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U.S. Violates World Health Organization Guidelines for Mad
Cow Disease:
A Comparison of North American and European Safeguards
Updated July 15, 2003 by Michael Greger, M.D. for the Organic
Consumers Association
The National Cattlemen's Beef Association describes government
and industry efforts to safeguard the American public from mad cow
disease as "swift," "decisive" and "aggressive."[1] The US Secretary
of Agriculture adds "diligent,"[2] "vigilant" and "strong."[3] The
world's authority on these diseases disagrees.
Dr. Stanley Prusiner is the scientist who won the Nobel Prize in
Medicine for his discovery of prions, the infectious agents thought
to cause bovine spongiform encephalopathy (BSE), or mad cow disease.
The word Dr. Prusiner uses to describe the efforts of the
U.S. government
and the cattle industry is "terrible."[4] What are these "stringent
protective measures"[5] that the Cattlemen's Association is talking
about, and how do they compare to global standards and
internationally
recognized guidelines?
In 1996, in response to the revelation that young people in Britain
were dying from variant Creutzfeldt Jakob Disease (vCJD), the human
equivalent of mad cow disease, the World Health Organization (WHO)
issued seven "Recommendations." Numbers 5-7 were observations and/or
recommendations for further research. The first four
recommendations,
however, were concrete proscriptions to reduce the likelihood of
mad cow disease spreading to human populations.[6] To this day,
the United States government continues to violate each and every
one of these four guidelines.
#1. Stop Feeding Infected Animals to Other Animals
The number one recommendation of the World Health Organization
was that no "part or product" of any animal showing signs
of a transmissible
spongiform encephalopathy (TSE), or mad cow-like disease, should
be fed to any animal.[7] "All countries," the guideline reads, "must
ensure the slaughter and safe disposal of TSE-affected animals so
that TSE infectivity cannot enter any food chain."[8] Yet, in the
U.S., it remains legal to feed deer and elk known to be infected
with a transmissible spongiform encephalopathy called
chronic wasting
disease to livestock such as pigs and chickens.[9]
Although science has yet to investigate whether pigs and chickens
are susceptible to "mad deer" prions, there is a concern that even
if these animals don't develop clinical symptoms of the disease,
they could become so-called "silent carriers." Dr. Richard Race
is a Senior Investigator with the National Institutes of Health.[10]
In 2001, he published a landmark paper showing that even species
thought to be resistant to particular strains of prions
could invisibly
harbor the disease and pass it on to other animals.[11] He also
found that these deadly prions were somehow able to adapt to the
new species, becoming even more lethal and replicating faster and
faster.[12]
At a 2002 symposium on chronic wasting disease, Dr. Race expressed
concern that U.S. cattle could be invisibly harboring
chronic wasting
disease and passing it on to humans.[13] The reason Dr. Race is
so concerned is because chronic wasting disease seems unique in
that it's the only prion disease thought to be spread by casual
contact[14] between deer through exposure to, or exchange of, bodily
fluids such as saliva.[15] And, the best available research suggests
that CWD prions can infect humans as well, perhaps even as readily
as mad cow disease can.[16] Dr. Race wonders if people could become
silent carriers as well.[17] And, "If these people are subclinical
carriers," Race asked, "do they represent a threat to
other people?"[18]
All transmissible spongiform encephalopathies are
invariably fatal.[19]
Consumer advocates argue that these prions should not be allowed
to enter into the food chain.[20]
In May 2003, the Food and Drug Administration finally drafted up
proposed voluntary "suggestions" for the rendering
industry, recommending
that deer and elk infected with chronic wasting disease, or at high
risk for the disease, be excluded from animal feed.[21] However,
even if this proposal is enacted, it represents only non-binding,
non-enforceable "guidance" recommendations for the industry. The
FDA made these same kinds of "guidance" recommendations to
pharmaceutical
companies over a decade ago, discouraging the use of bovine-derived
materials from countries with mad cow disease in manufacturing their
vaccines,[22] only to learn 7 years later that major pharmaceutical
manufacturers simply ignored the guidelines.[23]
Europe's Scientific Steering Committee met in 2003 and agreed that
the United States should comply with the World Health Organization
guidelines and ban the feeding of animals infected with chronic
wasting disease to other animals.[24] The United States seems to
remain the only country that knowingly allows prion infected animals
to be fed to other animals, including those destined for the dinner
plate.
#2. All Countries Need to Establish Adequate Testing and
Surveillance
The World Health Organization's second guideline was for
all countries
to establish adequate testing and surveillance for mad cow disease
according to the standards set down by the Office International
des Epizooties (OIE), World Animal Health Organization.[25] The
beef industry and the USDA claim that the level of U.S. testing
"far exceeds" these international testing standards.[26] If one
goes to the USDA website and clicks on "for the latest info on BSE
Surveillance," for example, one can read that "OIE recommends a
surveillance level of 433 samples per year."[27] And that, in 2002
alone, the U.S. tested almost 20,000 cattle for the disease.[28]
But if one reads the actual recommendations,[29] one can see that
the USDA isn't telling the whole story.
The oft-cited "433" figure[30-32] is indeed found in
Article 3.8.4.2.
of the OIE's International Animal Health Code.[33] But it
just represents
the required minimum number of cattle showing suspicious signs that
should be examined each year.[34] For examples, these are cows that
show "excitability," or "persistent kicking when milked."[35] The
Animal Health Code then directly goes on to recommend, in Article
3.8.4.3, that "Cattle that have died or have been killed for reasons
other than routine slaughter (including 'fallen' stock and emergency
slaughter) should be examined."[36] This is where the United States
(and Canada) fall seriously short.
The combination of these two populations, "fallen stock
and emergency
slaughter cattle," is essentially equivalent to the U.S.
nonambulatory,
or "downer" cattle population.[37] Every year, an
estimated 195,000[38]
to a million[39] cattle collapse in the U.S. for largely unknown
reasons and are too sick or injured to rise.[40] Even though these
downed animals are not even fit enough to stand, an investigation
of USDA slaughterhouse records showed that most of them are still
ruled fit enough for human consumption.[41] Quoting from a USDA
document released in 2002, "Thus, if BSE were present in the U.S.,
downer cattle infected with BSE could potentially be offered for
slaughter and, if the clinical signs of the disease were
not detected,
pass ante-mortem inspection. These cattle could then be slaughtered
for human food."[42]
Based on findings in Europe,[43] and evidence of at least a rare
form of mad cow disease already striking downer cows in
the U.S.,[44]
downer cattle are considered to be a particularly high
risk population.
The OIE recommends they be tested for mad cow disease.[45] Over
the past ten or so years, though, the USDA has tested less than
2% of the downer cattle in United States.[46] And, those tests were
almost exclusively limited to animals that were sent to
slaughter.[47]
The U.S. tests even fewer of the downer cattle on farms and ranches
that never make it to the slaughterhouse, considered the single
highest risk cattle population in the United States.[48] These dead,
dying or downed cattle can still then be fed to other livestock.[49]
It's no wonder that Dr. Prusiner, the world's expert on
prion disease,
describes the number of tests done by USDA as "appalling."[50]
When asked what level of testing in the U.S. he'd be comfortable
with, Prusiner replied, ""Well, I'd like to see every downer cattle,
every fallen cow tested. That's a beginning. And then after that,
at some point, I'd like to see every cow tested, just as they do
in Japan. Every single cow is being tested in Japan."[51] In Europe,
100% of all adult downer cattle are tested,[52] as well as 100%
of all healthy cows over a certain age that are slaughtered for
human consumption.[53] If the animal isn't tested, then by law,
the animal must be destroyed.[54] July, 2003, an amendment
was brought before the House that would have banned the sale downed
animals for human food in the United States. The amendment lost by
two votes.[292]
The United States and Europe have similar cattle populations,[55]
yet Europe tests almost a million cattle every month.[56] France,
which has only a fraction of the U.S. cattle population, tests more
cattle in a single week then the U.S. has tested in a decade.[57]
According to Europe's latest annual report, Europe is testing cattle
at a rate of almost two thousand times that of the United
States.[58]
Yes, the beef industry argues, but they have the disease, and we
don't.
The beef industry's position is an illustration of
circular reasoning:
We don't rigorously test, because we haven't found any cases.[59]
In the Summer of 2000, the Scientific Steering Committee of the
European Union, an internationally recognized group of BSE experts,
conducted and published elaborate risk assessments for a
wide variety
of countries.[60] They concluded that the risk status of a country
like Austria ("Unlikely, but not excluded"),[61] was identical to
that of the United States.[62] This didn't stop Austria, though,
from learning from the rest of Europe's example and testing all
cattle slaughtered for human consumption over a certain age.[63]
Though they too declared their country "BSE-free,"[64] within months
of initiating their testing program they discovered their first
case.[65]
The meat industry, however, opposes more testing.[66] Dan Murphy,
the spokesperson for the American Meat Institute,
responded to criticism
by stating, "Further testing would cost taxpayers more money, could
slow production and would yield no benefits."[67] He reiterated,
"It's a matter of asking the question, 'Where would the benefit
be?'"[68] I'm sure Don Simms has an answer for Mr. Murphy.
His teenage
son lies twitching in a hospital bed in Belfast. Jonathan Simms,
once healthy, strong and athletic, is in a coma, wasting away on
the verge of death from mad cow disease, like so many dozens of
teens before him.[69]
Dan Murphy argues that the U.S. government "already tests
the animals
that are at risk."[70] He likened expanding the testing program
to a larger number of animals "to testing elementary students for
Alzheimer's disease."[71] Or "like testing children for
breast cancer," the President of the American Feed Industry
Association adds. "It simply makes no sense."[289] But again, the
United States tests only
a minuscule percentage of the animals at most risk--the
downer cattle.[72]
Beyond high risk populations, though, Dan Murphy is correct when
he implies that the U.S. cattle population is younger than that
in Britain. Less than half of American dairy cows make it past their
fourth birthday, before being retired into hamburger meat.[73] In
fact the majority of U.S. cattle are slaughtered before they reach
age two.[74] While this may mean that the prion load in an infected
animal may be less at slaughter (since prions accumulate with age),
it also means mad cow disease may be harder to detect in the United
States.[75]
On that fated Oprah show, the spokesperson for the
National Cattlemen's
Beef Industry assured consumers that no animal could ever enter
a U.S. slaughterhouse displaying BSE symptoms.[76] As the European
Commission's risk assessment of the U.S. points out, though, the
"young age at slaughter makes it unlikely that fully
developed clinical
cases would occur (and could be detected)..."[77] Younger cattle
could be infected and infectious, but be slaughtered for
human consumption
before they started showing symptoms.[78] In fact, that first case
of mad cow disease in Austria was detected in a cow who presented
no clinical signs.[79] The only reason that the infected Austrian
cow was prevented from entering the human food supply is because,
even though they had no recorded cases[80] and even though
the country
was deemed as low risk as the United States,[81] Austria instituted
a surveillance program that tested every cow slaughtered for human
food over 30 months of age.[82] The chief reason that the present
mad cow surveillance program has not confirmed cases in the U.S.
could be because the surveillance program is inadequate.[83]
Another country that was ruled just as unlikely as the
United States
to have mad cow disease was Canada.[84] Saying Canada has mad cow
disease is not far from saying the United States does, because the
cattle industries of both countries are fully integrated across
an open border.[85] Every year, the U.S. imports over a million
head of cattle[86] and billions of pounds of beef from Canada.[87]
How can the U.S. still call itself BSE-free when over
three quarters[88]
of Canadian cattle exports end up in the United States? Mad cow
disease has been detected in North America.
Dr. Bruno Oesch of Zurich University recently told the BBC that
US consumers may well have been eating infected beef for some time
now.[89] The New Scientist, a weekly British science digest, reports
that, based on the Canadian case, it is "likely" that the mad cow
disease is also present in the United States.[90] So the question
of whether or not the U.S. had in the past been meeting
international
testing standards for BSE-free countries may now be moot. Now that
mad cow disease has been found in a downer cow in North America,
is the USDA drafting plans to at least step up its surveillance
of downer cattle? According to a spokesperson for the USDA, "at
the moment, no changes [in the U.S. testing program] are
being discussed."[91]
#3. Stop Feeding Bovine Brains, Eyes, Spinal Cords or Intestines
to People or Livestock
The third key recommendation of the World Health Organization is
that "Countries should not permit tissues that are likely to contain
the BSE agent to enter any food chain, human or
animal."[92] Basically,
this means excluding cattle brains, eyes, spinal cord and intestine
(from small intestine to rectum) from the human food supply, and
from all animal feed.[93] Unfortunately, the U.S. still feeds those
potentially risky tissues to people, pigs, pets and poultry.
High risk tissues in human food
Although beef brains, guts, eyes and spinal cords are available
to consumers as "variety meats," they are labeled as such
and therefore
represent only a small fraction of the American public's exposure
to these organs.[94] People are more likely to consume potentially
infectious tissues such as spinal cord disguised within all-American
favorites, like hot dogs and hamburgers.
After a cow is slaughtered and the standard cuts of beef removed,
one is left with a bloody skeleton with a few scraps of meat still
attached. To recover any last shreds of meat, the bones, prebroken
or whole, may be placed in a giant vice-like device that crushes
the carcass into bone "cakes."[95] Out through a sieve at the bottom
runs a "batter-like"[96] paste of "spread-like consistency" referred
to as mechanically separated meat.[97] The potentially
highly infectious
spinal cord and fluid may be forced out of the backbone and spewed
in the final product.[98] Mechanically separated beef has been "used
as a meat ingredient in the formulation of quality meat
food products"[99]
in the United States since the 1970's.[100] Examples of
such "quality
meat food products" include hot dogs, sausages and burgers.[101]
By law, hot dogs can contain up to 20% of this
mechanically separated
beef.[102]
Although food containing mechanically separated beef must
be labeled
as such, there are no labels on food in restaurants.[103] So people
could be exposed to spinal cord tissue in hot dogs,
sausages, hamburgers,
and ground meat products when dining out.[104] Although
Europe heeded
the World Health Organization's warnings and banned such
meat recovery
systems years ago, these devices remain one of the best
opportunities
for prion-infected tissues to enter the human food supply in North
America.[105]
In 1994, meat processors began using a new technology,
called advanced
meat recovery (AMR), to help "increase yields and
profitability."[106]
These systems also extrude meat from the remains of the carcass
under pressure, but without crushing the bones.[107] The American
Meat Institute describes the process: "Just as fruit processors
use machines to remove fruit from peels thoroughly and efficiently,
meat companies use similar equipment to remove meat from some hard
to trim bones."[108]
The end-product varies from a ground beef-like texture to
the consistency
of thick tomato sauce.[109] Prior to 1994, only cattle skeletal
muscle, tongue, diaphragm, heart, and esophagus could be labeled
as beef.[110] But by the end of that year, the USDA had already
amended the definition of "meat" to include the product of advanced
meat recovery machinery.[111] This meant that unlike mechanically
separated meat, AMR meat was considered 100% beef and
could be labeled
as such.[112] With no special labeling requirements, adoption of
AMR machinery spread rapidly throughout the industry,
largely replacing
mechanical separation equipment.[113]
Today, the majority of cattle are now processed using AMR.[114]
Over twenty thousand tons of AMR beef is produced every year in
the U.S., valued at over $100 million.[115] AMR beef typically ends
up as a hidden ingredient in hamburgers, hot dogs, sausages, and
beef jerky, as well as part of ground beef in meatballs,
pizza toppings
and taco fillings.[116] The danger, once again, is that if
the spinal
cord isn't removed before entering one of these machines, it is
bound to be incorporated into the meat that is produced.[117]
Companies are supposed to remove the animals' brains and spinal
cords before processing the carcasses through the AMR machinery,
but getting out all of the spinal cord can be challenging.
"It requires
special tools and skills," says Glenn Schmidt, a meat scientist
at Colorado State University. "The workers have to reach down to
the neck region of the carcass to remove the spinal cord by scraping
or suction, and sometimes they don't get all of it."[118]
In 1997, the consumer advocacy organization Public Citizen obtained
USDA inspection records through the Freedom of Information
Act showing
that a significant percentage of AMR samples were turning
up contaminated
with central nervous system (CNS) tissue (brain or spinal
cord).[119]
Instead of simply requiring that spinal columns be removed from
carcasses before being placed in advanced meat recovery systems,
the USDA responded by merely directing its inspectors to continue
testing samples of AMR meat for the presence of central nervous
tissue.[120]
Despite their promise to initiate testing, the USDA took fewer
than 60 samples over the next 3 years, yet still found spinal cord
in a number of them.[121] The first major study of AMR meat was
published in 2001.[122] Colorado State University researchers found
that "well over 50%" of the samples of AMR beef from neck bones
were contaminated with CNS tissue.[122] Then they went to 7 major
suppliers of large fast food chains across the country to sample
hamburger patties. Six out of seven suppliers had detectable CNS
tissue in their burgers.[123]
The USDA again responded only with promises to do more
testing.[124]
The results of the USDA's tests were made public in
2002.[125] Eighty-eight
percent of the meat processors (30 out of 34) were producing AMR
beef which contained unacceptable nervous tissue, and almost all
of the samples (96.5%) contained bone marrow,[126] which may also
be infectious.[127]
In 2001, the World Health Organization, in consultation with the
World Animal Health Organization and the Food and
Agriculture Organization
of the United Nations, reiterated the need for countries to remove
and destroy all tissues proven capable of transmitting mad
cow disease,
such as spinal cord.[128] And, the only way to guarantee that AMR
beef, or mechanically separated "beef," is free of spinal cord is
to require meat processors to remove the entire spinal column before
sending cattle carcasses through their machinery.[129] So that year,
the consumer advocacy group Center for Science in the
Public Interest
(CSPI) petitioned the USDA to do just that.[130] The petition was
supported by the American Public Health Association, the Consumer
Federation of America, the Government Accountability Project, the
National Consumers League, and Safe Tables Our Priority.[131]
The petition was opposed by the National Cattlemen's Beef
Association,[132]
the National Renderers Association,[133] the National Meat
Association,[134],
the Pork Producers Council, the sheep industry, the milk producers,
the Turkey Federation, and eight other industry trade groups.[135]
After all, about 50 percent of AMR meat comes from the neck bones
and spine which contain the spinal cord.[136] U.S. meat industry
analysts claim that any public health measure to remove these bones
would simply be too costly for the industry.[137]
The meat industry has invested at least $40 million in AMR machines
since their introduction in 1994, some of which that can process
9,000 lbs. of bones per hour.[138] Industry analysts place the final
figure of complying with any proposed USDA regulation that bans
neck bones and backbones at close to $200 million dollars.[138]
The European Commission considers the removal of cattle brains,
eyes, spinal cord and intestines from the human food supply as "the
single biggest contribution that can be made to reducing the risk
to humans."[139] Rather than learning from the outbreak in Europe
though, the U.S. livestock industry seems to oppose even the most
minimal tightening of U.S. feed regulations.[140]
The meat industry argues that voluntary compliance is enough.[141]
Seven years of testing by USDA inspectors, however, has demonstrated
otherwise.[142] This same inability to rely on industry efforts
was discovered in Britain. British meat processors also weren't
able to completely remove the spinal cord, so the law was changed
to simply remove the entire spine prior to processing.[143]
However, here in the United States, the USDA continues to allow
tissues in the American beef supply which are so
potentially dangerous
that the Food and Drug Administration has excluded them from cattle
feed.[144] As CSPI's Director of Food Safety put it, "U.S. cattle
aren't allowed to eat cattle spinal cord - and neither
should people,"
especially children--AMR beef is still allowed in the
National School
Lunch Program.[145] Thanks to CSPI,[146] at least AMR beef from
downer cattle is now excluded from the school lunch program.[147]
And, for years the government has excluded mechanically separated
meat from baby food, but only because the product might mottle an
infant's teeth as a result of increased fluoride intake[148] from
all the crushed bone particles that get extruded into the
paste.[149]
And, 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.[150] 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.[151] 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.[152] This
concern has led the FDA to consider banning the incorporation of
"plate waste" from restaurants into cattle feed.[290] The American
Feed Industry Associations's Rex Runyon 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'? "[291]
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.[153] A study in Europe found contamination with spinal cord
material on 100% of the split carcasses examined.[154]
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.[155] The World Health Organization has pointed out that
American beef can be contaminated with brain and spinal cord tissue
in another way as well.[156]
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."[158] They even found a 14 cm
piece of brain in one cow's lung.[159] They concluded, "It is likely
that prion proteins are found throughout the bodies of
animals stunned
for slaughter."[160]
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.[161] 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,"[162] 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[163] and smaller brain bits likely into
the muscle
meat as well.[164]
Although this method of stunning has been used in the United States
for over 20 years,[165] 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,[166]
as they have been throughout Europe.[167]
The stunning devices that remain in widespread use drive similar
bolts through the skull of the animal, but without air
injection.[168]
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.[169] 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.[170-173]
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."[174] 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,[175]
and these bolts move at over 200 miles per hour.[176] 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."[177]
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. The National Cattlemen's Beef
Association continues to assure consumers that beef is safe because
the deadly prions aren't found in muscle meat.[178] Even putting
aside contamination issues, it seems they are simply behind the
times. In 2002, Stanley Prusiner, the Nobel laureate who discovered
prions, proved in mice, at least, that muscle cells themselves were
capable of forming prions.[179] 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."[180]
Follow-up studies in Germany published May, 2003 confirm Prusiner's
findings, showing that an animal who are orally infected may indeed
end up with prions contaminating muscles throughout their body.[181]
This newly discovered muscle infectivity highlights how little
we know about these diseases. For example, the American
Meat Institute
released a fact sheet on BSE stressing that while the new variant
of Creutzfeldt Jakob Disease (vCJD) was known to be caused by eating
infected cattle parts, the more common classic form of CJD, the
so-called "sporadic" form, had nothing to do with mad cow disease.
The November 2002 fact sheet emphatically stated, "There
is absolutely
no evidence to suggest that CJD is caused by any food, including
beef.[182] But by the next month, December 2002, there was
evidence.[183]
The surprising new finding linking mad cow disease with classic
CJD has been used to explain the rising numbers of those stricken
with the classic form of CJD in Europe.[184] We don't the incidence
of this fatal disease in North America, because the disease isn't
tracked here like it is in Europe.[185] We do know though, that
when researchers have actually gone back and looked at the brains
of presumed Alzheimer's deaths--where Alzheimer's was indicated
on the death certificate--anywhere from between
3%[186-187] to 25%[188-190]
had actually died of Creutzfeldt Jakob Disease. According to the
CDC, Alzheimer's Disease is now the 8th leading cause of death in
the United States,[191] affecting as many as 4 million
Americans.[192]
Despite the fact that an unknown number of Americans are already
dying from this disease, the beef industry continues to ignore the
evidence.[193]
The uncertainties inherent to this mysterious class of diseases
make it even more important for the U.S. to follow the directives
of the World Health Organization, and the lead of affected countries
around the world, to implement concrete, practical
measures to safeguard
the American public.
High risk tissues in animal feed
In another direct violation of the World Health
Organization recommendations
and international standards,[194] the tissues with the
highest potential
for risk, cattle brains and spinal cord, are rendered directly into
animal feed that continues to be fed legally to pigs[195]
and chickens[196]
in North America.[197-198] The major concern in feeding rendered
cattle remains to other animals is that the cattle remains
may directly,
or indirectly, find their way back into cattle feed, which could
potentially spark a British style outbreak of mad cow disease.
In the United States, slaughterhouse waste from cattle is rendered,
or melted down, into "meat and bone meal" which is used in animal
feed, to help "animals grow bigger and faster."[199] Over 18 million
pounds of meat and bone meal are produced every day in the United
States.[200] Up until May 20th, 2003, the U.S. imported an extra
100,000 lbs. from Canada every day as well.[201] While rendering
can destroy conventional pathogens like viruses and bacteria, none
of the rendering methods used in the U.S.[202] or Canada[203] have
been shown to significantly destroy prion infectivity.
Almost all fattening beef cattle, all dairy calves and all adult
dairy cows raised conventionally are fed meat and bone meal in the
United States.[204] In fact, conventional dairy cows eat about a
pound of meat and bone every day in North America.[205-206] Since
the partial 1997 FDA feed ban, however, this meat and bone meal
is not supposed to come from ruminants--other cattle, sheep or deer.
Unfortunately, these regulations have been poorly enforced. In 2001,
the Food and Drug Administration published the results of a national
survey of rendering plants and feed mills. Up to a quarter of the
plants were found in violation of the 1997 feed regulations years
after the so-called "ban" went into effect.[207]
Ruminant meat and bone meal, even derived from downer cattle too
sick to walk or stand, can still be sold in North America.
As pointed
out by Dr. Michael Hansen from the Consumers Union, "All they said
is that you've got to label it, 'Do not feed to cattle and other
ruminants.'[208] Farmers can walk in a feed store and still buy
it. Nobody asks, 'Are you feeding it to cattle or pigs?'"[209] As
tough as it is to enforce the feed-labeling compliance
among renderers
and feed mills, it's virtually impossible to effectively monitor
America's thousands of livestock producers.
Even in Britain, the country most affected by mad cow disease,
inspections showed that it was impossible to enforce the feed ban.
If ruminant bone meal was available, and it was cheap,
British farmers
continued to illegally feed it to their cattle. The U.K. even had
to ban the use of mammalian meat and bone meal as
agricultural fertilizer
to keep it out of the stores.[210] Meanwhile in the United States,
violations of the 1997 feed regulations continue to this day.[211]
Even with 100% compliance with the feed regulations,
however, cattle
remains are still legally fed to pigs, for example, which have been
found to be susceptible to BSE prions.[212] Then the pig remains
can be fed back to cattle.[213] Or cattle remains can be fed to
chickens, and then the poultry litter can be fed back to cows.[214]
In these ways, prions may be indirectly cycled back into cattle
feed.
Poultry litter is the mixture of excrement, spilled feed, dirt,
feathers, etc. that gets scooped from the floors of poultry sheds
every year.[215] Because poultry litter can be as much as eight
times cheaper than alfalfa,[216] the cattle industry feeds
an estimated
one million tons of poultry litter to cattle every
year.[217] Although
excrement from other animals is fed to livestock in the
U.S., chicken
droppings are considered more nutritious for cows, compared to hog
feces or cattle dung.[218] A thousand chickens can make enough waste
to feed a growing calf year round.[219]
Although a single cow can eat as much as 3 tons of poultry waste
a year,[220] the manure in the feed does not seem to affect the
taste of the milk or the meat.[221] Taste panels have found little
difference in the tenderness, juiciness and flavor of beef made
from steers fed up to 50% poultry litter. In fact, beef made from
steers fed bird droppings may be even more juicy and tender.[222]
Cows are typically not fed more than 80% litter, since it's not
as palatable[223] and may not fully meet protein and
energy needs.[224]
Under the 1997 feed regulations, the FDA specifically allowed the
feeding of chicken litter to cattle to continue, even if
the chickens
had just been fed meat and bone meal made from cattle remains.[225]
Not only would the passage of infected feed through the chicken's
intestinal tract be unlikely to reduce prion infectivity, some of
the feed inevitably spills on the floor and mixes into the poultry
litter that's fed to cattle.[226] So in this way, the cannibalistic
practice of feeding cows to cows continues legally in the United
States.
The industry realizes that this practice might not stand up to
public scrutiny. They understand the practice carries
"certain stigmas,"[227]
"presents special consumer issues,"[228] and poses "potential public
relations problems."[229] They seem puzzled as to why the public
so "readily accepts organically grown vegetables" grown
with composted
manure, while there seems to be "apparent reluctance on the part
of the public" to accept the feeding of poultry litter to
cattle.[230]
"We hope," says one industry executive, "common sense will
prevail."[231]
Writes the editor of Beef magazine, "The Public Sees It
As 'Manure.'
We can call it what we want and argue its safety, feed
value, environmental
attributes, etc., but outsiders still see it simply as 'chicken
manure.' And, the most valid and convincing scientific argument
isn't going to counteract a gag reflex."[Joe Roybal. Beef, Dec 1,
1997] The industry's reaction, then, has been to silence the issue.
According to Beef magazine, public relations experts within the
National Cattlemen's Beef Association warned beef producers that
discussing the issue publicly would only, "bring out more adverse
publicity."[232] When the Kansas Livestock Association dared to
bring public attention to the issue by passing a resolution urging
the discontinuation of the practice, for example, irate producers
in neighboring states threatened a boycott of Kansas feedyards.[233]
The beef industry argues that this practice is safe because poultry
litter is processed to eliminate pathogens before being
fed to cattle.[234]
This typically involves heating the litter to about 140 degrees
Fahrenheit,[235] which is less than your typical sauna.[236]. Prions
have been shown even to survive incineration[237], at temperatures
hot enough to melt lead.[238]
The National Cattlemen's Beef Association and 14 other industry
groups petitioned the FDA in 2003 to continue to allow the feeding
of poultry litter to cattle.[239] As one industry executive said,
the National Cattlemen's Beef Association has a history of working
to prevent "unnecessary" federal regulations from "encumbering the
cattle business."[240]
In compliance with World Health Organization guidelines, Europe
has forbidden the feeding of all slaughterhouse and animal waste
to livestock[241] The American Feed Industry Association called
such a ban "a radical proposition."[242] The American Meat Institute
also disagreed stating, "no good is accomplished by... prejudicing
segments of society against the meat industry."[243] The reason
the industry may be so recalcitrant is that approximately 60% of
the meat and bone meal produced in the United States is of ruminant
origin.[244] But as far back as 1993, Gary Weber, a spokesperson
for the National Cattlemen's Beef Association, admitted that the
industry could indeed find economically feasible alternatives to
feeding rendered animal protein to other animals, but that
the Cattlemen's
Association did not want to set a precedent of being ruled
by "activists."[245]
Gary Weber was the beef industry spokesperson who appeared on the
infamous Oprah Winfrey show in 1996. Clearly alarmed and disturbed
by the fact that cows in the U.S. are fed the remains of
other cattle,
Oprah swore she would never eat another burger again. After Oprah
tried to remind the audience that cows were supposed to be
herbivores,
Dr. Weber defended the practice by stating, "Now keep in
mind, before
you--you view the ruminant animal, the cow, as simply a
vegetarian--remember
that they drink milk."[246] Besides the obvious absurdity of the
statement, it's not even entirely accurate. In modern agribusiness,
humans drink the milk. The calves get milk "replacer."
#4. Stop Weaning Calves on Cow's Blood
The last key recommendation of the World Health Organization was
that "All countries should ban the use of ruminant tissues
in ruminant
feed."[247] The USDA boasts, "To stop the way the [mad cow] disease
is thought to spread, in 1997, FDA prohibited the use of
most mammalian
protein in the manufacture of animal feed intended for cows and
other ruminants."[248] The pivotal word being "most."
Like all mammals, cows can only produce milk after they've had
a baby. And, most newborn calves in the United States are separated
from their mothers within 12 hours--many immediately after birth--so
that the mother's milk can be marketed for human consumption.[249]
Though many dairy farmers still wean their calves on whole milk,
the majority of dairy producers use milk replacer, which
is basically
a blend of water with a source of protein and some source of fat,
as a cheaper alternative to milk.[250] Outbreaks of mad cow disease
in Denmark,[251] Germany[252] and Japan[253] have already
been tentatively
tied to milk replacer which used beef tallow as a source of fat.
The protein source in milk replacer is most often milk protein
(whey), but dairy farmers also suckle their calves with
milk replacer
made from cattle blood protein.[254] The number one advantage given
for using blood as a protein source in milk replacer is that it
is cheaper than whey.[255] The chief disadvantage of blood-based
milk replacer, according to Jim Quigley, vice president of product
development for the Animal Protein Corporation, is simply
its "different
color." Milk replacer containing blood concentrate typically has
a "chocolate brown" color which can leave a dark residue on the
bottles, buckets and utensils used to feed the liquid.[256] "For
some producers," Quigley remarks, "the difference is difficult to
accept at first, since the product does not look 'like milk.'" But
the "Calves don't care," he is quick to add.[257]
The calves may not care, but Stanley Prusiner does. When asked
if the Nobel Laureate was concerned that the U.S. was feeding cattle
blood to calves, Dr. Prusiner replied, "Yeah, I think that
we shouldn't
be using anything from ruminants in cattle feed; I think that's
clear." [258] The reason Prusiner is so concerned is that there
is experimental proof that prions can indeed be transmitted through
blood.
The medical director for the US Public Health Service reviewed
the blood infectivity literature and found 15 published studies
showing prion transmission through blood.[259] A sixteenth study,
published in 2002, showed that blood taken even from an asymptomatic
animal that was silently incubating BSE could still transmit the
infection via a blood transfusion.[260] Reviewing the published
science, the European Commission concluded, "There is little doubt
that. humans or animals could be exposed to the BSE agent
by consuming
blood products..."[261]
The European Commission specifically condemned the practice of
"intraspecies recycling of ruminant blood and blood products"--the
practice of feeding cow's blood to calves.[262] Even excluding the
fact that brain emboli may pass into the trough that collects the
blood once an animal's throat is slit,[263] the report concludes,
"As far as ruminant blood is concerned, it is considered that the
best approach to protect public health at present is to assume that
it could contain low levels of infectivity."[264] Yet calves in
the U.S. to this day are still drinking up to 3 cups of "red blood
cell protein" concentrate every day.[265]
The American Protein Corporation, based in Ames, Iowa, is
the single
largest blood spray-dryer in the world.[266] They advertise blood
products that can even be fed "through the drinking water" to calves
and pigs[267] Indeed, the majority of pigs in the U.S. are raised
in part on spray-dried blood meal.[268] According to the National
Renderers Association, although young pigs may find spray-dried
blood meal initially unpalatable, they eventually get used
to it.[269]
In response to public concerns, the industry formed the Spray Dried
Blood and Plasma Producers Association to defend the practice.[270]
The association was founded on the commitment to "producing safe,
high quality blood products to use in feeds for commercial livestock
and companion animals."[271] The industry points out that blood
meal is one of the richest sources of protein available to the feed
industry and is produced using only "clean, fresh animal
blood."[272]
"We are winning this battle [for consumer confidence],"
the president
of the American Feed Industry Association recently wrote, "but it
continues to be slow and precarious when it should be a
slam-dunk."[273]
Conclusion
Since 1996, the World Health Organization has recommended that
all countries stop feeding prion infected animals to other animals,
yet the U.S. government continues to allow deer infected
with chronic
wasting disease to be rendered into animal feed,[274] and
the industry
continues to oppose any proposed change in the law.[275]
Since 1996, the World Health Organization has recommended that
all countries test their downer cattle for mad cow disease, yet
the U.S. government continues to test but a tiny fraction of this
high risk population. The beef industry calls U.S. surveillance
"aggressive" and doesn't think more testing is necessary[276]. The
world's authority on these diseases just calls it "appalling."[277]
Since 1996, the World Health Organization has recommended that
all countries remove beef products containing risky organs like
spinal cord from the human food supply. The U.S.
government continues
to refuse to implement such a measure, and the industry continues
to oppose it, referring to such products as nothing but
"wholesome."[278]
Since 1996, the World Health Organization has recommended that
all countries stop feeding risky cattle organs like brains to all
livestock. The U.S. government is considering it. The American Meat
Institute, and 14 other industry groups remain vocally opposed.[279]
And, Since 1996, the World Health Organization has recommended
that all countries stop feeding any remains of cows to cows, yet
the U.S. government still allows dairy farmers to feed
calves gallons
worth of cow blood and fat collected at the slaughterhouse.[280]
Industry representatives continue to actively support this
practice.[281]
In 2002, the USDA requested feedback on a number of options for
further preventive measures, including a total ban on allowing the
brains and spinal cords from downer cattle in the human
food supply.[282]
The spokesperson for the American Meat Institute explained that
the meatpacking industry would take a "significant hit" financially
if the USDA enacted such a proposal.[283]
The American Meat Institute explained that spinal cords pose no
health risk, "because the U.S. is BSE-free."[284] Despite grossly
inadequate surveillance for the disease, when asked if we have BSE
in U.S. cattle, the American Meat Institute in 2002 emphatically
replied, "No, BSE is a foreign animal disease." They stressed that,
"The fact that we share no physical borders with any
affected nations
has been a key means of protecting our cattle."[285]
Now that mad cow disease has been discovered in North America,
the USDA should immediately enact measures to prevent human exposure
by issuing an emergency interim rule to ban products that
may contain
the agent that causes mad cow disease.[286] So far,
though, according
to an agency spokesperson, the USDA isn't even discussing plans
to increase testing for the disease.[287]
Years ago, once mad cow disease started appearing up in Europe,
David Byrne, the European Commissioner for Health and
Consumer Protection,
immediately called for a comprehensive Europe-wide surveillance
program to test every cow slaughtered for human consumption over
a certain age. Commenting on the program he said, "One of the major
lessons I have learned in dealing with BSE is that the political
establishment must be fully transparent with the public on
the issue.
There must be no hidden agendas. No distortions. No false
assurances.
Transparency, information and open dialogue must guide our
actions."[288]
The United States could learn from Europe's experience.
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