BSE MAD COW LETTERS TO USDA (Tom Vilsack, Secretary of Agriculture) and FDA 
(Magaret Hamburg, Commissioner of FDA) May 1, 2012 
CONSUMERS UNION
BSE MAD COW LETTERS TO USDA (Tom Vilsack, Secretary of Agriculture) and FDA 
(Magaret Hamburg, Commissioner of FDA) May 1, 2012 
May 1, 2012
Honorable Tom Vilsack, Secretary U.S. Department of Agriculture 1400 
Independence Ave., SW Washington, DC 20250
Dear Secretary Vilsack:
USDA’s announcement last week that a fourth case of bovine spongiform 
encephalopathy (BSE) has been identified in the United States, in a dairy cow in 
Central California, is a warning flag that current safeguards against BSE are 
not adequate and USDA should take additional steps to protect the health of 
animals and of the beef-eating public.
Consumers Union, the policy and advocacy arm of Consumer Reports, is 
concerned that if additional steps are not taken now, this deadly disease could 
circulate and amplify within US cattle. USDA should conduct a full and complete 
investigation of this case, expand its surveillance program, and allow private 
companies to test as well. USDA should conduct a full and complete investigation 
of this new BSE case. USDA has confirmed to reporters that this case is an 
“L-type” atypical strain of BSE.1 USDA therefore must be especially vigilant, 
because this may well not be a “spontaneous” case, but rather may well have been 
infected through feed, and may be particularly infectious in humans.
The L-type BSE strain has previously been identified in cattle in Europe2 
and in Canada.3 This would suggest that the current case may have been 
contracted through feed, rather than be a new spontaneous occurrence.
Studies further suggest that the L-type BSE can infect humans, possibly 
even more easily than “classical” BSE. A study using humanized mice (mice 
genetically engineered to
have brain prions like humans) suggested that L-type BSE could infect 
humans.4 Another study showed oral transmission to a primate.5 The mouse study 
also found shorter incubation periods than for classical BSE, making it a more 
“virulent” strain.6 The fact that L-type BSE has been found before in cattle 
makes it extremely important that USDA conduct a thorough and complete 
investigation of this case. Not just all offspring, but all cows that consumed 
the same feed as this cow, should be tested for BSE.
USDA should significantly increase its surveillance for BSE.
Given the very small size of the current USDA surveillance program, it 
cannot be said with certainty whether this new case is an isolated one, or 
whether it is indicative of a much larger problem.
USDA tests approximately 40,000 dead or slaughtered cattle annually for 
BSE, only about .1 percent of the 35 million cattle slaughtered annually in the 
United States. This is far too small a sample to provide the nation with the 
assurance that our food supply is safe. In Europe and Japan, every animal over a 
certain age is tested at slaughter. In the U.S., having recently found one case 
of BSE in a program of just 40,000 tests annually, consumers need to know what 
the results would be from a larger test program in order to maintain their 
confidence in the U.S. beef supply.
Ideally USDA should test all cattle at slaughter over the age of 20 months 
for several years. At a minimum, USDA should test at least 350,000 annually, for 
at least three years, including all cows showing nervous system abnormalities, 
downers, and a random selection of cattle slaughtered at more than 30 months of 
age and cows sent to the renderers.
USDA should end its prohibition on private sector testing for BSE.
To augment USDA testing, and to assure meat producers’ access to foreign 
markets, USDA should reverse its counterproductive policy of prohibiting private 
companies from testing for BSE at their own expense. In the past, a private 
company sought permission to test animals for BSE at their own facility, using 
the same test that USDA employs to detect BSE, in order to be able to export 
beef to Japan, which requires testing of all animals over 20 months at 
slaughter. However, USDA has prohibited sale of test kits for this purpose. In 
an era of limited governmental resources, when public-private partnerships are 
essential to assure safety, we urge USDA to reconsider this highly 
counterproductive and anti-competitive policy. 
USDA has argued that the rapid tests are “worthless” when used for a food 
safety purpose because their use could result in a false negative.7 While we 
agree the rapid test kits can miss a case of BSE in the early stages of 
incubation, such test kits can catch the disease in later stages, before the 
animals show symptoms.8 They are used to test animals at slaughter in Europe and 
Japan and have identified more than 1,000 otherwise undetected cases in Europe.9 
We urge USDA to allow private testing, with the caveat that any findings of a 
BSE positive animal would have to be immediately reported to the USDA. Although 
tested beef should not be labeled “BSE-free,” testing could in fact be 
incentivized by allowing companies who use such tests to label their products as 
"BSEtested." We would appreciate having an opportunity to discuss these 
recommendations with you and your staff. Thank you for your consideration. 
1 Thompson, H. 2012. California BSE prion comes with a different twist. 
Nature News Blog, April 27. At: http://blogs.nature.com/news/2012/04/california-bse-prion-comes-with-a-different-twist.html 
2 Brown, P, McShane, LM, Zancusso, G and L Detwiler. 2006. On the question 
of sporadic or atypical bovine spongiform encephalopathy and Creutzfeldt-Jacob 
disease. Emerging Infectious Diseases, 12(12): 1816-1821. At: http://wwwnc.cdc.gov/eid/article/12/12/pdfs/06-0965.pdf 
3 Dudas, S et al. 2010. Molecular, Biochemical and Genetic Characteristics 
of BSE in Canada. PLOS One, At: http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone.0010638
4 Kong, Q, et al. 2008. Evaluation of the human transmission risk of an 
atypical bovine spongiform encephalopathy prion strain. Journal of Virology, pp. 
3697-3701.
5 Mestre-Frances N et al. 2012. Oral transmission of L-type bovine 
spongiform encephalopathy in primate model. Emerging Infectious Diseases, 18(1): 
142-145.
6 Kong et al. Op cit. 
Sincerely,
Michael Hansen, PhD. Jean Halloran
Senior Scientist 
===================END...TSS====================
rookie TSE scientist with no PhDs 
SENIOR LAYPERSON 
Terry S. Singeltary Sr. P.O. Box 42 Bacliff, Texas USA 77518 
flounder9@verizon.net 
MAD COW USDA ATYPICAL L-TYPE BASE BSE 
OIE says the animal was sub-clinical ; 
>>> The animal in question was 10 years and 7 months old I am 
curious, maybe I missed it somewhere, but was there paperwork on this mad cow, 
or was dental detention used to determine the age of the cattle ? 
I remember one of the other USA mad cows had no paper work and officials 
had to use dental detention to guess the age of that mad cow. 
detention, in my opinion, is another way to get around regulations. just 
throw away the paperwork, and officials then can just guesstimate the age of the 
mad cow, thus fudging on age by a few months, thus being able to keep in the so 
called safe zone i.e. barb or not. 
so, I am just curious as to if dental detention had to be used in this 4th 
mad cow case ??? 
On March 13, 2006, the U.S. Department of Agriculture (USDA) announced the 
confirmation of bovine spongiform encephalopathy (BSE) in a cow in Alabama. The 
newly confirmed case was identified in a non-ambulatory (downer) cow on a farm 
in Alabama. The animal was euthanized by a local veterinarian and buried on the 
farm. The age of the cow was estimated by examination of the dentition as 
10-years-old. It had no ear tags or distinctive marks; the herd of origin could 
not be identified despite an intense investigation (see Alabama BSE 
Investigation, Final Epidemiology Report, May 2006). http://www.fsis.usda.gov/ofo/tsc/bse_information.htm 
It is important to reiterate here, even though this animal did not enter 
the food chain, the fact that the USA now finds mad cow disease in samplings of 
1 in 40,000 is very disturbing, and to add the fact that it was an atypical 
L-type BASE BSE, well that is very disturbing in itself. 1 out of 40,000, would 
mean that there were around 25 mad cows in the USA annually going by a National 
herd of 100 million (which now I don’t think the USA herd is that big), but then 
you add all these disturbing factors together, the documented link of sporadic 
CJD cases to atypical L-type BASE BSE, the rise in sporadic CJD cases in the USA 
of a new strain of CJD called ‘classification pending Creutzfeldt Jakob Disease’ 
cpCJD, in young and old, with long duration of clinical symptoms until death. 
the USA has a mad cow problem and have consistently covered it up. it’s called 
the SSS policy. ... 
so, USDA et al accidently find two atypical mad cows in Texas and Alabama 
during the infamous enhanced BSE cover up back in 2004 and 2005, and then shut 
the testing down to numbers so low, it’s almost impossible to find another mad 
cow case, unless your country is to a point that mad cow disease can be found in 
1 in 40,000, and STILL FIND MAD COW DISEASE. partial and voluntary BSE mad cow 
feed ban of August 4, 1997 was nothing more than ink on paper, with as much as 
10,000,000 LBS. of blood laced meat and bone meal MBM going out into commerce 10 
years later in 2007. who knows since 2007 breach, fda et al stopped posting 
those warning letters. ARS said if atypical BSE was more virulent, SRM removal 
would have to change if tissue infectivity was found differently than c-BSE. it 
was. more virulent and infectivity was found in more tissues, including skeletal 
muscle. HOUSTON, WE HAVE A PROBLEM. ... 
I am deeply disturbed about the false and terribly misleading information 
that is being handed out by the USDA FDA et al about this recent case of the 
atypical L-type BASE BSE case in California. these officials are terribly 
misinformed (I was told they are not lying), about the risk factor and 
transmissibility of the atypical L-type BASE BSE. along with the USDA et al, the 
media is following through with these lies. these are very disturbing 
transmission studies that the CDC PUT OUT IN 2012. I urge officials to come 
forward with the rest of this story. 
please see ; 
CDC 2012 
Oral Transmission of L-type Bovine Spongiform Encephalopathy in Primate 
Model 
Nadine Mestre-Francés, Simon Nicot, Sylvie Rouland, Anne-Gaëlle Biacabe, 
Isabelle Quadrio, Armand Perret-Liaudet, Thierry Baron, and Jean-Michel Verdier 
We report transmission of atypical L-type bovine spongiform encephalopathy 
to mouse lemurs after oral or intracerebral inoculation with infected bovine 
brain tissue. After neurologic symptoms appeared, transmissibility of the 
disease by both inoculation routes was confirmed by detection of 
disease-associated prion protein in samples of brain tissue. 
snip... 
Conclusions 
We demonstrated that the agent of L-BSE can be transmitted by the oral 
route from cattle to mouse lemurs. As expected, orally inoculated animals 
survived longer than IC-inoculated animals. Orally inoculated lemurs had less 
severe clinical signs and symptoms, with no evidence of motor dysfunction. It 
was previously suggested that the agent of L-BSE might be involved in the 
foodborne transmission of a prion disease in mink (11,12), a species in which 
several outbreaks of transmissible mink encephalopathy had been identified, 
notably in the United States (13). 
Our study clearly confirms, experimentally, the potential risk for 
interspecies oral transmission of the agent of L-BSE. In our model, this risk 
appears higher than that for the agent of classical BSE, which could only be 
transmitted to mouse lemurs after a first passage in macaques (14). We report 
oral transmission of the L-BSE agent in young and adult primates. Transmission 
by the IC route has also been reported in young macaques (6,7). A previous study 
of L-BSE in transgenic mice expressing human PrP suggested an absence of any 
transmission barrier between cattle and humans for this particular strain of the 
agent of BSE, in contrast to findings for the agent of classical BSE (9). Thus, 
it is imperative to maintain measures that prevent the entry of tissues from 
cattle possibly infected with the agent of L-BSE into the food chain. 
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. 
Subject: Atypical BSE (BASE) Transmitted from Asymptomatic Aging Cattle to 
a Primate 
Atypical BSE (BASE) Transmitted from Asymptomatic Aging Cattle to a 
Primate 
Emmanuel E. Comoy1*, Cristina Casalone2, Nathalie Lescoutra-Etchegaray1, 
Gianluigi Zanusso3, Sophie Freire1, Dominique Marcé1, Frédéric Auvré1, 
Marie-Magdeleine Ruchoux1, Sergio Ferrari3, Salvatore Monaco3, Nicole Salès4, 
Maria Caramelli2, Philippe Leboulch1,5, Paul Brown1, Corinne I. Lasmézas4, 
Jean-Philippe Deslys1 
1 Institute of Emerging Diseases and Innovative Therapies, CEA, 
Fontenay-aux-Roses, France, 2 Istituto Zooprofilattico Sperimentale del 
Piemonte, Turin, Italy, 3 Policlinico G.B. Rossi, Verona, Italy, 4 Scripps 
Florida, Jupiter, Florida, United States of America, 5 Genetics Division, 
Brigham & Women's Hospital, Harvard Medical School, Boston, Massachusetts, 
United States of America 
Abstract Top Background 
Human variant Creutzfeldt-Jakob Disease (vCJD) results from foodborne 
transmission of prions from slaughtered cattle with classical Bovine Spongiform 
Encephalopathy (cBSE). Atypical forms of BSE, which remain mostly asymptomatic 
in aging cattle, were recently identified at slaughterhouses throughout Europe 
and North America, raising a question about human susceptibility to these new 
prion strains. 
Methodology/Principal Findings 
Brain homogenates from cattle with classical BSE and atypical (BASE) 
infections were inoculated intracerebrally into cynomolgus monkeys (Macacca 
fascicularis), a non-human primate model previously demonstrated to be 
susceptible to the original strain of cBSE. The resulting diseases were compared 
in terms of clinical signs, histology and biochemistry of the abnormal prion 
protein (PrPres). The single monkey infected with BASE had a shorter survival, 
and a different clinical evolution, histopathology, and prion protein (PrPres) 
pattern than was observed for either classical BSE or vCJD-inoculated animals. 
Also, the biochemical signature of PrPres in the BASE-inoculated animal was 
found to have a higher proteinase K sensitivity of the octa-repeat region. We 
found the same biochemical signature in three of four human patients with 
sporadic CJD and an MM type 2 PrP genotype who lived in the same country as the 
infected bovine. 
Conclusion/Significance 
Our results point to a possibly higher degree of pathogenicity of BASE 
than classical BSE in primates and also raise a question about a possible link 
to one uncommon subset of cases of apparently sporadic CJD. Thus, despite the 
waning epidemic of classical BSE, the occurrence of atypical strains should 
temper the urge to relax measures currently in place to protect public health 
from accidental contamination by BSE-contaminated products. 
Citation: Comoy EE, Casalone C, Lescoutra-Etchegaray N, Zanusso G, Freire 
S, et al. (2008) Atypical BSE (BASE) Transmitted from Asymptomatic Aging Cattle 
to a Primate. PLoS ONE 3(8): e3017. doi:10.1371/journal.pone.0003017 
Editor: Neil Mabbott, University of Edinburgh, United Kingdom 
Received: April 24, 2008; Accepted: August 1, 2008; Published: August 20, 
2008 
Copyright: © 2008 Comoy et al. This is an open-access article distributed 
under the terms of the Creative Commons Attribution License, which permits 
unrestricted use, distribution, and reproduction in any medium, provided the 
original author and source are credited. 
Funding: This work has been supported by the Network of Excellence 
NeuroPrion. 
Competing interests: CEA owns a patent covering the BSE diagnostic tests 
commercialized by the company Bio-Rad. 
* E-mail: emmanuel.comoy@cea.fr 
snip... 
In summary, we have transmitted one atypical form of BSE (BASE) to a 
cynomolgus macaque monkey that had a shorter incubation period than monkeys 
infected with classical BSE, with distinctive clinical, neuropathological, and 
biochemical features; and have shown that the molecular biological signature 
resembled that seen in a comparatively uncommon subtype of sporadic CJD. We 
cannot yet say whether BASE is more pathogenic for primates (including humans) 
than cBSE, nor can we predict whether its molecular biological features 
represent a clue to one cause of apparently sporadic human CJD. However, the 
evidence presented here and by others justifies concern about a potential human 
health hazard from undetected atypical forms of BSE, and despite the waning 
epizoonosis of classical BSE, it would be premature to abandon the precautionary 
measures that have been so successful in reversing the impact of cBSE. We would 
instead urge a gradual, staged reduction that takes into account the evolving 
knowledge about atypical ruminant diseases, and both a permanent ban on the use 
of bovine central nervous system tissue for either animal or human use, and its 
destruction so as to eliminate any risk of environmental contamination. 
Wednesday, March 31, 2010 
Atypical BSE in Cattle 
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. 
This study will contribute to a correct definition of specified risk 
material (SRM) in atypical BSE. The incumbent of this position will develop new 
and transfer existing, ultra-sensitive methods for the detection of atypical BSE 
in tissue of experimentally infected cattle. 
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... 
October 2009 O.11.3 
Infectivity in skeletal muscle of BASE-infected cattle 
Silvia Suardi1, Chiara Vimercati1, Fabio Moda1, Ruggerone Margherita1, 
Ilaria Campagnani1, Guerino Lombardi2, Daniela Gelmetti2, Martin H. Groschup3, 
Anne Buschmann3, Cristina Casalone4, Maria Caramelli4, Salvatore Monaco5, 
Gianluigi Zanusso5, Fabrizio Tagliavini1 1Carlo Besta" Neurological 
Institute,Italy; 2IZS Brescia, Italy; 33FLI Insel Riems, D, Germany; 4CEA-IZS 
Torino, Italy; 5University of Verona, Italy 
Background: BASE is an atypical form of bovine spongiform encephalopathy 
caused by a prion strain distinct from that of BSE. Upon experimental 
transmission to cattle, BASE induces a previously unrecognized disease phenotype 
marked by mental dullness and progressive atrophy of hind limb musculature. 
Whether affected muscles contain infectivity is unknown. This is a critical 
issue since the BASE strain is readily transmissible to a variety of hosts 
including primates, suggesting that humans may be susceptible. 
Objectives: To investigate the distribution of infectivity in peripheral 
tissues of cattle experimentally infected with BASE. Methods: Groups of Tg mice 
expressing bovine PrP (Tgbov XV, n= 7-15/group) were inoculated both i.c. and 
i.p. with 10% homogenates of a variety of tissues including brain, spleen, 
cervical lymph node, kidney and skeletal muscle (m. longissimus dorsi) from 
cattle intracerebrally infected with BASE. No PrPres was detectable in the 
peripheral tissues used for inoculation either by immunohistochemistry or 
Western blot. 
Results: Mice inoculated with BASE-brain homogenates showed clinical signs 
of disease with incubation and survival times of 175±15 and 207±12 days. Five 
out of seven mice challenged with skeletal muscle developed a similar 
neurological disorder, with incubation and survival times of 380±11 and 410±12 
days. At present (700 days after inoculation) mice challenged with the other 
peripheral tissues are still healthy. The neuropathological phenotype and PrPres 
type of the affected mice inoculated either with brain or muscle were 
indistinguishable and matched those of Tgbov XV mice infected with natural BASE. 
Discussion: Our data indicate that the skeletal muscle of cattle 
experimentally infected with BASE contains significant amount of infectivity, at 
variance with BSE-affected cattle, raising the issue of intraspecies 
transmission and the potential risk for humans. Experiments are in progress to 
assess the presence of infectivity in skeletal muscles of natural BASE. 
now, what about that mad cow feed and atypical BSE $$$ 
LET’S see how that mad cow triple firewall aka mad cow feed ban is working 
out $$$ 
*** BANNED MAD COW FEED IN THE USA IN COMMERCE TONS AND TONS 
THIS is just ONE month report, of TWO recalls of prohibited banned MBM, 
which is illegal, mixed with 85% blood meal, which is still legal, but yet we 
know the TSE/BSE agent will transmit blood. we have this l-BSE in North America 
that is much more virulent and there is much concern with blood issue and l-BSE 
as there is with nvCJD in humans. some are even starting to be concerned with 
sporadic CJD and blood, and there are studies showing transmission there as 
well. ... this is one month recall page, where 10 MILLION POUNDS OF BANNED MAD 
COW FEED WENT OUT INTO COMMERCE, TO BE FED OUT. very little of the product that 
reaches commerce is ever returned via recall, very, very little. this was 2007, 
TEN YEARS AFTER THE AUGUST 4, 1997, PARTIAL AND VOLUNTARY MAD COW FEED BAN IN 
THE USA, that was nothing but ink on paper. i have listed the tonnage of mad cow 
feed that was in ALABAMA in one of the links too, this is where the infamous 
g-h-BSEalabama case was, a genetic relation matching the new sporadic CJD in the 
USA. seems this saga just keeps getting better and better.......$$$ 
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 
Saturday, August 14, 2010 
BSE Case Associated with Prion Protein Gene Mutation (g-h-BSEalabama) and 
VPSPr PRIONPATHY 
*** (see mad cow feed in COMMERCE IN ALABAMA...TSS) 
BANNED MAD COW FEED IN COMMERCE IN ALABAMA 
Date: September 6, 2006 at 7:58 am PST PRODUCT 
a) EVSRC Custom dairy feed, Recall # V-130-6; 
b) Performance Chick Starter, Recall # V-131-6; 
c) Performance Quail Grower, Recall # V-132-6; 
d) Performance Pheasant Finisher, Recall # V-133-6. 
CODE None RECALLING FIRM/MANUFACTURER Donaldson & Hasenbein/dba 
J&R Feed Service, Inc., Cullman, AL, by telephone on June 23, 2006 and by 
letter dated July 19, 2006. Firm initiated recall is complete. 
REASON 
Dairy and poultry feeds were possibly contaminated with ruminant based 
protein. 
VOLUME OF PRODUCT IN COMMERCE 477.72 tons 
DISTRIBUTION AL 
______________________________ 
PRODUCT Bulk custom dairy pre-mixes, 
Recall # V-120-6 CODE None RECALLING FIRM/MANUFACTURER Ware Milling Inc., 
Houston, MS, by telephone on June 23, 2006. Firm initiated recall is complete. 
REASON Possible contamination of dairy animal feeds with ruminant derived meat 
and bone meal. 
VOLUME OF PRODUCT IN COMMERCE 350 tons 
DISTRIBUTION AL and MS 
______________________________ 
PRODUCT 
a) Tucker Milling, LLC Tm 32% Sinking Fish Grower, #2680-Pellet, 50 lb. 
bags, Recall # V-121-6; 
b) Tucker Milling, LLC #31120, Game Bird Breeder Pellet, 50 lb. bags, 
Recall # V-122-6; 
c) Tucker Milling, LLC #31232 Game Bird Grower, 50 lb. bags, Recall # 
V-123-6; 
d) Tucker Milling, LLC 31227-Crumble, Game Bird Starter, BMD Medicated, 50 
lb bags, Recall # V-124-6; 
e) Tucker Milling, LLC #31120, Game Bird Breeder, 50 lb bags, Recall # 
V-125-6; 
f) Tucker Milling, LLC #30230, 30 % Turkey Starter, 50 lb bags, Recall # 
V-126-6; 
g) Tucker Milling, LLC #30116, TM Broiler Finisher, 50 lb bags, Recall # 
V-127-6 
CODE All products manufactured from 02/01/2005 until 06/20/2006 RECALLING 
FIRM/MANUFACTURER Recalling Firm: Tucker Milling LLC, Guntersville, AL, by 
telephone and visit on June 20, 2006, and by letter on June 23, 2006. 
Manufacturer: H. J. Baker and Brothers Inc., Stamford, CT. Firm initiated recall 
is ongoing. 
REASON Poultry and fish feeds which were possibly contaminated with 
ruminant based protein were not labeled as "Do not feed to ruminants". 
VOLUME OF PRODUCT IN COMMERCE 7,541-50 lb bags 
DISTRIBUTION AL, GA, MS, and TN 
END OF ENFORCEMENT REPORT FOR AUGUST 9, 2006 
### 
Subject: MAD COW FEED RECALL AL AND FL VOLUME OF PRODUCT IN COMMERCE 125 
TONS Products manufactured from 02/01/2005 until 06/06/2006 
Date: August 6, 2006 at 6:16 pm PST PRODUCT 
a) CO-OP 32% Sinking Catfish, Recall # V-100-6; 
b) Performance Sheep Pell W/Decox/A/N, medicated, net wt. 50 lbs, Recall # 
V-101-6; 
c) Pro 40% Swine Conc Meal -- 50 lb, Recall # V-102-6; 
d) CO-OP 32% Sinking Catfish Food Medicated, Recall # V-103-6; 
e) "Big Jim's" BBB Deer Ration, Big Buck Blend, Recall # V-104-6; 
f) CO-OP 40% Hog Supplement Medicated Pelleted, Tylosin 100 grams/ton, 50 
lb. bag, Recall # V-105-6; 
g) Pig Starter Pell II, 18% W/MCDX Medicated 282020, Carbadox -- 0.0055%, 
Recall # V-106-6; 
h) CO-OP STARTER-GROWER CRUMBLES, Complete Feed for Chickens from Hatch to 
20 Weeks, Medicated, Bacitracin Methylene Disalicylate, 25 and 50 Lbs, Recall # 
V-107-6; 
i) CO-OP LAYING PELLETS, Complete Feed for Laying Chickens, Recall # 
108-6; 
j) CO-OP LAYING CRUMBLES, Recall # V-109-6; 
k) CO-OP QUAIL FLIGHT CONDITIONER MEDICATED, net wt 50 Lbs, Recall # 
V-110-6; 
l) CO-OP QUAIL STARTER MEDICATED, Net Wt. 50 Lbs, Recall # V-111-6; 
m) CO-OP QUAIL GROWER MEDICATED, 50 Lbs, Recall # V-112-6 CODE 
Product manufactured from 02/01/2005 until 06/06/2006 
RECALLING FIRM/MANUFACTURER Alabama Farmers Cooperative, Inc., Decatur, 
AL, by telephone, fax, email and visit on June 9, 2006. FDA initiated recall is 
complete. 
REASON Animal and fish feeds which were possibly contaminated with 
ruminant based protein not labeled as "Do not feed to ruminants". 
VOLUME OF PRODUCT IN COMMERCE 125 tons 
DISTRIBUTION AL and FL 
END OF ENFORCEMENT REPORT FOR AUGUST 2, 2006 
### 
MAD COW FEED RECALL USA EQUALS 10,878.06 TONS NATIONWIDE Sun Jul 16, 2006 
09:22 71.248.128.67 
RECALLS AND FIELD CORRECTIONS: VETERINARY MEDICINE -- CLASS II 
______________________________ 
PRODUCT 
a) PRO-LAK, bulk weight, Protein Concentrate for Lactating Dairy Animals, 
Recall # V-079-6; 
b) ProAmino II, FOR PREFRESH AND LACTATING COWS, net weight 50lb (22.6 
kg), Recall # V-080-6; 
c) PRO-PAK, MARINE & ANIMAL PROTEIN CONCENTRATE FOR USE IN ANIMAL 
FEED, Recall # V-081-6; 
d) Feather Meal, Recall # V-082-6 CODE 
a) Bulk 
b) None 
c) Bulk 
d) Bulk 
RECALLING FIRM/MANUFACTURER H. J. Baker & Bro., Inc., Albertville, AL, 
by telephone on June 15, 2006 and by press release on June 16, 2006. Firm 
initiated recall is ongoing. 
REASON 
Possible contamination of animal feeds with ruminent derived meat and bone 
meal. 
VOLUME OF PRODUCT IN COMMERCE 10,878.06 tons 
DISTRIBUTION Nationwide 
END OF ENFORCEMENT REPORT FOR July 12, 2006 
### 
please see full text ; 
Tuesday, March 2, 2010 
Animal Proteins Prohibited in Ruminant Feed/Adulterated/Misbranded Rangen 
Inc 2/11/10 USA 
Monday, March 1, 2010 
ANIMAL PROTEIN I.E. MAD COW FEED IN COMMERCE A REVIEW 2010 
Tuesday, September 14, 2010 
Feed Safety and BSE/Ruminant Feed Ban Support Project (U18) 
Friday, October 8, 2010 
Scientific reasons for a feed ban of meat-and-bone meal, applicable to all 
farmed animals including cattle, pigs, poultry, farmed fish and pet food 
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) 
Sunday, February 5, 2012 
February 2012 Update on Feed Enforcement Activities to Limit the Spread of 
BSE 
Saturday, July 23, 2011 
CATTLE HEADS WITH TONSILS, BEEF TONGUES, SPINAL CORD, SPECIFIED RISK 
MATERIALS (SRM's) AND PRIONS, AKA MAD COW DISEASE 
IMPORT EXPORT BEEF, LIVE, PRODUCTS, CANADA AND USA 
America's Mad Cow Crisis by John Stauber 
Permission granted to reprint this article: 
America's Mad Cow Crisis 
John Stauber 
Americans might remember that when the first mad cow was confirmed in the 
United States in December, 2003, it was major news. The United States Department 
of Agriculture (USDA) and the Food and Drug Administration (FDA) had been 
petitioned for years by lawyers from farm and consumer groups I worked with to 
stop the cannibal feeding practices that transmit this horrible, always fatal, 
human and animal dementia. When the first cow was found in Washington state, the 
government said it would stop such feeding, and the media went away. But once 
the cameras were off and the reporters were gone nothing substantial changed. 
In the United States, dairy calves are still taken from their mothers and 
fed the blood and fat of dead cattle. This is no doubt a way to infect them with 
the mad cow disease that has now been incubating here for decades, spread 
through such animal feeding practices. No one knows how the latest dairy cow was 
infected, the fourth confirmed in the United States. Maybe it was nursed on 
cow's blood. Perhaps it was fed feed containing cattle fat with traces of cattle 
protein. Or perhaps there is a mad cow disease in pigs in the United States, 
which simply has not been found yet, because pigs are not tested for it at all, 
even though pigs are fed both pig and cattle byproducts, and then the blood, fat 
and other waste parts of these pigs are fed to cattle. 
All these U.S. cattle feeding methods are long banned and illegal in other 
countries that suffered through but eventually dealt properly with mad cow 
disease. Here, rather than stopping the transmission of the disease by stopping 
the cannibal feeding, mad cow is simply covered up with inadequate testing and 
very adequate public relations. US cattle are still fed mammalian blood, fat and 
protein, risking human deaths and threatening the long term safety of human 
blood products, simply to provide the U.S. livestock industry with a cheap 
protein source and a cheap way to get rid of dead animal waste. 
I began researching this issue around 1989, long before the disease was 
confirmed to have jumped from cattle to the people eating them, as announced by 
the British government in 1996. In 1997 I co-authored <http://www.prwatch.org/books/madcow.html> 
Mad Cow USA, warning that the disease was likely already here and spreading, 
since the animal cannibalism that caused its outbreak in Britain and spread it 
to other countries was actually more widespread in the United States than 
anywhere. 
Some years ago responsible U.S. beef companies wanted to test their 
animals for mad cow disease and label their beef as being disease free, but they 
were forbidden under penalty of law from doing so. Only the USDA can test for 
mad cows in America. In 2004 and 2005, after two additional mad cows were 
discovered in Texas and Alabama, the United Sates government declared that 
obviously mad cow wasn't much of a problem and gutted it's anemic testing 
program. Today only about 40,000 cattle a year are tested, out of tens of 
millions slaughtered. It's amazing that the California cow was even detected 
given this pathetic testing program that seems well designed to hide rather than 
find mad cows. 
The prevention of mad cow disease is relatively simple. If your country 
has it, test each animal before it goes to slaughter to keep the diseased 
animals out of the food chain. Cheap, accurate and easy tests are now available 
in other countries but illegal here. Testing cattle both identifies the true 
extent of the disease, and keeps infected animals from being eaten in your 
sausage or hamburger. In this manner countries like Britain, Germany, France and 
Japan have controlled their problem through testing and a strict ban on cannibal 
feed. 
Once mad cow disease moves into the human population of a country, all 
bets are off as to what could happen next. It's a very slow disease, it develops 
invisibly over decades in someone who has been infected, and it is always fatal. 
We'll know a lot more in fifty years, but the future looks worrisome. In Britain 
people are dying from mad cow disease, people who never consumed infected meat. 
They used medical products containing human blood, and that blood was infected 
because it was from infected people. There is no test to identify infectious 
prions, the causal agent, in blood. 
Almost none of this information appeared in news stories about the 
California mad cow. Instead the headlines and the talking heads fed us the line 
that the United States fixed this problem long ago, and the fact that only 4 mad 
cows have been detected so far is proof of our success. Oprah Winfrey once tried 
via her talk show to warn about this, way back in 1996, but Texas cattlemen 
dragged her and her guest Howard Lyman into court and she had to spend many 
millions of dollars defending herself from the supposed crime of slandering 
meat. 
Oprah won her case, which was probably unfortunate for the rest of us 
because had she been convicted the ensuing appeals court trial might have gotten 
enough attention to wake up Americans to the truth. Instead Oprah learned her 
lesson - shut up and you won't get sued. Other media learned too that if the 
government and industry can silence Oprah, they can muzzle anyone. (One of the 4 
confirmed U.S. mad cows was later found in Texas, appropriately enough.) 
There are a handful of dedicated activists such as Howard Lyman who have 
been sounding the alarm on this. They include the ecologist Dr. Michael Hansen 
of Consumers Union and Dr. Michael Greger, a physician. Terry Singeltary Sr., 
whose mom died of a version of the human form of mad cow disease, has been a 
relentless, unpaid activist on this issue. 
Despite their dedicated work, there is no indication that anything is 
going to change here in America. The U.S. government refuses to implement the 
feed ban and the animal testing necessary. It doesn't matter if the President is 
named Clinton, Bush or Obama because their bureaucrats in the USDA and FDA stay 
the course and keep the cover up going. Docile, eating what they are fed, 
trusting the rancher all the way to the slaughterhouse. Is that just the cows, 
or is it us too? 
-- John Stauber: <http://sourcewatch.org/index.php?title=John_Stauber> 
is an independent author and activist. He founded the Center for Media and 
Democracy in 1993, retiring in 2009. Way back in 1997 he co-authored Mad Cow 
USA. <http://www.prwatch.org/books/madcow.html> 
Tell the USDA to Stop the Spread of Mad Cow Disease! 
Terry Singeltary P.O. Box 42 Bacliff, TX 77518-0042 
April 25, 2012 
Administrator Gregory Parham 
12th & Jefferson Drive, SW Whitten Bldg., Room 313-E Washington, DC 
20250 Re: Docket No. APHIS-2008-0010 
Dear Administrator Parham: 
In order to stop the spread of bovine spongiform encephalopathy (BSE or 
mad cow disease), the US Department of Agriculture should adopt and enforce the 
same strict standards required by the European Union and Japan: 
* Mandatory testing for all cattle brought to slaughter, before they enter 
the food chain. 
* Ban the feeding of blood, manure, and slaughterhouse waste to animals. 
In the meantime, the USDA must stop harassing farmers and food processors 
who are interested in independently testing their own beef for mad cow disease. 
Ironically, the news that mad cow is still in our food supply comes at a 
time that the U.S. Department of Agriculture Animal and Plant Health Inspection 
Service (APHIS) is proposing to drop significant protections the U.S. has 
against the importation of cattle infected with mad cow disease. 
APHIS proposes to open United States' borders to cattle from countries 
that have had thousands of cases of BSE, and where new BSE cases continue to be 
found. The importation of a single infected cow from Canada in 2001 set in 
motion restrictions on U.S. beef exports that cost the beef industry billions of 
dollars and that still exist today in several major export markets. 
APHIS also proposes to drop important measures that have been used to 
protect U.S. consumers from these imported cattle and meat products (which have 
a much higher chance of being infected with BSE than U.S.-raised cattle), and 
intends to rely almost exclusively on slaughtering techniques, particularly the 
removal of specified risk materials (SRMs), which we know on occasion is not 
employed fully or effectively, and which has not been practiced long enough to 
determine whether it is indeed the panacea APHIS assumes, given the long 
gestation time of variant Creutzfeldt-Jakob Disease (vCJD) in humans. 
I support the view of R-CALF USA CEO Bill Bullard: 
"Seventy-six farm and consumer organizations, representing tens of 
millions of U.S. citizens, recently urged Secretary Vilsack to strengthen, not 
weaken, our already lax BSE policies by reversing the so-called 
'over-thirty-month rule,' which allows Canadian cattle born during the time the 
BSE agent was known to be circulating in Canada's feed system to be imported 
into the United States. 
"Secretary Vilsack has again ignored our concerns and is putting the 
self-interests of corporate meatpackers that want access to more meat supplies 
regardless of risk to humans and livestock, ahead of the health and safety 
concerns of U.S. citizens. 
"The USDA is touting its proposed rule as a trade rule, claiming it will 
strengthen the United States' negotiating position in trade agreements. This is 
the same failed argument the Bush Administration used when it first relaxed our 
U.S. BSE policies in 2004, and the result of that failed argument is that many 
important export markets imposed long-lasting export restrictions on U.S. beef. 
"USDA's proposal amounts to a unilateral disarmament of essential disease 
protections for U.S. citizens and livestock. It will disadvantage U.S. producers 
in the global market because other major beef exporters, including Brazil, 
Australia, and India continue to maintain adequate import standards while the 
U.S. relaxes its own. This will create unnecessary and avoidable anxieties among 
other beef consuming nations for U.S. beef. 
"Exposing U.S. consumers and U.S. livestock to a heightened risk of BSE 
introduction is irresponsible and contrary to pledges made by the Obama 
Administration during his campaign." 
This is no time to relax our essential protections against the 
introduction of mad cow disease. 
so, USDA et al accidently find two atypical mad cows in Texas and Alabama 
during the infamous enhanced BSE cover up back in 2004 and 2005, and then shut 
the testing down to numbers so low, it's almost impossible to find another mad 
cow case, unless your country is to a point that mad cow disease can be found in 
1 in 40,000, and STILL FIND MAD COW DISEASE, HOUSTON, WE HAVE A PROBLEM. ... 
PLEASE UNDERSTAND, the USDA et al are lying about atypical BSE being a 
spontaneous mutation, NOT caused by feed. spontaneous BSE has NEVER been proven 
in any natural field case of BSE. feed is the most likely route. ...tss 
As previously stated most of the characteristics of atypical BSE have not 
been defined. In addition to the origin, the risk to other cattle by means of 
natural transmission, the risk to humans and other animal species suck as 
chickens and pigs is still unknown as is the distribution of infectivity 
throughout the body of a bovine. There is little information on clinical 
manifestation if it occurs at all in certain of the cases. Documented L cases 
have been diagnosed from samples taken from older ''healthy'' cattle presented 
for routine slaughter. 
While additional surveillance and research is being conducted, it is 
important for policy make to consider the implications of atypical BSE. They may 
need to rethink what populations are appropriate targets. It would probably be 
unwise to prematurely lessen or discontinue the current BSE protection measures. 
SNIP... 
Atypical BSE: What is it and what is the significance 
Linda A. Detwiler, Paul Brown, Lisa M. McShane, and Gianluigi Zanusso 
When atypical cases were first reported there was some speculation that 
these may merely be protein accumulation disorders associated with old age. It 
has now been shown that both the Land H types of atypical BSE are at least 
experimentally transmissible. Homogenates from L cases have been transmitted to 
bovinized transgenic mice, humanized transgenic mice, Cynomolgus monkeys and 1 
breed of cattle (Buschmann et al. 2006; Book of abstracts (2006), International 
Conference on Prion Diseases, Turin, Italy). H cases have been transmitted to 
bovinized transgenic (Tgbov) and ovinized transgenic mice (Béringue et al. 
2006). The incubation times for atypical L cases of BSE were shorter in the 
Tgbov mice than classical BSE inoculated into Tgbov mice and the H cases had 
longer incubations. 
A variation or mutation of the classical BSE strain  A different route 
of exposure or exposure at an older age  A strain of Scrapie transmitted to 
cattle  Sporadic or a spontaneous occurrence of BSE At his point in time, 
there is no evidence to conclude that any of the theories are or are not a 
possibility. There is considerable interest in the sporadic theory. If a form of 
BSE were to ocnaturally, this may suggest that certain control and prevention 
measure would have to remain in place indefinitely. Proving or disproving the 
occurrence of a relatively rare sporadic disease poses a significant challenge. 
It would require between 3 and 4.5 million tests performed on brain samples 
randomly taken from cattle over 7 years of age in a country with no evidencrisk 
from orally acquired BSE. It is unlikely that any country would have the will or 
resources to perform such a study. Lacking this type of evidence, systematic 
surveillance over a long time period may provide evidence about the nature of 
atypical BSE. 
snip...see full text ; 
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. 
This study will contribute to a correct definition of specified risk 
material (SRM) in atypical BSE. The incumbent of this position will develop new 
and transfer existing, ultra-sensitive methods for the detection of atypical BSE 
in tissue of experimentally infected cattle. 
BY the way, ammonia treated beef DOES NOT KILL MAD COW DISEASE !!! 
Tuesday, April 24, 2012 
MAD COW DISEASE USA 4TH CASE DOCUMENTED ATYPICAL BSE CALIFORNIA 
Wednesday, April 25, 2012 
4th MAD COW DISEASE U.S.A. CALIFORNIA ATYPICAL L-TYPE BSE 2012 
Wednesday, April 25, 2012 
ACTUALITY - USDA Chief Veterinary Officer On Surveillance And Milk Safety 
and BSE aka MAD COW DISEASE 
Thursday, April 26, 2012 
Maternal Transmission of the BSE and Birth Cohorts 
Harvard Risk Assessment of Bovine Spongiform Encephalopathy Update, October 
31, 2005 INTRODUCTION The United States Department of Agriculture’s Food Safety 
and Inspection Service (FSIS) held a public meeting on July 25, 2006 in 
Washington, D.C. to present findings from the Harvard Risk Assessment of Bovine 
Spongiform Encephalopathy Update, October 31, 2005 (report and model located on 
the FSIS website: 
Comments on technical aspects of the risk assessment were then submitted 
to FSIS. 
Comments were received from Food and Water Watch, Food Animal Concerns 
Trust (FACT), Farm Sanctuary, R-CALF USA, Linda A Detwiler, and Terry S. 
Singeltary. 
This document provides itemized replies to the public comments received on 
the 2005 updated Harvard BSE risk assessment. Please bear the following points 
in mind: 
Owens, Julie From: Terry S. Singeltary Sr. [mailto:flounder9%40verizon.net] 
Sent: Monday, July 24, 2006 1:09 PM 
To: FSIS RegulationsComments 
Subject: [Docket No. FSIS-2006-0011] FSIS Harvard Risk Assessment of 
Bovine Spongiform Encephalopathy (BSE) Page 1 of 98 
Sunday, November 13, 2011 
California BSE mad cow beef recall, QFC, CJD, and dead stock downer 
livestock 
> > > Ackerman says downed cattle are 50 times more likely to have 
mad cow disease (also known as Bovine Spongiform Encephalopathy, or BSE) than 
ambulatory cattle that are suspected of having BSE. Of the 20 confirmed cases of 
mad cow disease in North America since 1993, at least 16 have involved downer 
cattle, he said. < < < 
don’t forget the children... 
PLEASE be aware, for 4 years, the USDA fed our children all across the 
Nation (including TEXAS) dead stock downer cows, the most high risk cattle for 
BSE aka mad cow disease and other dangerous pathogens. 
who will watch our children for CJD for the next 5+ decades ??? 
WAS your child exposed to mad cow disease via the NSLP ??? 
SCHOOL LUNCH PROGRAM FROM DOWNER CATTLE UPDATE 
DID YOUR CHILD CONSUME SOME OF THESE DEAD STOCK DOWNER COWS, THE MOST HIGH 
RISK FOR MAD COW DISEASE ??? 
you can check and see here ; 
ATYPICAL L-TYPE BASE BSE AND TRANSMISSIBLE SPONGIFORM ENCEPHALOPATHY TME, 
is there a link ??? 
4.6.1. Epidemiology TME is a disease that affected mink ranches, decimating 
the herds, in the frame of five to eleven isolated outbreaks, from 1947 to 1985, 
mainly in USA (Wisconsin was the main affected State since it is where mink 
ranches where mainly located) (Robinson et al., 1994). Moreover, eastern 
European countries (East Germany, Finland and USSR) also reported outbreaks in 
the mid-sixties. 
According to its rare occurrence associated with a massive rate of 
infection, and in the absence of probing horizontal or vertical transmission, 
the hypothesis of a food-borne infection is the most convincing explanation. 
This theory is enforced by the fact that three of those outbreaks occurred in 
large mink production facilities that prepared on-site feed involving the use of 
non-ambulatory (i.e. animal unable to stand alone) cattle (Hartsoug and Burger, 
1965; Marsh et al., 
1991). 
SNIP... 
IS THERE A SCRAPIE-LIKE DISEASE IN CATTLE ? 
In April of 1985, a mink rancher in Wisconsin reported a debilitating 
neurologic disease in his herd which we diagnosed as TME by histopathologic 
findings confirmed by experimental transmission to mink and squirrel monkeys. 
The rancher was a ''dead stock'' feeder using mostly (>95%) downer or dead 
dairy cattle and a few horses. She had never been fed. 
We believe that these findings may indicate the presence of a previously 
unrecognized scrapie-like disease in cattle and wish to alert dairy 
practitioners to this possibility. 
snip... 
PROCEEDINGS OF THE SEVENTH ANNUAL WESTERN CONFERENCE FOR FOOD ANIMAL 
VETERINARY MEDICINE, University of Arizona, March 17-19, 1986 
Saturday, December 01, 2007 
Phenotypic Similarity of Transmissible Mink Encephalopathy in Cattle and 
L-type Bovine Spongiform Encephalopathy in a Mouse Model 
Volume 13, Number 12–December 2007 Research 
Phenotypic Similarity of Transmissible Mink Encephalopathy in Cattle and 
L-type Bovine Spongiform Encephalopathy in a Mouse Model 
Thierry Baron,* Anna Bencsik,* Anne-Gaëlle Biacabe,* Eric Morignat,* 
andRichard A. Bessen†*Agence Française de Sécurité Sanitaire des Aliments–Lyon, 
Lyon, France; and†Montana State University, Bozeman, Montana, USA 
Abstract 
Transmissible mink encepholapathy (TME) is a foodborne transmissible 
spongiform encephalopathy (TSE) of ranch-raised mink; infection with a ruminant 
TSE has been proposed as the cause, but the precise origin of TME is unknown. To 
compare the phenotypes of each TSE, bovine-passaged TME isolate and 3 distinct 
natural bovine spongiform encephalopathy (BSE) agents (typical BSE, H-type BSE, 
and L-type BSE) were inoculated into an ovine transgenic mouse line (TgOvPrP4). 
Transgenic mice were susceptible to infection with bovine-passaged TME, typical 
BSE, and L-type BSE but not to H-type BSE. Based on survival periods, brain 
lesions profiles, disease-associated prion protein brain distribution, and 
biochemical properties of protease-resistant prion protein, typical BSE had a 
distint phenotype in ovine transgenic mice compared to L-type BSE and bovine 
TME.The similar phenotypic properties of L-type BSE and bovine TME in TgOvPrP4 
mice suggest that L-type BSE is a much more likely candidate for the origin of 
TME than is typical BSE. 
snip... 
Conclusion 
These studies provide experimental evidence that the Stetsonville TME 
agent is distinct from typical BSE but has phenotypic similarities to L-type BSE 
in TgOvPrP4 mice. Our conclusion is that L-type BSE is a more likely candidate 
for a bovine source of TME infection than typical BSE. In the scenario that a 
ruminant TSE is the source for TME infection in mink, this would be a second 
example of transmission of a TSE from ruminants to non-ruminants under natural 
conditions or farming practices in addition to transmission of typical BSE to 
humans, domestic cats, and exotic zoo animals(37). The potential importance of 
this finding is relevant to L-type BSE, which based on experimental transmission 
into humanized PrP transgenic mice and macaques, suggests that L-type BSE is 
more pathogenic for humans than typical BSE (24,38). 
Emmanuel Comoy,1,† Valérie Durand,1 Evelyne Correia,1 Sophie Freire,1 
Jürgen Richt,2 Justin Greenlee,3 Juan-Maria Torres,4 Paul Brown,1 Bob Hills5 and 
Jean-Philippe Deslys1
1Atomic Energy Commission; Fontenay-aux-Roses, France; 2Kansas State 
University; Manhattan, KS USA; 3USDA; Ames, IA USA; 4INIA; Madrid, Spain; 
5Health Canada; Ottawa, ON Canada†Presenting author; Email: 
emmanuel.comoy@cea.fr
The epidemiology of Transmissible mink encephalopathy (TME) indicates an 
alimentary origin. Several inter-species transmission experiments have not 
succeeded in establishing with certainty any natural reservoir of this prion 
strain, although both ovine and bovine sources have been suspected. Cattle 
exposed to TME develop a spongiform encephalopathy that is distinct from 
classical Bovine Spongiform Encephalopathy (c-BSE).
Inoculation of c-BSE to cynomolgus macaque provided early evidence of a 
possible risk to humans, and remains an important model to define the risk of 
both primary (oral transmission from cattle to primate) and secondary 
(intravenous intra-species transmission) exposures. We have also evaluated the 
transmissibility of other cattle prion strains to macaques, including L- and H- 
atypical forms of BSE, namely BSE-L and BSE-H, and cattle-adapted TME.
BSE-L induced a neurological disease distinct from c-BSE. Peripheral 
exposures demonstrate the transmissibility of BSE-L by oral, intravenous, and 
intra-cerebral routes, with incubation periods similar to c-BSE. Cattle-adapted 
TME also induced a rapid disease in cynomolgus macaque. The clinical features, 
lesion profile, and biochemical signature of the induced disease was similar to 
the features observed in animals exposed to BSE-L, suggesting a link between the 
two prion strains. Secondary transmissions to a common host (transgenic mouse 
overexpressing bovine PrP) of cattle-TME and BSE-L before or after passage in 
primates induced diseases with similar incubation periods: like the c-BSE 
strain, these cattle strains maintained their distinctive features regardless of 
the donor species and passages.
If the link between TME and BSE-L is confirmed, our results would suggest 
that BSE-L in North America may have existed for decades, and highlight a 
possible preferential transmission of animal prion strains to primates after 
passage in cattle. 
=====================end...tss==================== 
link url not available, please see PRION 2011 ; 
In Confidence - Perceptions of unconventional slow virus diseases of 
animals in the USA - APRIL-MAY 1989 - G A H Wells 
snip... 
PAGE 31 
Appendix I 
VISIT TO USA - DR A E WRATHALL - INFO ON BSE AND SCRAPIE 
1. Dr Clark lately of the Scrapie Research Unit, Mission Texas has 
successfully transmitted ovine and caprine scrapie to cattle. The experimental 
results have not been published but there are plans to do this. This work was 
initiated in 1978. A summary of it is:- 
Expt A 6 Her x Jer calves born in 1978 were inoculated as follows with a 
2nd Suffolk scrapie passage:- 
i/c 1ml i/m, 5ml; s/c 5ml; oral 30ml. 
1/6 went down after 48 months with a scrapie/BSE-like disease. 
Expt B 6 Her or Jer or HxJ calves were inoculated with angora Goat virus 
2/6 went down similarly after 36 months. 
Expt C Mice inoculated from brains of calves/cattle in expts A & B 
were resistant, only 1/20 going down with scrapie and this was the reason given 
for not publishing. 
Diagnosis in A, B, C was by histopath. No reports on SAF were given. 
Dr Warren Foote indicated success so far in eliminating scrapie in 
offspring from experimentally- (and naturally) infected sheep by ET. He had 
found difficulty in obtaining emhryos from naturally infected sheep (cf SPA). 
3. Prof. A Robertson gave a brief account of BSE. The US approach was to 
PAGE 32 
accord it a very low profile indeed. Dr A Thiermann showed the picture in 
the "Independent" with cattle being incinerated and thought this was a fanatical 
incident to be avoided in the US at all costs. BSE was not reported in USA. 
4. Scrapie incidents (ie affected flocks) have shown a dramatic increase 
since 1978. In 1953 when the National Control Scheme was started there were 
10-14 incidents, in 1978 - 1 and in 1988 so far 60. 
5. Scrapie agent was reported to have been isolated from a solitary fetus. 
6. A western blotting diagnostic technique (? on PrP} shows some promise. 
7. Results of a questionnaire sent to 33 states on the subject of the 
national sheep scrapie programme survey indicated; 
17/33 wished to drop it 6/33 wished to develop it 8/33 had few sheep and 
were neutral 
Information obtained from Dr Wrathall's notes of a meeting of the U.S. 
Animal Health Association at Little Rock, Arkansas Nov. 1988. 
please see ; 
In Confidence - Perceptions of unconventional slow virus diseases of 
animals in the USA - APRIL-MAY 1989 - G A H Wells 
Thursday, March 29, 2012 
atypical Nor-98 Scrapie has spread from coast to coast in the USA 2012 
NIAA Annual Conference April 11-14, 2011San Antonio, Texas 
*** Chronic Wasting Disease CWD CDC REPORT MARCH 2012 *** 
Saturday, February 18, 2012 
Occurrence, Transmission, and Zoonotic Potential of Chronic Wasting 
Disease 
CDC Volume 18, Number 3—March 2012 
SNIP... 
Long-term effects of CWD on cervid populations and ecosystems remain 
unclear as the disease continues to spread and prevalence increases. In captive 
herds, CWD might persist at high levels and lead to complete herd destruction in 
the absence of human culling. Epidemiologic modeling suggests the disease could 
have severe effects on free-ranging deer populations, depending on hunting 
policies and environmental persistence (8,9). CWD has been associated with large 
decreases in free-ranging mule deer populations in an area of high CWD 
prevalence (Boulder, Colorado, USA) (5). 
SNIP... 
Reasons for Caution There are several reasons for caution with respect to 
zoonotic and interspecies CWD transmission. First, there is strong evidence that 
distinct CWD strains exist (36). Prion strains are distinguished by varied 
incubation periods, clinical symptoms, PrPSc conformations, and CNS PrPSc 
depositions (3,32). Strains have been identified in other natural prion 
diseases, including scrapie, BSE, and CJD (3). Intraspecies and interspecies 
transmission of prions from CWD-positive deer and elk isolates resulted in 
identification of >2 strains of CWD in rodent models (36), indicating that 
CWD strains likely exist in cervids. However, nothing is currently known about 
natural distribution and prevalence of CWD strains. Currently, host range and 
pathogenicity vary with prion strain (28,37). Therefore, zoonotic potential of 
CWD may also vary with CWD strain. In addition, diversity in host (cervid) and 
target (e.g., human) genotypes further complicates definitive findings of 
zoonotic and interspecies transmission potentials of CWD. Intraspecies and 
interspecies passage of the CWD agent may also increase the risk for zoonotic 
CWD transmission. The CWD prion agent is undergoing serial passage naturally as 
the disease continues to emerge. In vitro and in vivo intraspecies transmission 
of the CWD agent yields PrPSc with an increased capacity to convert human PrPc 
to PrPSc (30). Interspecies prion transmission can alter CWD host range (38) and 
yield multiple novel prion strains (3,28). The potential for interspecies CWD 
transmission (by cohabitating mammals) will only increase as the disease spreads 
and CWD prions continue to be shed into the environment. This environmental 
passage itself may alter CWD prions or exert selective pressures on CWD strain 
mixtures by interactions with soil, which are known to vary with prion strain 
(25), or exposure to environmental or gut degradation. Given that prion disease 
in humans can be difficult to diagnose and the asymptomatic incubation period 
can last decades, continued research, epidemiologic surveillance, and caution in 
handling risky material remain prudent as CWD continues to spread and the 
opportunity for interspecies transmission increases. Otherwise, similar to what 
occurred in the United Kingdom after detection of variant CJD and its subsequent 
link to BSE, years of prevention could be lost if zoonotic transmission of CWD 
is subsequently identified, SNIP...SEE FULL TEXT ; 
*** Chronic Wasting Disease CWD CDC REPORT MARCH 2012 *** 
Saturday, February 18, 2012 
Occurrence, Transmission, and Zoonotic Potential of Chronic Wasting 
Disease 
CDC Volume 18, Number 3—March 2012 
see much more here ; 
Sunday, January 22, 2012 
Chronic Wasting Disease CWD cervids interspecies transmission 
Thursday, January 26, 2012 
The Risk of Prion Zoonoses 
Science 27 January 2012: Vol. 335 no. 6067 pp. 411-413 DOI: 
10.1126/science.1218167 
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 
CJD9/10022 
October 1994 
Mr R.N. Elmhirst Chairman British Deer Farmers Association Holly Lodge 
Spencers Lane BerksWell Coventry CV7 7BZ 
Dear Mr Elmhirst, 
CREUTZFELDT-JAKOB DISEASE (CJD) SURVEILLANCE UNIT REPORT 
Thank you for your recent letter concerning the publication of the third 
annual report from the CJD Surveillance Unit. I am sorry that you are 
dissatisfied with the way in which this report was published. 
The Surveillance Unit is a completely independant outside body and the 
Department of Health is committed to publishing their reports as soon as they 
become available. In the circumstances it is not the practice to circulate the 
report for comment since the findings of the report would not be amended. In 
future we can ensure that the British Deer Farmers Association receives a copy 
of the report in advance of publication. 
The Chief Medical Officer has undertaken to keep the public fully informed 
of the results of any research in respect of CJD. This report was entirely the 
work of the unit and was produced completely independantly of the the 
Department. 
The statistical results reqarding the consumption of venison was put into 
perspective in the body of the report and was not mentioned at all in the press 
release. Media attention regarding this report was low key but gave a realistic 
presentation of the statistical findings of the Unit. This approach to 
publication was successful in that consumption of venison was highlighted only 
once by the media ie. in the News at one television proqramme. 
I believe that a further statement about the report, or indeed statistical 
links between CJD and consumption of venison, would increase, and quite possibly 
give damaging credence, to the whole issue. From the low key media reports of 
which I am aware it seems unlikely that venison consumption will suffer 
adversely, if at all. 
http://web.archive.org/web/20030511010117/http://www.bseinquiry.gov.uk/files/yb/1994/10/00003001.pdf 
THIRD CJD REPORT UK 1994 
snip... 
Consumption of venison and veal was much less widespread among both cases 
and controls. For both of these meats, there was evidence of a trend with 
increasing frequency of consumption being associated with increasing risk of 
CJD. These associations were largely unchanged when attention was restricted to 
pairs with data obtained from relatives. ... 
Wednesday, March 14, 2012 
PINK SLIME, MRM’s, BSE AKA MAD COW DISEASE, AND THE USDA NSLP 
Saturday, March 5, 2011 
MAD COW ATYPICAL CJD PRION TSE CASES WITH CLASSIFICATIONS PENDING ON THE 
RISE IN NORTH AMERICA 
Sunday, February 12, 2012 
National Prion Disease Pathology Surveillance Center Cases Examined1 
(August 19, 2011) including Texas 
Wednesday, March 28, 2012 
VARIABLY PROTEASE-SENSITVE PRIONOPATHY IS TRANSMISSIBLE, price of prion 
poker goes up again $ 
Monday, August 9, 2010 
Variably protease-sensitive prionopathy: A new sporadic disease of the 
prion protein or just more PRIONBALONEY ? 
snip...see full text ; 
O.K. let's compare some recent cases of this prionpathy in other countries 
besides Gambetti's first 10 recently, that he claims is a spontaneous event, 
from a genetic disorder, that is not genetic, but sporadic, that is related to 
no animal TSE in North America, or the world. ... 
Wednesday, October 27, 2010 
A novel variant of human disease with a protease-sensitive prion protein 
and heterozygosity methionine/valine at codon 129: Case report 
Wednesday, March 28, 2012 
CJD FOUNDATION CWRU GAMBETTI FAMILIAL FAMILY AFFAIR CONFERENCE 2012 
Thursday, April 12, 2012 
Health professions and risk of sporadic Creutzfeldt–Jakob disease, 1965 to 
2010 
Eurosurveillance, Volume 17, Issue 15, 12 April 2012 
Research articles 
Tuesday, November 08, 2011 
Can Mortality Data Provide Reliable Indicators for Creutzfeldt-Jakob 
Disease Surveillance? A Study in France from 2000 to 2008 Vol. 37, No. 3-4, 2011 
Original Paper 
Conclusions:These findings raise doubt about the possibility of a reliable 
CJD surveillance only based on mortality data. 
Terry S. Singeltary Sr. on the Creutzfeldt-Jakob Disease Public Health 
Crisis 
full text with source references ; 
PLEASE REMEMBER ; 
The Akron, Ohio-based CJD Foundation said the Center for Disease Control 
revised that number in October of 2004 to about one in 9,000 CJD cases per year 
in the population group age 55 and older. 
HAVE YOU GOT YOUR CJD QUESTIONNAIRE ASKING REAL QUESTIONS PERTAINING TO 
ROUTE AND SOURCE OF THE TSE AGENT THAT KILLED YOUR LOVED ONE ??? 
if not, why not... 
Friday, November 30, 2007 
CJD QUESTIONNAIRE USA CWRU AND CJD FOUNDATION 
Monday, April 16, 2012 
Continuing Enhanced National Surveillance for Prion Diseases in the United 
States 
Wednesday, April 25, 2012 
USA MAD COW DISEASE AND CJD THERE FROM SINGELTARY ET AL 1999 - 2012 
U.S.A. 50 STATE BSE MAD COW CONFERENCE CALL Jan. 9, 2001 
Thursday, April 26, 2012
FDA Statement on USDA Announcement of Positive BSE Test Result For 
Immediate Release: April 26, 2012 
Thursday, April 26, 2012 
Update from USDA Regarding a Detection of Bovine Spongiform Encephalopathy 
(BSE) in the United States WASHINGTON bulletin at 04/26/2012 10:11 PM EDT 
How the California cow got the disease remains unknown. Government 
officials expressed confidence that contaminated food was not the source, saying 
the animal had atypical L-type BSE, a rare variant not generally associated with 
an animal consuming infected feed.
However, a BSE expert said that consumption of infected material is the 
only known way that cattle get the disease under natural conditons.
“In view of what we know about BSE after almost 20 years experience, 
contaminated feed has been the source of the epidemic,” said Paul Brown, a 
scientist retired from the National Institute of Neurological Diseases and 
Stroke.
BSE is not caused by a microbe. It is caused by the misfolding of the 
so-called “prion protein” that is a normal constituent of brain and other 
tissues. If a diseased version of the protein enters the brain somehow, it can 
slowly cause all the normal versions to become misfolded.
It is possible the disease could arise spontaneously, though such an event 
has never been recorded, Brown said. 
counterpart: Creutzfeldt-Jakob disease (CJD).
In a statement released on 24 April, Karen Ross, Secretary of the 
California Department of Food and Agriculture said, “The detection of BSE shows 
that the surveillance program in place in California and around the country is 
working.” Food safety advocates such as Yonkers, New York, -based Consumers 
Union say it’s a warning sign that surveillance is inadequate and needs to be 
stepped up.
Ross’s statement also makes a point of noting a key feature of this 
particular case: The infected cow carried what is known as ‘L-type’ BSE, a 
version of the disease that has not been detected before in the US and has so 
far not been associated with transmission through animal feed. As the policy 
debate over testing rumbles on, here is a short guide to what is known and not 
known about this rare strain and its unexpected appearance.
STATEMENT FROM CDFA SECRETARY KAREN ROSS ON USDA ANNOUNCEMENT OF DETECTION 
OF BSE Release #12-016 Print This Release
SACRAMENTO, April 24, 2012 – CDFA Secretary Karen Ross issued this 
statement following the USDA’s announcement of the detection of atypical bovine 
spongiform encephalopathy (BSE) in a California dairy cow:
“The detection of BSE shows that the surveillance program in place in 
California and around the country is working. Milk and beef remain safe to 
consume. The disease is not transmitted through milk. Because of the strength of 
the food protection system, the cow did not enter the food or feed supply. There 
are numerous safeguards in place to prevent BSE from entering the food 
chain.
“The atypical BSE designation is important because this is a very rare form 
of BSE not generally associated with an animal consuming infected feed. CDFA 
veterinarians are working with the USDA to investigate this case and to identify 
whether additional cows are at risk. Feed restrictions in place in California 
and around the country for the last 15 years minimize that risk to the greatest 
degree possible. We will provide additional information about this case as it 
becomes available.”
The USDA announcement may be viewed at: http://www.usda.gov/wps/portal/usda/usdahome?contentid=2012/04/0132.xml&contentidonly=true 
CDC - Bovine Spongiform Encephalopathy and Variant Creutzfeldt ... Dr. 
Paul Brown is Senior Research Scientist in the Laboratory of Central Nervous 
System ... Address for correspondence: Paul Brown, Building 36, Room 4A-05, 
...
CDC DR. PAUL BROWN TSE EXPERT COMMENTS 2006 
In an article today for United Press International, science reporter Steve 
Mitchell writes: 
Analysis: What that mad cow means 
By STEVE MITCHELL UPI Senior Medical Correspondent 
WASHINGTON, March 15 (UPI) -- The U.S. Department of Agriculture was quick 
to assure the public earlier this week that the third case of mad cow disease 
did not pose a risk to them, but what federal officials have not acknowledged is 
that this latest case indicates the deadly disease has been circulating in U.S. 
herds for at least a decade. 
The second case, which was detected last year in a Texas cow and which 
USDA officials were reluctant to verify, was approximately 12 years old. 
These two cases (the latest was detected in an Alabama cow) present a 
picture of the disease having been here for 10 years or so, since it is thought 
that cows usually contract the disease from contaminated feed they consume as 
calves. The concern is that humans can contract a fatal, incurable, 
brain-wasting illness from consuming beef products contaminated with the mad cow 
pathogen. 
"The fact the Texas cow showed up fairly clearly implied the existence of 
other undetected cases," Dr. Paul Brown, former medical director of the National 
Institutes of Health's Laboratory for Central Nervous System Studies and an 
expert on mad cow-like diseases, told United Press International. "The question 
was, 'How many?' and we still can't answer that." 
Brown, who is preparing a scientific paper based on the latest two mad cow 
cases to estimate the maximum number of infected cows that occurred in the 
United States, said he has "absolutely no confidence in USDA tests before one 
year ago" because of the agency's reluctance to retest the Texas cow that 
initially tested positive. 
USDA officials finally retested the cow and confirmed it was infected 
seven months later, but only at the insistence of the agency's inspector 
general. 
"Everything they did on the Texas cow makes everything they did before 
2005 suspect," Brown said. 
Despite this, Brown said the U.S. prevalence of mad cow, formally known as 
bovine spongiform encephalopathy, or BSE, did not significantly threaten human 
or cattle health. 
"Overall, my view is BSE is highly unlikely to pose any important risk 
either in cattle feed or human feed," he said. 
However, Jean Halloran of Consumers Union in Yonkers, N.Y., said consumers 
should be troubled by the USDA's secrecy and its apparent plan to dramatically 
cut back the number of mad cow tests it conducts. 
"Consumers should be very concerned about how little we know about the 
USDA's surveillance program and the failure of the USDA to reveal really 
important details," Halloran told UPI. "Consumers have to be really concerned if 
they're going to cut back the program," she added. 
Last year the USDA tested more than 300,000 animals for the disease, but 
it has proposed, even in light of a third case, scaling back the program to 
40,000 tests annually. 
"They seem to be, in terms of actions and policies, taking a lot more 
seriously the concerns of the cattle industry than the concerns of consumers," 
Halloran said. "It's really hard to know what it takes to get this 
administration to take action to protect the public." 
The USDA has insisted that the safeguards of a ban on incorporating cow 
tissue into cattle feed (which is thought to spread the disease) and removal of 
the most infectious parts of cows, such as the brain and spinal cord, protect 
consumers. But the agency glosses over the fact that both of these systems have 
been revealed to be inadequately implemented. 
The feed ban, which is enforced by the Food and Drug Administration, has 
been criticized by the Government Accountability Office in two reports, the most 
recent coming just last year. The GAO said the FDA's enforcement of the ban 
continues to have weaknesses that "undermine the nation's firewall against BSE." 
USDA documents released last year showed more than 1,000 violations of the 
regulations requiring the removal of brains and spinal cords in at least 35 
states, Puerto Rico and the Virgin Islands, with some plants being cited 
repeatedly for infractions. In addition, a violation of similar regulations that 
apply to beef exported to Japan is the reason why Japan closed its borders to 
U.S. beef in January six weeks after reopening them. 
Other experts also question the adequacy of the USDA's surveillance 
system. The USDA insists the prevalence of mad cow disease is low, but the 
agency has provided few details of its surveillance program, making it difficult 
for outside experts to know if the agency's monitoring plan is sufficient. 
"It's impossible to judge the adequacy of the surveillance system without 
having a breakdown of the tested population by age and risk status," Elizabeth 
Mumford, a veterinarian and BSE expert at Safe Food Solutions in Bern, 
Switzerland, a company that provides advice on reducing mad cow risk to industry 
and governments, told UPI. 
"Everybody would be happier and more confident and in a sense it might be 
able to go away a little bit for (the USDA) if they would just publish a 
breakdown on the tests," Mumford added. 
UPI requested detailed records about animals tested under the USDA's 
surveillance plan via the Freedom of Information Act in May 2004 but nearly two 
years later has not received any corresponding documents from the agency, 
despite a federal law requiring agencies to comply within 30 days. This leaves 
open the question of whether the USDA is withholding the information, does not 
have the information or is so haphazardly organized that it cannot locate it. 
Mumford said the prevalence of the disease in U.S. herds is probably quite 
low, but there have probably been other cases that have so far gone undetected. 
"They're only finding a very small fraction of that low prevalence," she said. 
Mumford expressed surprise at the lack of concern about the deadly disease 
from American consumers. "I would expect the U.S. public to be more concerned," 
she said. 
Markus Moser, a molecular biologist and chief executive officer of 
Prionics, a Swiss firm that manufactures BSE test kits, told UPI one concern is 
that if people are infected, the mad cow pathogen could become "humanized" or 
more easily transmitted from person to person. 
"Transmission would be much easier, through all kinds of medical 
procedures" and even through the blood supply, Moser said. 
© Copyright 2006 United Press International, Inc. All Rights Reserved 
PAUL BROWN COMMENT TO ME ON THIS ISSUE
Tuesday, September 12, 2006 11:10 AM
"Actually, Terry, I have been critical of the USDA handling of the mad cow 
issue for some years, and with Linda Detwiler and others sent lengthy detailed 
critiques and recommendations to both the USDA and the Canadian Food Agency." 
OIE says the animal was sub-clinical ;
also, officials have confirmed it was a atypical L-type BASE BSE. 
I am deeply disturbed about the false and terribly misleading information 
that is being handed out by the USDA FDA et al about this recent case of the 
atypical L-type BASE BSE case in California. these officials are terribly 
misinformed (I was told they are not lying), about the risk factor and 
transmissibility of the atypical L-type BASE BSE. these are very disturbing 
transmission studies that the CDC PUT OUT IN 2012. I urge officials to come 
forward with the rest of this story. 
It is important to reiterate here, even though this animal did not enter 
the food chain, the fact that the USA now finds mad cow disease in samplings of 
1 in 40,000 is very disturbing, and to add the fact that it was an atypical 
L-type BASE BSE, well that is very disturbing in itself. 1 out of 40,000, would 
mean that there were around 25 mad cows in the USA annually going by a National 
herd of 100 million (which now I don’t think the USA herd is that big), but then 
you add all these disturbing factors together, the documented link of sporadic 
CJD cases to atypical L-type BASE BSE, the rise in sporadic CJD cases in the USA 
of a new strain of CJD called ‘classification pending Creutzfeldt Jakob Disease’ 
cpCJD, in young and old, with long duration of clinical symptoms until death. 
the USA has a mad cow problem and have consistently covered it up. it’s called 
the SSS policy. ... 
see full text with updated transmission studies and science on the atypical 
L-type BASE BSE Jan. 2012 CDC. ... 
***Oral Transmission of L-type Bovine Spongiform Encephalopathy in Primate 
Model 
***Infectivity in skeletal muscle of BASE-infected cattle 
***feedstuffs- It also suggests a similar cause or source for atypical BSE 
in these countries. 
***Also, a link is suspected between atypical BSE and some apparently 
sporadic cases of Creutzfeldt-Jakob disease in humans. 
full text ; 
kindest regards, terry 
rookie TSE scientist with no PhDs 
SENIOR LAYPERSON 
Terry S. Singeltary Sr. P.O. Box 42 Bacliff, Texas USA 77518 
flounder9@verizon.net 

 
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