it would be prudent for USDA to consider taking some action to inform consumers when products may contain central nervous system or other tissue that could pose a risk if taken from a BSE-infected animal. This effort would allow American consumers to make more informed choices about the products they consume."[15] The USDA, however, did not follow those recommendations, deciding such foods need not be labeled.[16]

Even if Americans just stick to steak, they may not be shielded from risk. The "T" in a T-bone steak is a vertebra from the animal's spinal column, and as such may contain a section of the actual spinal cord. Other potentially contaminated cuts include porterhouse, standing rib roast, prime rib with bone, bone-in rib steak, and (if they contain bone) chuck blade roast and loin. These cuts may include spinal cord tissue and/or so-called dorsal root ganglia, swellings of nerve roots coming into the meat from the spinal cord which have been proven to be infectious as well.[17] This concern has led the FDA to consider banning the incorporation of "plate waste" from restaurants into cattle feed.[18] The American Feed Industry Association defends the current exemption of plate scrapings from the 1997 feed regulations: "How can you tell the consumer 'Hey, you've just eaten a T-bone steak and it's fine for you, but you can't feed it to animals'? "[19]

Even boneless cuts may not be risk-free, though. In the slaughterhouse, the bovine carcass is typically split in half down the middle with a band saw, sawing right through the spinal column. This has been shown to aerosolize the spinal cord and contaminate the surrounding meat.[20] A study in Europe found contamination with spinal cord material on 100% of the split carcasses examined.[21] Similar contamination of meat derived from cattle cheeks can occur from brain tissue, if the cheek meat is not removed before the skull is fragmented or split.[22] The World Health Organization has pointed out that American beef can be contaminated with brain and spinal cord tissue in another way as well.[23]

Except for Islamic halal and Jewish kosher slaughter (which involve slitting the cow's throat while the animal is still conscious), cattle slaughtered in the United States are first stunned unconscious with an impact to the head before being bled to death. Medical science has known for over 60 years that people suffering head trauma can end up with bits of brain embolized into their bloodstream; so Texas A&M researchers wondered if fragments of brain could be found within the bodies of cattle stunned for slaughter. They checked and reportedly exclaimed, "Oh, boy did we find it."[24] They even found a 14 cm piece of brain in one cow's lung. They concluded, "It is likely that prion proteins are found throughout the bodies of animals stunned for slaughter."[25]

There are different types of stunning devices, however, which likely have different levels of risk associated with them. The Texas A&M study was published in 1996 using the prevailing method at the time, pneumatic-powered air injection stunning.[26] The device is placed in the middle of the animal's forehead and fired, shooting a 4 inch bolt through the skull and injecting compressed air into the cranial vault which scrambles the brain tissue. The high pressure air not only "produces a smearing of the head of the animal with liquefied brain,"[27] but has been shown over and over to blow brain back into the circulatory system, scattering whole plugs of brain into a number of organs[28] and smaller brain bits likely into the muscle meat as well.[29]

Although this method of stunning has been used in the United States for over 20 years,[30] the meat industry, to their credit, has been phasing out these particularly risky air injection-type stunners. The Deputy Director of Public Citizen argues that this industry initiative should be given the force of federal regulation and banned,[31] as they have been throughout Europe.[32]

The stunning devices that remain in widespread use drive similar bolts through the skull of the animal, but without air injection.[33] Operators then may or may not pith the animals by sticking a rod into the stun hole to further agitate the deeper brain structures to reduce or eliminate reflex kicking during shackling of the hind limbs.[34] Even without pithing, which has been shown to be risky, these stunners currently in use in the U.S. today may still force brain into the bloodstream of some of these animals.[35-38]

In one experiment, for example, researchers applied a marker onto the stunner bolt. The marker was later detected within the muscle meat of the stunned animal. They conclude: "This study demonstrates that material present in... the CNS of cattle during commercial captive bolt stunning may become widely dispersed across the many animate and inanimate elements of the slaughter-dressing environment and within derived carcasses including meat entering the human food chain."[39] Even non-penetrative "mushroom-headed" stunners which just rely on concussive force to the skull to render the animal unconscious may not be risk free. People in automobile accidents with non-invasive head trauma can still end up with brain embolization,[40] and these bolts move at over 200 miles per hour.[41] The researchers at Texas A&M conclude, "Reason dictates that any method of stunning to the head will result in the likelihood of brain emboli in the lungs or, indeed, other parts of the body."[42]

And, finally, even if consumers of American beef just stick to boneless cuts from ritually slaughtered animals who just happen to have had their spinal columns safely removed, the muscle meat itself may be infected with prions. It is unconscionable that the USDA and the beef industry continue to insist that the deadly prions aren't found in muscle meat.[43] In 2002, Stanley Prusiner, the scientist who won the Nobel Prize in Medicine for his discovery of prions, proved in mice, at least, that muscle cells themselves were capable of forming prions.[44] He describes the levels of prions in muscle as "quite high," and describes the studies relied upon by the Cattlemen's Association as "extraordinarily inadequate."[45] Follow-up studies in Germany published May, 2003 confirm Prusiner's findings, showing that an animal who is orally infected may indeed end up with prions contaminating muscles throughout their body.[46] And just last month, published in the New England Journal of Medicine, Swiss scientists found prions in the muscles of human CJD victims on autopsy. Eight out of the 32 muscle samples turned up positive for the deadly prions.[47]

The discovery of a case of mad cow disease in the U.S. highlights how ineffective current safeguards are in North America. The explosive spread of mad cow disease in Europe has been blamed on the cannibalistic practice of feeding slaughterhouse waste to livestock.[48] Both Canada[49] and the United States[50] banned the feeding of the muscles and bones of most animals to cows and sheep back in 1997, but unlike Europe left gaping loopholes in the law. For example, blood is currently exempted from the Canadian[51] and the U.S.[52] feed bans. You can still feed calves cow's blood collected at the slaughterhouse. In modern factory farming practice calves may be removed from their mothers immediately after birth, so the calves are fed milk replacer, which is often supplemented with protein rich cow serum. Weaned calves and young pigs also may have cattle blood sprayed directly on their feed to save money on feed costs.[53] For more information on this and other risky agriculture practices please see http://organicconsumers.org/madcow/GregerBSE.cfm

And the Canadian[54] and U.S. feed bans[55] also allows the feeding of pigs and horses to cows. Cattle remains can be rendered down and fed to pigs, for example, and then the pig remains can be fed back to cattle.[56] Or rendered cattle remains can be fed to chickens and then the chicken litter, or manure, can be legally fed back to the cows.[57] So the fact that according to the USDA the most infectious tissues of the U.S. mad cow case, the brain, spinal cord, and intestines, "were removed from this animal and sent to rendering" is not necessarily reassuring.[58]

D. Carleton Gajdusek was also awarded the Nobel Prize in Medicine for his work on mad cow-like diseases.[59] He was quoted on Dateline NBC as saying, "it's got to be in the pigs as well as the cattle. It's got to be passing through the chickens."[60] Dr. Paul Brown, medical director for the US Public Health Service, believes that pigs and poultry could indeed be harboring mad cow disease and passing it on to humans, adding that pigs are especially sensitive to the disease. "It's speculation," he says, "but I am perfectly serious."[61]

The 2002 General Accounting Office report concluded: "BSE may be silently incubating somewhere in the United States. If that is the case, then FDA 's failure to enforce the feed ban may already have placed U.S. herds and, in turn, the human food supply at risk. FDA has no clear enforcement strategy for dealing with firms that do not obey the feed ban... Moreover, FDA has been using inaccurate, incomplete, and unreliable data to track and oversee feed ban compliance."[62] The report can be downloaded at http://www.gao.gov/new.items/d02183.pdf

Despite these shortcomings, Secretary Veneman and Washington's governor both assured the public that they were still having beef for Christmas, reminiscent of the 1990 fiasco in which the British agriculture minister appeared on TV urging his 4-year-old daughter to eat a hamburger.[63] Four years later, young people in Britain were dying from an invariably fatal neurogenerative disease called variant Creutzfeldt-Jakob Disease--the human equivalent of mad cow disease--which they contracted through the consumption of infected beef.[64] With an incubation period up to decades long, no one knows how high the final human death toll will be.

[1] http://organicconsumers.org/madcow/GregerBSE.cfm
[2] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted by Angie Coiro. .
[3] World Health Organization Consultation on Public Health Issues Related to Bovine Spongiform Encephalopathy and the Emergence of a New Variant of Creutzfeldt-Jakob Disease. MMWR 45(14);295-6, 303. 12 April 1996.
[4] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted by Angie Coiro. .
[5] Even assuming 195,000 downers a year and that every single of the tests in the surveillance program's history was performed on downer cattle, (48,000 in 13 years)/(195,000 x 13 years) is less than 2%.
[6] A Review of USDA Slaughterhouse Records for Downed Animals (U.S. District 65 from January, 1999 to June, 2001) Farm Sanctuary, October 2001. http://www.nodowners.org/downedanimals.pdf
[7] "Critics say U.S. needs to do more to protect against mad cow." The Journal News (New York) 29 May 2003.
[8] "Mad Cow Meat May Have Been Eaten, Official Says." Reuters. December 23, 2003.
[9] "First US Case Of Mad Cow Disease Found In WA." The Bulletin's Frontrunner. December 24, 2003.
[10] National Cattlemen's Beef Association Statement. December 23, 2003.
[11]
[12] United States General Accounting Office. GAO Report to Congressional Requesters. January 2002 MAD COW DISEASE: Improvements in the Animal Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention Efforts. GAO-02-183. http://www.gao.gov/new.items/d02183.pdf
[13] "Health and Consumer Groups Urge USDA to Keep Cattle Spinal Cord Tissue Out of Processed Meat" Center for Science in the Public Interest News Release. 10 August 2001.
[14] USDA, Food Safety and Inspection Service, USDA Begins Sampling Program for Advanced Meat Recovery Systems, News Release.3 March 2002.
[15] United States General Accounting Office. GAO Report to Congressional Requesters. January 2002 MAD COW DISEASE: Improvements in the Animal Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention Efforts. GAO-02-183. http://www.gao.gov/new.items/d02183.pdf
[16] USDA Response To GAO Recommendations on BSE Prevention. Release No. F.S. 0071.02.
[17] Center for Science in the Public Interest. Nutrition Health Letter. June, 2001.
[18] FDA Veterinarian Newsletter. Volume XVII, No. VI. November/December 2002.
[19] USA Today, June 10, 2003.
[20] Harvard Center for Risk Analysis. Risk Analysis of Transmissible Spongiform Encephalopathies in Cattle and the Potential for Entry of the Etiologic Agent(s) Into the U.S. Food Supply . 2001. /madcow_report.pdf>.
[21] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE Headquarters, Paris, 11-14 June 2001.
[22] USDA Food Safety and Inspection Service. Current Thinking on Measures that Could be Implemented to Minimize Human Exposure to Materials that Could Potentially Contain the Bovine Spongiform Encephalopathy Agent. 15 January 2002.
[23] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE Headquarters, Paris, 11-14 June 2001.
[24] Reuters 29 August 1996.
[25] Lancet Vol 348 August 31, 1996.
[26] Lancet Vol 348 August 31, 1996.
[27] European Commission Health & Consumer Protection Directorate-General Scientific Opinion on Stunning Methods and BSE Risks. January 2002.
[28] Transfusion, Vol. 41, No. 11, 1325, November 2001.
[29] European Commission Health & Consumer Protection Directorate-General Scientific Opinion on Stunning Methods and BSE Risks. January 2002.
[30] Transfusion, Vol. 41, No. 11, 1325, November 2001.
[31] Testimony of Peter Lurie, MD, MPH Deputy Director Public Citizen's Health Research Group Before the Consumer Affairs, Foreign Commerce and Tourism Subcommittee Senate Commerce, Science and Transportation Committee. 4 April 2001.
[32] Regulation (EC)No 999/2001 of the European Parliament and of the Council. Laying down rules for the prevention, control and eradication of certain transmissible spongiform encephalopathies. 22 May 2001.
[33] European Commission Health & Consumer Protection Directorate-General Scientific Opinion on Stunning Methods and BSE Risks. January 2002.
[34] European Commission Scientific Report on Stunning Methods And BSE Risks (The Risk of Dissemination of Brain Particles Into the Blood And Carcass When Applying Certain Stunning Methods. December 2001).
[35] Berliner und M�nchener Tier�rztliche Wochenschrift 2002 Jan-Feb; 115(1-2): 1-5.
[36] Joint WHO/FAO/OIE Technical Consultation on BSE. OIE Headquarters, Paris, 11-14 June 2001.
[37] European Commission Health & Consumer Protection Directorate-General. Scientific Steering Committee Opinion on the Safety of Ruminant Blood with Respect to Risks. 14 April 2000.
[38] European Commission Scientific Report On Stunning Methods and BSE Risks (The Risk of Dissemination of Brain Particles into the Blood and Carcass when Applying Certain Stunning Methods. December 2001).
[39] Applied and Environmental Microbiology. 2002 Feb; 68(2): 791-8.
[40] Letters to the Editor. The Lancet Vol 348 September 14, 1996.
[41] European Commission Health & Consumer Protection Directorate-General. Scientific Steering Committee Opinion on the Safety of Ruminant Blood with Respect to Risks. 14 April 2000.
[42] Letters to the Editor. The Lancet Vol 348 September 14, 1996.
[43] National Cattlemen's Beef Association news release. 21 May 2003. .
[44] Proceedings of the National Academy of Sciences. 2002 Mar 19;99(6):3812-7.
[45] Mad Cow Disease in Canada. May 23, 2003 9:00am KQED Forum hosted by Angie Coiro. .
[46] European Molecular Biology Organization Reports 4, 5 (2003), 530.
[47] New England Journal of Medicine 349(2003):1812.
[48] Kimberlin, R. H. "Human Spongiform Encephalopathies and BSE." Medical Laboratory Sciences 49 (1992): 216-217.
[49] Canadian Food Inspection Agency BSE Fact Sheet. May 2003 P0091E-00. http://www.inspection.gc.ca/english/anima/heasan/disemala/bseesb/bseesbe.shtml
[50] Food and Drug Administration 2000 CFR Title 21, Volume 6, Chapter 1, Part 589. http://www.access.gpo.gov/nara/cfr/waisidx_00/21cfr589_00.html
[51] Canadian Food Inspection Agency, Regulations: Food for Ruminants, Livestock and Poultry (Part XIV), "Prohibited Materials"
[52] Food and Drug Administration 2000 CFR Title 21, Volume 6, Chapter 1, Part 589. http://www.access.gpo.gov/nara/cfr/waisidx_00/21cfr589_00.html
[53] International Center for Technology Assessment. Citizen Petition Before The United States Food And Drug Administration. 1/9/03. http://www.icta.org/legal/madcow1.htm
[54] Canadian Food Inspection Agency, Regulations: Food for Ruminants, Livestock and Poultry (Part XIV), "Prohibited Materials"
[55] Food and Drug Administration 2000 CFR Title 21, Volume 6, Chapter 1, Part 589. http://www.access.gpo.gov/nara/cfr/waisidx_00/21cfr589_00.html
[56] Public Citizen. Letter to the FDA and USDA RE: BSE. 21 April 2001. http://www.citizen.org/cmep/foodsafety/gsfc/articles.cfm?ID=1562
[57] Food and Drug Administration Sec. 685.100 Recycled Animal Waste (CPG 7126.34)
[58] FDCH Political Transcripts December 23, 2003
[59] Unconventional viruses and the origin and disappearance of kuru. 13 December 1976. http://www.nobel.se/medicine/laureates/1976/gajdusek-lecture.html
[60] NBC Dateline 14 March 1997.
[61] Pearce, Fred. "BSE May Lurk in Pigs and Chickens." New Scientist 6 April 1996: 5.
[62] United States General Accounting Office. GAO Report to Congressional Requesters. January 2002 MAD COW DISEASE: Improvements in the Animal Feed Ban and Other Regulatory Areas Would Strengthen U.S. Prevention Efforts. GAO-02-183. http://www.gao.gov/new.items/d02183.pdf
[63] Chicago Tribune 21 May 21 2003.
[64] "Ministers Hostile to Advice on BSE." New Scientist 30 March 1996: 4.

   
         

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