February 2012 Update on Feed Enforcement Activities to Limit the Spread of  BSE 
 February 2, 2012 
To help prevent the establishment and amplification of Bovine Spongiform  Encephalopathy (BSE) through feed in the United States, the Food and Drug  Administration (FDA) implemented a final rule that prohibits the use of most  mammalian protein in feeds for ruminant animals. This rule, Title 21 Part  589.2000 of the Code of Federal Regulations, here called the Ruminant Feed Ban,  became effective on August 4, 1997. 
A second rule, Title 21 Part 589.2001 of the Code of Federal Regulations,  here called the Enhanced Feed Ban, became effective on April 27, 2009. This rule  prohibits the use of certain cattle-derived materials in all animal feed. The  BSE inspection report form has been revised and is being used for determining  compliance with both the ruminant feed ban and the enhanced feed ban. The  inspection results summarized below reflect the compliance status for both  rules. 
The following is an update on FDA enforcement activities regarding the  ruminant feed ban. FDA's Center for Veterinary Medicine (CVM) has summarized  results of those inspections that have been entered into FDA's inspection  database as of January 28, 2012. As of January 28, 2012, FDA had received over  93,000 inspection reports since 1997. Approximately 73% of these inspections  have been conducted by State feed control officials, with the remainder  conducted by FDA officials. 
Inspections conducted by FDA or State investigators are classified to  reflect the compliance status at the time of the inspection based upon the  objectionable conditions documented. These inspection conclusions are reported  as Official Action Indicated (OAI), Voluntary Action Indicated (VAI), or No  Action Indicated (NAI). 
An OAI inspection classification occurs when significant objectionable  conditions or practices were found and regulatory sanctions are warranted in  order to address the establishment's lack of compliance with the regulation. An  example of an OAI inspection classification would be findings of manufacturing  procedures insufficient to ensure that ruminant feed is not contaminated with  prohibited material. Inspections classified with OAI violations will be promptly  re-inspected following the regulatory sanctions to determine whether adequate  corrective actions have been implemented. 
A VAI inspection classification occurs when objectionable conditions or  practices were found that do not meet the threshold of regulatory significance,  but do warrant advisory actions to inform the establishment of findings that  should be voluntarily corrected. Inspections classified with VAI violations are  more technical violations of the Ruminant Feed Ban. These include provisions  such as minor recordkeeping lapses and conditions involving non-ruminant feeds.  
An NAI inspection classification occurs when no objectionable conditions or  practices were found during the inspection or the significance of the documented  objectionable conditions found does not justify further actions. A firm’s  compliance status and whether the firm handles prohibited material is based on  its most recent inspection. 
The results to date are reported here both by “segment of industry” and “in  total”. NOTE – A single firm can operate as more than one firm type. As a  result, the categories of the different industry segments are not mutually  exclusive. 
RENDERERS 
 These firms are the first to handle and process (i.e., render) animal  proteins and to send these processed materials to feed mills and/or protein  blenders for use as a feed ingredient. 
Number of active firms inspected – 279 
Number of active firms handling materials prohibited from use in ruminant  feed – 152 (54% of those active firms inspected) 
Of the 152 active firms handling prohibited materials, their most recent  inspection revealed that: 
2 firms (1.3%) were classified as OAI 
9 firms (5.9%) were classified as VAI 
LICENSED FEED MILLS 
FDA licenses these feed mills to produce medicated feed products. The  license is required to manufacture and distribute feed using certain potent drug  products, usually those requiring some pre-slaughter withdrawal time. This  licensing has nothing to do with handling prohibited materials under the feed  ban regulation. A medicated feed license from FDA is not required to handle  materials prohibited under the Ruminant Feed Ban. 
Number of active firms inspected – 1,046 
Number of active firms handling materials prohibited from use in ruminant  feed – 459 (44% of those active firms inspected) 
Of the 459 active firms handling prohibited materials, their most recent  inspection revealed that: 
0 firms (0%) were classified as OAI 
10 firms (2.2%) were classified as VAI 
FEED MILLS NOT LICENSED BY FDA 
These feed mills are not licensed by the FDA to produce medicated feeds.  
Number of active firms inspected – 5,304 
Number of active firms handling materials prohibited from use in ruminant  feed – 2,751 (52% of those active firms inspected) 
Of the 2,751 active firms handling prohibited materials, their most recent  inspection revealed that: 
0 firms (0%) were classified as OAI 
30 firms (1.1%) were classified as VAI 
PROTEIN BLENDERS 
These firms blend rendered animal protein for the purpose of producing  quality feed ingredients that will be used by feed mills. 
Number of active firms inspected – 284 
Number of active firms handling materials prohibited from use in ruminant  feed – 129 (45% of those active firms inspected) 
Of the 129 active firms handling prohibited materials, their most recent  inspection revealed that: 
0 firms (0%) were classified as OAI 
2 firm (1.6%) was classified as VAI 
RENDERERS, FEED MILLS, AND PROTEIN BLENDERS MANUFACTURING WITH PROHIBITED  MATERIAL 
This category includes only those firms that actually use prohibited  material to manufacture, process, or blend animal feed or feed ingredients.  
Total number of active renderers, feed mills, and protein blenders  inspected – 6,696 
Number of active renderers, feed mills, and protein blenders processing  with prohibited materials – 471 (7.0%) 
Of the 471 active renderers, feed mills, and protein blenders processing  with prohibited materials, their most recent inspection revealed that: 
 2 firms (0.4%) were classified as OAI 
18 firms (3.8%) were classified as VAI 
OTHER FIRMS INSPECTED 
Examples of such firms include ruminant feeders, on-farm mixers, pet food  manufacturers, animal feed salvagers, distributors, retailers, and animal feed  transporters. 
Number of active firms inspected – 28,217 
Number of active firms handling materials prohibited from use in ruminant  feed – 9,293 (33% of those active firms inspected) 
Of the 9,293 active firms handling prohibited materials, their most recent  inspection revealed that: 
0 firms (0%) were classified as OAI 
123 firms (1.3%) were classified as VAI 
TOTAL FIRMS 
Note that a single firm can be reported under more than one firm category;  therefore, the summation of the individual OAI/VAI firm categories will be more  than the actual total number of OAI/VAI firms, as presented below. 
Number of active firms whose initial inspection has been reported to FDA –  30,124 
Number of active firms handling materials prohibited from use in ruminant  feed – 9,819 (33% of those active firms inspected) 
Of the 9,819 active firms handling prohibited materials, their most recent  inspection revealed that: 
 2 firms (0.02%) were classified as OAI 
130 firms (1.3%) were classified as VAI 
WITH the looks of things, the BSE GBR risk assessment for the USA in 2012  should be held stead fast at BSE GBR III. but as I said long ago, the BSE GBR  risk assessment should be BSE GBR IV due to the terribly failed, if not  fraudulent USDA FDA BSE TESTING, AND SURVEILLANCE FOR BSE, since the inception  of the programs. all failed terribly. ...TSS 
 AN appalling amount of violations, that most likely led to a great deal of  banned suspect mad cow protein in commerce. however sadly, the way the  violations are now wrote up, the common layperson cannot know exact what the  violations were, or how much banned suspect mad cow protein actually went out  into commerce. as was the infamous decade post partial and voluntary feed ban  violations, where the one in 2007 let loose 10,000,000 LBS of banned blood laced  MBM into commerce ; 
 10,000,000+ LBS. of PROHIBITED BANNED MAD COW FEED I.E. BLOOD LACED MBM IN  COMMERCE USA 2007 
Date: March 21, 2007 at 2:27 pm PST 
RECALLS AND FIELD CORRECTIONS: VETERINARY MEDICINES -- CLASS II 
___________________________________ 
PRODUCT 
Bulk cattle feed made with recalled Darling's 85% Blood Meal, Flash Dried,  Recall # V-024-2007 
CODE 
Cattle feed delivered between 01/12/2007 and 01/26/2007 
RECALLING FIRM/MANUFACTURER 
Pfeiffer, Arno, Inc, Greenbush, WI. by conversation on February 5, 2007.  
Firm initiated recall is ongoing. 
REASON 
Blood meal used to make cattle feed was recalled because it was cross-  contaminated with prohibited bovine meat and bone meal that had been  manufactured on common equipment and labeling did not bear cautionary BSE  statement. 
VOLUME OF PRODUCT IN COMMERCE 
42,090 lbs. 
DISTRIBUTION 
WI 
___________________________________ 
PRODUCT 
Custom dairy premix products: MNM ALL PURPOSE Pellet, HILLSIDE/CDL Prot-  Buffer Meal, LEE, M.-CLOSE UP PX Pellet, HIGH DESERT/ GHC LACT Meal, TATARKA, M  CUST PROT Meal, SUNRIDGE/CDL PROTEIN Blend, LOURENZO, K PVM DAIRY Meal, DOUBLE B  DAIRY/GHC LAC Mineral, WEST PIONT/GHC CLOSEUP Mineral, WEST POINT/GHC LACT Meal,  JENKS, J/COMPASS PROTEIN Meal, COPPINI - 8# SPECIAL DAIRY Mix, GULICK, L-LACT  Meal (Bulk), TRIPLE J - PROTEIN/LACTATION, ROCK CREEK/GHC MILK Mineral,  BETTENCOURT/GHC S.SIDE MK-MN, BETTENCOURT #1/GHC MILK MINR, V&C DAIRY/GHC  LACT Meal, VEENSTRA, F/GHC LACT Meal, SMUTNY, A- BYPASS ML W/SMARTA, Recall #  V-025-2007 
CODE 
The firm does not utilize a code - only shipping documentation with  commodity and weights identified. 
RECALLING FIRM/MANUFACTURER 
Rangen, Inc, Buhl, ID, by letters on February 13 and 14, 2007. Firm  initiated recall is complete. 
REASON 
Products manufactured from bulk feed containing blood meal that was cross  contaminated with prohibited meat and bone meal and the labeling did not bear  cautionary BSE statement. 
VOLUME OF PRODUCT IN COMMERCE 
9,997,976 lbs. 
DISTRIBUTION 
ID and NV 
END OF ENFORCEMENT REPORT FOR MARCH 21, 2007 
see much more tonnage of recalled prohibited banned suspect BSE  contaminated feed here ; 
Saturday, November 6, 2010 
TAFS1 Position Paper on Position Paper on Relaxation of the Feed Ban in the  EU 
Berne, 2010 TAFS INTERNATIONAL FORUM FOR TRANSMISSIBLE ANIMAL DISEASES AND  FOOD SAFETY a non-profit Swiss Foundation 
Archive Number 20101206.4364 Published Date 06-DEC-2010 Subject  PRO/AH/EDR> 
Prion disease update 2010 (11) PRION DISEASE UPDATE 2010 (11) 
Saturday, July 23, 2011 
CATTLE HEADS WITH TONSILS, BEEF TONGUES, SPINAL CORD, SPECIFIED RISK  MATERIALS (SRM's) AND PRIONS, AKA MAD COW DISEASE 
To date the OIE/WAHO assumes that the human and animal health standards set  out in the BSE chapter for classical BSE (C-Type) applies to all forms of BSE  which include the H-type and L-type atypical forms. This assumption is  scientifically not completely justified and accumulating evidence suggests that  this may in fact not be the case. Molecular characterization and the spatial  distribution pattern of histopathologic lesions and immunohistochemistry (IHC)  signals are used to identify and characterize atypical BSE. Both the L-type and  H-type atypical cases display significant differences in the conformation and  spatial accumulation of the disease associated prion protein (PrPSc) in brains  of afflicted cattle. Transmission studies in bovine transgenic and wild type  mouse models support that the atypical BSE types might be unique strains because  they have different incubation times and lesion profiles when compared to C-type  BSE. When L-type BSE was inoculated into ovine transgenic mice and Syrian  hamster the resulting molecular fingerprint had changed, either in the first or  a subsequent passage, from L-type into C-type BSE. In addition, non-human  primates are specifically susceptible for atypical BSE as demonstrated by an  approximately 50% shortened incubation time for L-type BSE as compared to  C-type. Considering the current scientific information available, it cannot be  assumed that these different BSE types pose the same human health risks as  C-type BSE or that these risks are mitigated by the same protective measures.  
Thursday, August 12, 2010
Seven main threats for the future linked to prions
First threat
The TSE road map defining the evolution of European policy for protection  against prion diseases is based on a certain numbers of hypotheses some of which  may turn out to be erroneous. In particular, a form of BSE (called atypical  Bovine Spongiform Encephalopathy), recently identified by systematic testing in  aged cattle without clinical signs, may be the origin of classical BSE and thus  potentially constitute a reservoir, which may be impossible to eradicate if a  sporadic origin is confirmed. ***Also, a link is suspected between atypical BSE  and some apparently sporadic cases of Creutzfeldt-Jakob disease in humans. These  atypical BSE cases constitute an unforeseen first threat that could sharply  modify the European approach to prion diseases.
Second threat 
snip... 
 Monday, October 10, 2011 
EFSA Journal 2011 The European Response to BSE: A Success Story 
snip... 
EFSA and the European Centre for Disease Prevention and Control (ECDC)  recently delivered a scientific opinion on any possible epidemiological or  molecular association between TSEs in animals and humans (EFSA Panel on  Biological Hazards (BIOHAZ) and ECDC, 2011). This opinion confirmed Classical  BSE prions as the only TSE agents demonstrated to be zoonotic so far but the  possibility that a small proportion of human cases so far classified as  "sporadic" CJD are of zoonotic origin could not be excluded. Moreover,  transmission experiments to non-human primates suggest that some TSE agents in  addition to Classical BSE prions in cattle (namely L-type Atypical BSE,  Classical BSE in sheep, transmissible mink encephalopathy (TME) and chronic  wasting disease (CWD) agents) might have zoonotic potential. 
snip... 
 see follow-up here about North America BSE Mad Cow TSE prion risk factors,  and the ever emerging strains of Transmissible Spongiform Encephalopathy in many  species here in the USA, including humans ; 
P.9.21 Molecular characterization of BSE in Canada 
 Jianmin Yang1, Sandor Dudas2, Catherine Graham2, Markus Czub3, Tim  McAllister1, Stefanie Czub1 1Agriculture and Agri-Food Canada Research Centre,  Canada; 2National and OIE BSE Reference Laboratory, Canada; 3University of  Calgary, Canada 
 Background: Three BSE types (classical and two atypical) have been  identified on the basis of molecular characteristics of the misfolded protein  associated with the disease. To date, each of these three types have been  detected in Canadian cattle. 
 Objectives: This study was conducted to further characterize the 16  Canadian BSE cases based on the biochemical properties of there associated  PrPres. 
 Methods: Immuno-reactivity, molecular weight, glycoform profiles and  relative proteinase K sensitivity of the PrPres from each of the 16 confirmed  Canadian BSE cases was determined using modified Western blot analysis. Results:  Fourteen of the 16 Canadian BSE cases were C type, 1 was H type and 1 was L  type. The Canadian H and L-type BSE cases exhibited size shifts and changes in  glycosylation similar to other atypical BSE cases. PK digestion under mild and  stringent conditions revealed a reduced protease resistance of the atypical  cases compared to the C-type cases. N terminal- specific antibodies bound to  PrPres from H type but not from C or L type. The C-terminal-specific antibodies  resulted in a shift in the glycoform profile and detected a fourth band in the  Canadian H-type BSE. 
 Discussion: The C, L and H type BSE cases in Canada exhibit molecular  characteristics similar to those described for classical and atypical BSE cases  from Europe and Japan. This supports the theory that the importation of BSE  contaminated feedstuff is the source of C-type BSE in Canada. *** It also  suggests a similar cause or source for atypical BSE in these countries. 
Saturday, June 25, 2011 
Transmissibility of BSE-L and Cattle-Adapted TME Prion Strain to Cynomolgus  Macaque 
"BSE-L in North America may have existed for decades" 
Over the next 8-10 weeks, approximately 40% of all the adult mink on the  farm died from TME. 
 snip... 
 The rancher was a ''dead stock'' feeder using mostly (>95%) downer or  dead dairy cattle... 
 14th ICID International Scientific Exchange Brochure - 
 Final Abstract Number: ISE.114 
 Session: International Scientific Exchange 
 Transmissible Spongiform encephalopathy (TSE) animal and human TSE in  North America update October 2009 
 T. Singeltary 
 Bacliff, TX, USA 
 Background: 
 An update on atypical BSE and other TSE in North America. Please remember,  the typical U.K. c-BSE, the atypical l-BSE (BASE), and h-BSE have all been  documented in North America, along with the typical scrapie's, and atypical  Nor-98 Scrapie, and to date, 2 different strains of CWD, and also TME. All these  TSE in different species have been rendered and fed to food producing animals  for humans and animals in North America (TSE in cats and dogs ?), and that the  trading of these TSEs via animals and products via the USA and Canada has been  immense over the years, decades. 
 Methods: 
 12 years independent research of available data 
 Results: 
 I propose that the current diagnostic criteria for human TSEs only  enhances and helps the spreading of human TSE from the continued belief of the  UKBSEnvCJD only theory in 2009. With all the science to date refuting it, to  continue to validate this old myth, will only spread this TSE agent through a  multitude of potential routes and sources i.e. consumption, medical i.e.,  surgical, blood, dental, endoscopy, optical, nutritional supplements, cosmetics  etc. 
 Conclusion: 
 I would like to submit a review of past CJD surveillance in the USA, and  the urgent need to make all human TSE in the USA a reportable disease, in every  state, of every age group, and to make this mandatory immediately without  further delay. The ramifications of not doing so will only allow this agent to  spread further in the medical, dental, surgical arena's. Restricting the  reporting of CJD and or any human TSE is NOT scientific. Iatrogenic CJD knows NO  age group, TSE knows no boundaries. I propose as with Aguzzi, Asante, Collinge,  Caughey, Deslys, Dormont, Gibbs, Gajdusek, Ironside, Manuelidis, Marsh, et al  and many more, that the world of TSE Transmissible Spongiform Encephalopathy is  far from an exact science, but there is enough proven science to date that this  myth should be put to rest once and for all, and that we move forward with a new  classification for human and animal TSE that would properly identify the  infected species, the source species, and then the route. 
Sunday, January 29, 2012 
Prion Disease Risks in the 21st Century 2011 PDA European Virus-TSE Safety  Dr. Detwiler 
Dr. Detwiler published Prion Disease Risks in the 21st Century 2011 PDA  European Virus-TSE Safety Forum\Presentations TSE\ Page 33 and 34 of 44 ; 
Wednesday, February 1, 2012 
CJD and PLASMA / URINE PRODUCTS EMA Position Statements Alberto Ganan  Jimenez, European Medicines Agency PDA TSE Safety Forum, 30 June 2011 
Wednesday, February 1, 2012 
Prion Disease Risks in the 21st Century 2011 PDA European Virus-TSE Safety  Update on CJD and VCJD Transmission RG Will 
Thursday, January 26, 2012 
Facilitated Cross-Species Transmission of Prions in Extraneural Tissue  
 Science 27 January 2012: Vol. 335 no. 6067 pp. 472-475 DOI:  10.1126/science.1215659 
 Tuesday, May 27, 2008 
FDA BSE/Ruminant Feed Inspections Firms Inventory Report Texas Legend Ranch  OAI 05/10/2008 
Friday, September 4, 2009
FOIA REQUEST ON FEED RECALL PRODUCT 429,128 lbs. feed for ruminant animals  may have been contaminated with prohibited material Recall # V-258-2009
Saturday, August 29, 2009
FOIA REQUEST FEED RECALL 2009 Product may have contained prohibited  materials Bulk Whole Barley, Recall # V-256-2009
C O N F I R M E D 
----- Original Message -----
From: "Terry S. Singeltary Sr."
To:
Sent: Thursday, November 05, 2009 9:25 PM
Subject: [BSE-L] re-FOIA REQUEST ON FEED RECALL PRODUCT contaminated with  prohibited material Recall # V-258-2009 and Recall # V-256-2009
PLEASE UNDERSTAND, with a Transmissible Spongiform Encephalopathy, once  clinical, the disease is 100% fatal. There should be NO debate of the  'unacceptable risk factor', with any TSE. ...TSS 
Sunday, June 26, 2011 
Risk Analysis of Low-Dose Prion Exposures in Cynomolgus Macaque 
 Saturday, June 13, 2009 
BSE FEED VIOLATIONS USA UPDATE From 01/01/2009 To 06/10/2009 
Monday, April 5, 2010 
Update on Feed Enforcement Activities to Limit the Spread of BSE April 5,  2010 
Monday, January 17, 2011 
MAD COW Update on Feed Enforcement Activities to Limit the Spread of BSE  January 13, 2011 
Friday, January 6, 2012 
OIE 2012 Training Manual on Wildlife Diseases and Surveillance and TSE  Prion disease 
 TSS

 
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