Susceptibility of European Red Deer (Cervus elaphus elaphus) to Alimentary 
Challenge with Bovine Spongiform Encephalopathy 
Mark P. Dagleish , * E-mail: mark.dagleish@moredun.ac.uk
Affiliation: Moredun Research Institute, Pentlands Science Park, Bush Loan, 
Penicuik, Near Edinburgh EH26 0PZ, United Kingdom 
⨯ Stuart Martin, Affiliation: Animal Health & Veterinary Laboratories 
Agency Lasswade, Pentlands Science Park, Bush Loan, Penicuik, Near Edinburgh 
EH26 0PZ, United Kingdom 
⨯ Philip Steele, Affiliation: Moredun Research Institute, Pentlands Science 
Park, Bush Loan, Penicuik, Near Edinburgh EH26 0PZ, United Kingdom 
⨯ Jeanie Finlayson, Affiliation: Moredun Research Institute, Pentlands 
Science Park, Bush Loan, Penicuik, Near Edinburgh EH26 0PZ, United Kingdom 
⨯ Samantha L. Eaton, Affiliation: Neurobiology Division, The Roslin 
Institute at, Royal (Dick) School of Veterinary Studies, University of 
Edinburgh, Easter Bush Campus, Midlothian, EH25 9RG, United Kingdom 
⨯ Sílvia Sisó, Affiliation: Animal Health & Veterinary Laboratories 
Agency Lasswade, Pentlands Science Park, Bush Loan, Penicuik, Near Edinburgh 
EH26 0PZ, United Kingdom 
⨯ Paula Stewart, Affiliation: Neurobiology Division, The Roslin Institute 
at, Royal (Dick) School of Veterinary Studies, University of Edinburgh, Easter 
Bush Campus, Midlothian, EH25 9RG, United Kingdom 
⨯ Natalia Fernández-Borges, Affiliation: CIC bioGUNE, Parque tecnológico de 
Bizkaia, Derio 48160, Spain 
⨯ Scott Hamilton, Affiliation: Moredun Research Institute, Pentlands 
Science Park, Bush Loan, Penicuik, Near Edinburgh EH26 0PZ, United Kingdom 
⨯ Yvonne Pang, Affiliation: Moredun Research Institute, Pentlands Science 
Park, Bush Loan, Penicuik, Near Edinburgh EH26 0PZ, United Kingdom 
⨯ Francesca Chianini, Affiliation: Moredun Research Institute, Pentlands 
Science Park, Bush Loan, Penicuik, Near Edinburgh EH26 0PZ, United Kingdom 
⨯ Hugh W. Reid, Affiliation: Moredun Research Institute, Pentlands Science 
Park, Bush Loan, Penicuik, Near Edinburgh EH26 0PZ, United Kingdom 
⨯ Wilfred Goldmann, Affiliation: Neurobiology Division, The Roslin 
Institute at, Royal (Dick) School of Veterinary Studies, University of 
Edinburgh, Easter Bush Campus, Midlothian, EH25 9RG, United Kingdom 
⨯ Lorenzo González, Affiliation: Animal Health & Veterinary 
Laboratories Agency Lasswade, Pentlands Science Park, Bush Loan, Penicuik, Near 
Edinburgh EH26 0PZ, United Kingdom 
⨯ Joaquín Castilla, Affiliations: CIC bioGUNE, Parque tecnológico de 
Bizkaia, Derio 48160, Spain, IKERBASQUE, Basque Foundation for Science, Bilbao 
48013, Bizkaia, Spain 
⨯ [ ... ], Martin Jeffrey Affiliation: Animal Health & Veterinary 
Laboratories Agency Lasswade, Pentlands Science Park, Bush Loan, Penicuik, Near 
Edinburgh EH26 0PZ, United Kingdom 
⨯ [ view all ] [ view less ] Susceptibility of European Red Deer (Cervus 
elaphus elaphus) to Alimentary Challenge with Bovine Spongiform Encephalopathy 
Mark P. Dagleish, Stuart Martin, Philip Steele, Jeanie Finlayson, Samantha L. 
Eaton, Sílvia Sisó, Paula Stewart, Natalia Fernández-Borges, … Scott Hamilton, 
Yvonne Pang PLOS x Published: January 23, 2015 DOI: 10.1371/journal.pone.0116094 
Abstract
European red deer (Cervus elaphus elaphus) are susceptible to the agent of 
bovine spongiform encephalopathy, one of the transmissible spongiform 
encephalopathies, when challenged intracerebrally but their susceptibility to 
alimentary challenge, the presumed natural route of transmission, is unknown. To 
determine this, eighteen deer were challenged via stomach tube with a large dose 
of the bovine spongiform encephalopathy agent and clinical signs, gross and 
histological lesions, presence and distribution of abnormal prion protein and 
the attack rate recorded. Only a single animal developed clinical disease, and 
this was acute with both neurological and respiratory signs, at 1726 days post 
challenge although there was significant (27.6%) weight loss in the preceding 
141 days. The clinically affected animal had histological lesions of vacuolation 
in the neuronal perikaryon and neuropil, typical of transmissible spongiform 
encephalopathies. Abnormal prion protein, the diagnostic marker of transmissible 
encephalopathies, was primarily restricted to the central and peripheral nervous 
systems although a very small amount was present in tingible body macrophages in 
the lymphoid patches of the caecum and colon. Serial protein misfolding cyclical 
amplification, an in vitro ultra-sensitive diagnostic technique, was positive 
for neurological tissue from the single clinically diseased deer. All other 
alimentary challenged deer failed to develop clinical disease and were negative 
for all other investigations. These findings show that transmission of bovine 
spongiform encephalopathy to European red deer via the alimentary route is 
possible but the transmission rate is low. Additionally, when deer carcases are 
subjected to the same regulations that ruminants in Europe with respect to the 
removal of specified offal from the human food chain, the zoonotic risk of 
bovine spongiform encephalopathy, the cause of variant Creutzfeldt-Jakob 
disease, from consumption of venison is probably very low. 
snip...
Discussion 
This investigation resulted in the first and only known case, to 
date, of clinical disease or accumulation of abnormal PrPd in any cervid species 
due to oral challenge with BSE. The increase in incubation period compared to 
European red deer challenged with BSE intra-cerebrally (1060 days) [33] compared 
to oral challenge (1727 days) is approximately 60% and similar to the 
differences observed in incubation periods for sheep or goats when challenged 
with TSE agents by these two routes [40,41]. The neurological clinical signs 
observed could be broadly related to the spongiform encephalopathy and the 
accumulation of PrPd in that the restlessness, stereotypic head movements and 
pacing may be due to compromise of the nucleus accumbens [42], found in the 
striatum, and the laboured breathing due to the lesions in the medulla, where 
the respiratory centre is located [43]. Alternatively, the laboured and audible 
mouth breathing may have been due to, or contributed to by, compromise of either 
of the recurrent laryngeal nerves resulting in some degree of laryngeal 
paralysis but we were unable to determine this. Apart from the gradual loss of 
body weight, the speed of onset of clinical signs and progression was very rapid 
but animal welfare requirements precluded any further longitudinal study of 
these. The clinical signs described for this animal are broadly similar to those 
reported for clinical BSE in European red deer challenged via the intracerebral 
route [33], clinical cases of CWD in deer [44] and clinical cases of BSE in 
cattle [45].
snip...see full text ; 
MANY THANKS TO THE AUTHORS FOR THEIR WORK ON THE TSE PRION DISEASE, AND TO 
THEM AND PLOS FOR OPEN ACCESS, THANK YOU!...TSS
2008-05-28 
***Therefore, although BSE has never been diagnosed in any deer species, a 
possible risk to human health remains via ingestion of cervine products. Chronic 
wasting disease (CWD), also a TSE, naturally infects several cervid species in 
North America and is spreading rapidly in both captive and free-ranging 
populations.
Conclusions: This study shows that deer are susceptible to BSE by 
intracerebral inoculation and display clinical signs and vacuolar pathology that 
are similar to those of CWD. ***These findings highlight the importance of 
preventing the spread to Europe of CWD from North America as this may 
necessitate even more extensive testing of animal tissues destined for human 
consumption within the EU.
***Although the absence of PrPd in lymphoid and other non-neurological 
tissues potentially limits the risk of transmission to humans, the replication 
of TSE agents in peripheral tissues following intra-cerebral challenge is often 
limited. Thus the assessment of risk posed by cervine BSE as a human pathogen or 
for environmental contamination should await the outcome of ongoing oral 
challenge experiments. 
2008-05-28 
From: TSS
Subject: EXPERIMENTAL TRANSMISSION OF BSE TO EUROPEAN RED DEER 
Date: May 29, 2008 at 11:30 am PST
Experimental transmission of bovine spongiform encephalopathy to European 
red deer (Cervus elaphus elaphus)
Bovine spongiform encephalopathy (BSE), a member of the transmissible 
spongiform encephalopathies (TSE), primarily affects cattle. Transmission is via 
concentrate feed rations contaminated with infected meat and bone meal 
(MBM).
In addition to cattle, other food animal species are susceptible to BSE and 
also pose a potential threat to human health as consumption of infected meat 
products is the cause of variant Creutzfeldt-Jakob disease in humans, which is 
invariably fatal. In the UK, farmed and free ranging deer were almost certainly 
exposed to BSE infected MBM in proprietary feeds prior to legislation banning 
its inclusion.
***Therefore, although BSE has never been diagnosed in any deer species, a 
possible risk to human health remains via ingestion of cervine products. Chronic 
wasting disease (CWD), also a TSE, naturally infects several cervid species in 
North America and is spreading rapidly in both captive and free-ranging 
populations.
Results: Here we show that European red deer (Cervus elaphus elaphus) are 
susceptible to intra-cerebral (i/c) challenge with BSE positive cattle brain 
pool material resulting in clinical neurological disease and weight loss by 
794-1290 days and the clinical signs are indistinguishable to those reported in 
deer with CWD.
Spongiform changes typical of TSE infections were present in brain and 
accumulation of the disease-associated abnormal prion protein (PrPd) was present 
in the central and peripheral nervous systems, but not in lymphoid or other 
tissues. Western immunoblot analysis of brain material showed a similar 
glycosylation pattern to that of BSE derived from infected cattle and 
experimentally infected sheep with respect to protease-resistant PrP 
isoforms.
However, the di-, mono- and unglycosylated bands migrated significantly (p 
<0 .001="" affected="" and="" brains="" bse="" cattle="" clinically="" compared="" deer="" div="" from="" further="" in="" infected="" of="" samples="" sheep.="" the="" to="" when="">
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Friday, December 14, 2012
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
0>
Conclusions: This study shows that deer are susceptible to BSE by 
intracerebral inoculation and display clinical signs and vacuolar pathology that 
are similar to those of CWD. ***These findings highlight the importance of 
preventing the spread to Europe of CWD from North America as this may 
necessitate even more extensive testing of animal tissues destined for human 
consumption within the EU.
***Although the absence of PrPd in lymphoid and other non-neurological 
tissues potentially limits the risk of transmission to humans, the replication 
of TSE agents in peripheral tissues following intra-cerebral challenge is often 
limited. Thus the assessment of risk posed by cervine BSE as a human pathogen or 
for environmental contamination should await the outcome of ongoing oral 
challenge experiments. 
Author: Mark P Dagleish, Stuart Martin, Philip Steele, Jeanie Finlayson, 
Silvia Siso, Scott Hamilton, Francesca Chianini, Hugh W Reid, Lorenzo Gonzalez 
and Martin Jeffrey Credits/Source: BMC Veterinary Research 2008, 4:17
Published on: 2008-05-28 
FDA WARNING LETTER (14-ATL-04) adulterated under Section 402(a)(4) [21 
U.S.C. 342(a)(4)] of the Act, protein derived from mammalian tissues to feeds 
that may be used for ruminants [21 C.F.R. 589.2000(e)(1)(iii)(B)] 
Newberry Feed & Farm, Inc. 2/14/14 Department of Health and Human 
Services logoDepartment of Health and Human Services Public Health Service
Food and Drug Administration Atlanta District Office 60 8th St., NE 
Atlanta, GA 30309 
February 14, 2014
VIA UPS 
J. Clint Layne, President/Co-owner Rhett Baker, 
Secretary-Treasurer/Co-owner Newberry Feed & Farm Center, Inc. 131 Giff 
Street Newberry, SC 29108
WARNING LETTER (14-ATL-04)
Dear Messrs. Layne and Baker,
An inspection of your feed mill located at 2431 Vincent Street, Newberry, 
SC 29108 conducted by Investigators from the U.S. Food & Drug Administration 
(FDA) and South Carolina Department of Agriculture on September 5-9, 2013 
revealed significant violations of Current Good Manufacturing Practice (CGMP) 
regulations for Medicated Feeds found in Title 21, Code of Federal Regulations, 
Part 225 (21 C.F.R. 225). Such violations cause the medicated feeds manufactured 
at your facility to be adulterated within the meaning of Section 501(a)(2)(B) of 
the Federal Food, Drug, and Cosmetic Act (the Act) [21 U.S.C. § 351(a)(2)(B)] in 
that the methods used in, or the facilities or controls used for the 
manufacture, processing, packing, or holding of the medicated feeds do not 
conform to or are not operated or administered in conformity with current good 
manufacturing practices. 
The inspection also revealed significant violations of the requirements set 
forth in Title 21, Code of Federal Regulations, Section 589.2000 (21 C.F.R. 
589.2000), Animal Proteins Prohibited in Ruminant Feed. This regulation is 
intended to prevent the establishment and amplification of Bovine Spongiform 
Encephalopathy (BSE). Animal feeds and feed ingredients containing prohibited 
mammalian proteins are considered potentially injurious to ruminant and public 
health. Because you failed to comply with the requirements set forth in 21 
C.F.R. 589.2000, the feed products manufactured and distributed by your facility 
are adulterated within the meaning of Section 402(a)(4) of the Act [21 U.S.C. 
342(a)(4)] in that they have been prepared, packed, or held under insanitary 
conditions whereby they may have become contaminated with filth or rendered 
injurious to health. The adulterated feed was subsequently misbranded within the 
meaning of Section 403(a)(1) of the Act [21 U.S.C. 343(a)(1)] because it was not 
properly labeled with the required BSE cautionary statement.
Medicated Feed CGMP violations observed during the inspection include, but 
are not limited to, the following:
1. You failed to ensure that all equipment that comes in contact with the 
active drug component, feeds in process or finished medicated feed is subject to 
reasonable and effective procedures to prevent unsafe contamination of feeds 
with drugs. [21 C.F.R. 225.65(b)]
Your written equipment cleaning procedure that requires flushing with a 
minimum of (b)(4) does not appear to be effective to prevent unsafe 
contamination of your manufactured feed. During the inspection, our 
Investigators observed a build-up of feed residue on surfaces inside the mixer 
that was approximately three inches thick in accumulation. This build-up was 
observed on the equipment throughout the inspection, including after flushing 
had been performed. In addition, the cleaning procedure does not include 
cleaning of the hand-add chute or scoops/buckets used to handle ingredients that 
are then used to manufacture medicated feed. During the inspection, our 
Investigators observed a build-up of feed residues approximately four inches 
thick on the inside of the chute used to add the drug ingredients and other 
“hand-adds”. Considering the extent of residue accumulation—some of which would 
include the drug sources used in your medicated feeds—on surfaces in the mixer 
and the hand-add chute, it is likely that chunks of this material break off 
periodically, and may sometimes end up in feeds not intended to contain that 
drug. 
This is a repeat observation from the July 24-26, 2012 inspection. Your 
response to the Form FDA 483, Inspectional Observations, issued to you following 
the 2012 inspection stated the buckets and scoops would be replaced, and you 
would schedule a regular cleaning of the equipment every (b)(4). Based on the 
accumulation of residual feed observed on manufacturing equipment during the 
inspection and which remained following flushing, you have either failed to 
implement the promised corrective action or you have failed to ensure that the 
corrective action was lasting and effective in preventing the violation from 
recurring.
On October 3, 2013, we received your response to the Form FDA 483 issued to 
you following the September 2013 inspection. You state in your response that you 
have posted signs, added cleaning of the dump chute to the (b)(4) cleaning 
procedure, and increased the physical cleaning of the mixer to (b)(4). You also 
state that dedicated scoops will be used for each component or drug and have 
ordered disposable liners for the buckets that will be discarded following each 
dumping of product. However, you did not provide any documentation to 
demonstrate these changes have been made, such as photos of the new sign or 
newly cleaned equipment, or copies of the revised cleaning procedure. 
2. You failed to investigate and implement corrective action where the 
results of assays indicated that the level of drug in medicated feed was not in 
accord with label specifications or not within permissible assay limits. An 
original or copy of the record of such action must be maintained on the 
premises. [21 C.F.R. 225.58(d)]
Your firm failed to adequately investigate and implement corrective action 
when you received an assay result on 6/21/13 for a Type C medicated feed 
containing Amprolium, showing the drug present at 73% of the concentration 
stated on the label. This assay result is outside of the assay limits of 80-120% 
established in 21 C.F.R. 558.4. The subsequent review of production and 
inventory records conducted by your firm revealed these records were “OK”, and 
it was determined the feed sample was taken incorrectly. Your firm’s 
“\investigation sheet” dated 6/21/13 states the corrective action as “[t]rying 
to make sure the samples are taken correctly.” No technique or procedural 
changes were made in response to the described corrective action, however. Thus, 
your firm failed to implement any corrective action in response to the out of 
specification assay result.
Your firm also received assay results for a Type C medicated broiler feed 
containing a Salinomycin concentration of 75% on 7/7/12 and 78% on 8/3/12. These 
assay results are outside the specification tolerance of 80-120% of the 
concentration stated on the label. [21 C.F.R. 558.4]. Your firm did not initiate 
any investigation or corrective action after receiving these results. Failure to 
investigate and implement corrective action following an out-of-limits assay is 
a repeat observation from the July 24-26, 2012 inspection.
In your response to the Form FDA 483 issued to you following the September 
2013 inspection, you state that you have instructed personnel further on 
completing the investigation form and have also added sampling instructions to 
the procedures manual. However, you did not provide copies of the new/revised 
investigation form or the revisions to the procedures manual discussing 
sampling. 
3. Your daily inventory records fail to record the batches or production 
runs (or lots) of medicated feed in which each drug was used. [21 C.F.R. 
225.42(b)(6)(iii)] Although your daily inventory records appear to contain all 
of the other required information, due to the way the form is designed, there is 
only space to record one batch per day per drug and no space to record the name 
of the product, lot number, or other identifier for that batch. Your daily 
inventory record must reflect every batch or lot of medicated feed manufactured 
each day.
4. You failed to document in the daily inventory record actions taken to 
reconcile any discrepancies in the daily inventory record. [21 C.F.R. 
225.42(b)(6)(v)] For example, the drug inventory conducted on 8/30/13 revealed a 
discrepancy with respect to one fifty pound bag of (b)(4)(a Type A medicated 
article). It does not appear that your firm took any action to reconcile this 
discrepancy.
You state in your response to both #3 and #4 above that you have added an 
area to the inventory control sheet to report any drugs that do not reconcile, 
and that there is a space to make notes and/or adjustments to inventory to 
ensure they reconcile. However, you did not indicate that the inventory control 
sheet had been adjusted to provide for the possibility that any single drug may 
be used more than once a day, and you did not provide any documentation—such as 
a copy of the revised form—to demonstrate that these changes have been made. 
5. You have failed to properly identify, store, handle, and control drugs 
in your mixing areas to maintain their integrity and identity [21 C.F.R. 
225.42(b)(4)]. Our inspection found that your firm was storing bags of Type A 
Medicated Articles in a manner and location that allowed them to be covered in 
bird droppings.
This finding also relates to your obligations under 21 C.F.R. 225.20(b)(2) 
and (3), which requires the facility to be maintained in a reasonably clean and 
orderly manner, and for access by birds and other pests to be minimized. During 
the September 5-6, 2013 inspection, our Investigators observed birds (greater 
than ten) nesting, flying, perched and foraging in the mill. Your response 
indicated that you are investigating ways to keep birds out of the mill, but 
that you did not yet have a plan at that time. You indicated that you would have 
a plan in place by November 1, 2013, but did not provide further information 
regarding any plan.
In addition, the following violations of the Animal Proteins Prohibited in 
Ruminant Feed regulation [21 C.F.R. 589.2000] were observed during the 
inspection:
1. You failed to use clean out procedures or other means adequate to 
prevent carryover of protein derived from mammalian tissues to feeds that may be 
used for ruminants [21 C.F.R. 589.2000(e)(1)(iii)(B)]. Your feed is therefore 
adulterated under Section 402(a)(4) [21 U.S.C. 342(a)(4)] of the Act.
Because your firm uses animal proteins prohibited from use in ruminant 
feeds, and also makes feeds for ruminants, you are required to have a cleanout 
procedure adequate to prevent carryover into ruminant feeds. As noted above, our 
Investigators observed a significant build-up of feed residues inside the feed 
mixer and the hand-add chute, which remained following your cleanout procedure. 
This equipment is used for processing both proteins derived from mammalian 
tissues and feeds for ruminants. Since flushing was ineffective in removing the 
accumulated feed from the equipment, your clean out procedure was inadequate to 
prevent carryover of protein derived from mammalian tissues to feeds intended 
for ruminant animals.
Your response indicates that your corrective actions for this item are the 
same as for Item 1 above. However, as noted above, you did not provide any 
documentation to demonstrate that the changes you discussed have been made, or 
that they were adequate to address this issue.
2. You failed to label all products which contained or may have contained 
prohibited materials and that are intended for use in animal feed with the BSE 
cautionary statement, "Do not feed to cattle or other ruminants." [21 C.F.R. 
589.2000(e)(1)(i).]
As discussed above, your clean out procedure is inadequate to prevent 
carryover of protein derived from mammalian tissues to feeds intended for 
ruminant animals. Thus, all feeds manufactured using your mixer and hand-add 
chute that did not contain the BSE cautionary statement “Do not feed to cattle 
or other ruminants,” are misbranded under Section 403(a)(1) [21 U.S.C. 
343(a)(1)] of the Act. For example, a batch of Carolina Choice Beef Conditioner 
Custom Mix (b)(4), manufactured on September 6, 2013, while there was a 
significant build-up of feed residues in the feed mixer, was misbranded as its 
label did not contain the required BSE cautionary statement. 
The above is not intended to be an all-inclusive list of violations at your 
facility. As a medicated and non-medicated feed manufacturer, you are 
responsible for assuring that your overall operation and the products you 
manufacture and distribute are in compliance with the law. You should take 
prompt action to correct these violations, and you should establish procedures 
whereby such violations do not recur. Failure to promptly correct these 
violations may result in regulatory and/or administrative sanctions. These 
sanctions include, but are not limited to, seizure, injunction, and/or notice of 
opportunity for a hearing on a proposal to withdraw approval of your Medicated 
Feed Mill License under Section 512(m)(4)(B)(ii) of the Act and 21 C.F.R. 
515.22(c)(2).
Based on the results of the September 5-9, 2013 inspection, evaluated 
together with the evidence before FDA when the Medicated Feed Mill License was 
approved, the methods used in, or the facilities and controls used for, the 
manufacture, processing, and packing of medicated feeds are inadequate to assure 
and preserve the identity, strength, quality, and purity of the new animal drugs 
therein. This letter constitutes official notification under the law and 
provides you an opportunity to correct the above described violations.
You should notify this office, in writing, within fifteen (15) working days 
of the receipt of this letter of the steps you have taken to bring your firm 
into compliance with the law. Your response should include an explanation of 
each step being taken to correct the violations and prevent their recurrence. In 
your response, please include the timeframe in which the corrections will be 
completed and provide any documentation that will effectively assist us in 
evaluating whether the corrective actions have been made and the adequacy of 
such. If you are unable to complete the corrective actions within fifteen (15) 
working days, identify the reason for the delay and the time within which you 
will complete the corrections. Include copies of any available documentation 
demonstrating that corrections have been made.
Your written response should be sent to the U.S. Food and Drug 
Administration, Attn: Janice L. King, Compliance Officer, at the address noted 
in the letterhead. If you have questions, please contact Mrs. King at 
843-746-2990 or write her at the noted address. 
Sincerely, /S/ Philip S. Campbell Acting District Director Atlanta District 
Office 
cc: South Carolina Department of Agriculture, Phillip C. Trefsgar 
HOLY MAD COW BATMAN, how much went out into commerce, how much was 
recovered, what species are consuming these adulterated under Section 402(a)(4) 
[21 U.S.C. 342(a)(4)] of the Act, protein derived from mammalian tissues to 
feeds that may be used for ruminants [21 C.F.R. 589.2000(e)(1)(iii)(B)] ??? 
1. You failed to use clean out procedures or other means adequate to 
prevent carryover of protein derived from mammalian tissues to feeds that may be 
used for ruminants [21 C.F.R. 589.2000(e)(1)(iii)(B)]. Your feed is therefore 
adulterated under Section 402(a)(4) [21 U.S.C. 342(a)(4)] of the Act.
Because your firm uses animal proteins prohibited from use in ruminant 
feeds, and also makes feeds for ruminants, you are required to have a cleanout 
procedure adequate to prevent carryover into ruminant feeds. As noted above, our 
Investigators observed a significant build-up of feed residues inside the feed 
mixer and the hand-add chute, which remained following your cleanout procedure. 
This equipment is used for processing both proteins derived from mammalian 
tissues and feeds for ruminants. Since flushing was ineffective in removing the 
accumulated feed from the equipment, your clean out procedure was inadequate to 
prevent carryover of protein derived from mammalian tissues to feeds intended 
for ruminant animals.
Your response indicates that your corrective actions for this item are the 
same as for Item 1 above. However, as noted above, you did not provide any 
documentation to demonstrate that the changes you discussed have been made, or 
that they were adequate to address this issue.
2. You failed to label all products which contained or may have contained 
prohibited materials and that are intended for use in animal feed with the BSE 
cautionary statement, "Do not feed to cattle or other ruminants." [21 C.F.R. 
589.2000(e)(1)(i).]
As discussed above, your clean out procedure is inadequate to prevent 
carryover of protein derived from mammalian tissues to feeds intended for 
ruminant animals. Thus, all feeds manufactured using your mixer and hand-add 
chute that did not contain the BSE cautionary statement “Do not feed to cattle 
or other ruminants,” are misbranded under Section 403(a)(1) [21 U.S.C. 
343(a)(1)] of the Act. For example, a batch of Carolina Choice Beef Conditioner 
Custom Mix (b)(4), manufactured on September 6, 2013, while there was a 
significant build-up of feed residues in the feed mixer, was misbranded as its 
label did not contain the required BSE cautionary statement...end...TSS 
Rocky Ford Pet Foods 8/27/13
Department of Health and Human Services logoDepartment of Health and Human 
Services Public Health Service
Food and Drug Administration 
  Denver District Office
Bldg. 20-Denver Federal Center
P.O. Box 25087
6th Avenue & Kipling Street
Denver, Colorado 80225-0087
Telephone: 303-236-3000
FAX:              303-236-3100  
August 27, 2013
 WARNING LETTER
VIA UPS Overnight
Mr. Juan Manuel Villegas
Owner
Rocky Ford Pet Foods
21693 Highway 50 East
Rocky Ford, CO 81067
Ref. #: DEN-13-20-WL
Dear Mr. Villegas:
On February 25-27, 2013, the U.S. Food and Drug Administration (FDA) 
conducted an inspection of your rendering facility located at 21693 Highway 50 
East, Rocky Ford, Colorado. This inspection revealed significant deviations from 
the requirements set forth in FDA regulations intended to reduce the risk of 
bovine spongiform encephalopathy (BSE) within the United States. These 
regulations are found in Title 21 of the Code of Federal Regulations (CFR), 
Section 589.2000 (21 CFR 589.2000), Animal Proteins Prohibited in Ruminant Feed, 
and Section 589.2001 (21 CFR 589.2001), Cattle Materials Prohibited in Animal 
Food or Feed to Prevent the Transmission of Bovine Spongiform Encephalopathy. 
These regulations address how renderers process (1) mammalian proteins 
prohibited from use in ruminant food or feed and (2) materials designated as 
“cattle materials prohibited in animal food or feed” (CMPAF) which are 
prohibited from use in animal food or feed. CMPAF include, but are not limited 
to:
The brain and spinal cord of cattle 30 months of age or older; 
The entire carcass of cattle infected with BSE; and 
The entire carcass of cattle 30 months of age or older that have not been 
inspected and passed for human consumption if the brains and spinal cords were 
not removed or otherwise effectively excluded from animal feed.
Your facility processes CMPAF.
Your failure to follow certain requirements of these regulations, as 
described below, resulted in products manufactured and distributed by your 
facilities being adulterated within the meaning of Section 402(a)(4) of the 
Federal Food, Drug, and Cosmetic Act (the Act), [21 U.S.C. 342(a)(4)] and 
misbranded within the meaning of Section 403(f) of the Act, [21 U.S.C. 343(f)].  
You can find the Act, and its implementing regulations on the Internet through 
links on the FDA’s web page at www.fda.gov1.
Our inspection revealed the following serious deviations from the 
regulations at your rendering facility:
Failure to prevent the inclusion of cattle materials prohibited in animal 
feed (CMPAF) in animal feed or feed ingredients, as required by 21 CFR 
589.2001(c)(1). Specifically, on February 25, 2013, our investigator observed 
that the unmarked CMPAF posterior sections of vertebral columns for two cows, 
identified by your firm as older than 30 months of age, were separated from the 
rest of the marked CMPAF material from those animals. The unmarked CMPAF 
material was then commingled with 18 additional posterior vertebral columns and 
placed in a trailer for shipment to another renderer for further processing and 
possible use in animal feed.
You removed all 20 posterior vertebral columns from the trailer during the 
inspection and stated that you would dispose of them in a landfill.
Failure to maintain adequate written procedures specifying how the process 
of removing the brain and spinal cord from cattle not inspected and passed for 
human consumption or 30 months of age or older is carried out, as required by 21 
CFR 589.2001(c)(2)(ii).  Specifically, your written procedure “Rocky Ford Ped 
[sic] Food Standard Operating Procedure for handling 30 month and older Beef and 
CMPAF Products” indicates that the head, vertebral column, and rib cage for 
cattle 30 months of age and older are kept in one piece. This written procedure 
is not consistent with actual operations observed at your firm on February 26, 
2013. Our investigator observed that posterior vertebral columns from two cows 
30 months of age or older were separated from the animals’ heads and anterior 
vertebral columns; the posterior sections were not marked as CMPAF material. 
Your written procedures fail to specify how, for animals 30 months of age or 
older, posterior vertebral columns separated from marked anterior vertebral 
columns would themselves be marked as CMPAF material.   
Failure to mark the CMPAF and products that contain or may contain CMPAF 
with an agent that can be readily detected on visual inspection, as required by 
21 CFR 589.2001(c)(2)(v). Specifically, the posterior sections of vertebra 
columns from cattle identified by your firm as 30 months of age or older were 
separated from the head and anterior vertebral columns but then were not 
identified as CMPAF with an agent readily detectable on visual examination. 
Therefore, the CMPAF posterior vertebral columns were indistinguishable from the 
non-CMPAF posterior vertebral columns.
Failure to label containers, including vehicles when used as containers, 
which contain CMPAF with the required statement, “Do not feed to animals,” as 
required by 21 CFR 589.2001(c)(2)(iv). Specifically, the dump truck and trailer 
used for storage and transport of CMPAF materials did not bear the statement “Do 
not feed to animals.”
Failure to avoid cross-contamination once CMPAF have been separated from 
other cattle materials as required by 21 CFR 589.2001(c)(2)(iii). Specifically, 
both marked and unmarked CMPAF were observed to be stored on the floor of the 
processing area rather than in separate containers that adequately prevent 
contact with animal feed, animal feed ingredients, or equipment surfaces, 21 CFR 
589.2001(c)(2)(iii)(B). As described in item #1 above, the unmarked materials 
were indistinguishable from non-CMPAF materials and could result in 
cross-contamination.
This letter is not intended to serve as an all-inclusive list of violations 
at your facility. As a manufacturer of materials intended for animal feed use, 
you are responsible for ensuring your overall operation and the products you 
manufacture and distribute are in compliance with the law. You should take 
prompt action to correct these violations, and you should establish a system 
whereby violations do not recur. Failure to promptly correct these violations 
may result in regulatory action, such as seizure and/or injunction, without 
further notice.
You should notify this office in writing of the steps you have taken to 
bring your firm into compliance with the law within fifteen (15) working days of 
receiving this letter. Your response should include each step that has been 
taken or will be taken to correct the violations and prevent their recurrence. 
If corrective action cannot be completed within fifteen (15) working days, state 
the reason for the delay and the timeframe within which the corrections will be 
completed. Please include copies of supporting documentation demonstrating that 
corrections have been made.
Your written response should be sent to: U.S. Food and Drug Administration, 
P.O. Box 25087, 6th Ave. and Kipling St., DFC, Bldg 20, Denver, CO 80225-0087, 
Attn: Sarah A. Della Fave, Compliance Officer. If you have any questions about 
this letter, please contact Ms. Della Fave at (303) 236-3006.          
Sincerely,
/S/ 
LaTonya Mitchell
District Director
cc:    Ronald K. Jones, D.V.M.
         Denver District Manager
         USDA/FSIS
         PO Box 25387
         DFC, Bldg 45
         Denver, CO 80225
        Laurel Hamling
        Colorado Department of Agriculture
        Feed Program
        2331 W. 31st Avenue
        Denver, CO 80211
-
Close Out Letter
Rocky Ford Pet Foods - Close Out Letter 4/16/142 
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. *** 
see page 176 of 201 pages...tss 
*** Singeltary reply ; 
Molecular, Biochemical and Genetic Characteristics of BSE in Canada 
*** Singeltary reply ; 
31 Jan 2015 at 20:14 GMT 
Friday, December 14, 2012
DEFRA U.K. What is the risk of Chronic Wasting Disease CWD being introduced 
into Great Britain? A Qualitative Risk Assessment October 2012 
snip... 
In the USA, under the Food and Drug Administration’s BSE Feed Regulation 
(21 CFR 589.2000) most material (exceptions include milk, tallow, and gelatin) 
from deer and elk is prohibited for use in feed for ruminant animals. With 
regards to feed for non-ruminant animals, under FDA law, CWD positive deer may 
not be used for any animal feed or feed ingredients. For elk and deer considered 
at high risk for CWD, the FDA recommends that these animals do not enter the 
animal feed system. However, this recommendation is guidance and not a 
requirement by law. 
Animals considered at high risk for CWD include: 
1) animals from areas declared to be endemic for CWD and/or to be CWD 
eradication zones and 
2) deer and elk that at some time during the 60-month period prior to 
slaughter were in a captive herd that contained a CWD-positive animal. 
Therefore, in the USA, materials from cervids other than CWD positive 
animals may be used in animal feed and feed ingredients for non-ruminants. 
The amount of animal PAP that is of deer and/or elk origin imported from 
the USA to GB can not be determined, however, as it is not specified in TRACES. 
It may constitute a small percentage of the 8412 kilos of non-fish origin 
processed animal proteins that were imported from US into GB in 2011. 
Overall, therefore, it is considered there is a __greater than negligible 
risk___ that (nonruminant) animal feed and pet food containing deer and/or elk 
protein is imported into GB. 
There is uncertainty associated with this estimate given the lack of data 
on the amount of deer and/or elk protein possibly being imported in these 
products. 
snip... 
36% in 2007 (Almberg et al., 2011). In such areas, population declines of 
deer of up to 30 to 50% have been observed (Almberg et al., 2011). In areas of 
Colorado, the prevalence can be as high as 30% (EFSA, 2011). The clinical signs 
of CWD in affected adults are weight loss and behavioural changes that can span 
weeks or months (Williams, 2005). In addition, signs might include excessive 
salivation, behavioural alterations including a fixed stare and changes in 
interaction with other animals in the herd, and an altered stance (Williams, 
2005). These signs are indistinguishable from cervids experimentally infected 
with bovine spongiform encephalopathy (BSE). Given this, if CWD was to be 
introduced into countries with BSE such as GB, for example, infected deer 
populations would need to be tested to differentiate if they were infected with 
CWD or BSE to minimise the risk of BSE entering the human food-chain via 
affected venison. 
snip... 
The rate of transmission of CWD has been reported to be as high as 30% and 
can approach 100% among captive animals in endemic areas (Safar et al., 2008). 
snip... 
In summary, in endemic areas, there is a medium probability that the soil 
and surrounding environment is contaminated with CWD prions and in a 
bioavailable form. In rural areas where CWD has not been reported and deer are 
present, there is a greater than negligible risk the soil is contaminated with 
CWD prion. 
snip... 
In summary, given the volume of tourists, hunters and servicemen moving 
between GB and North America, the probability of at least one person travelling 
to/from a CWD affected area and, in doing so, contaminating their clothing, 
footwear and/or equipment prior to arriving in GB is greater than negligible. 
For deer hunters, specifically, the risk is likely to be greater given the 
increased contact with deer and their environment. However, there is significant 
uncertainty associated with these estimates. 
snip... 
Therefore, it is considered that farmed and park deer may have a higher 
probability of exposure to CWD transferred to the environment than wild deer 
given the restricted habitat range and higher frequency of contact with tourists 
and returning GB residents. 
snip... 
Friday, December 14, 2012 
DEFRA U.K. What is the risk of Chronic Wasting Disease CWD being introduced 
into Great Britain? A Qualitative Risk Assessment October 2012 
*** The potential impact of prion diseases on human health was greatly 
magnified by the recognition that interspecies transfer of BSE to humans by beef 
ingestion resulted in vCJD. While changes in animal feed constituents and 
slaughter practices appear to have curtailed vCJD, there is concern that CWD of 
free-ranging deer and elk in the U.S. might also cross the species barrier. 
Thus, consuming venison could be a source of human prion disease. Whether BSE 
and CWD represent interspecies scrapie transfer or are newly arisen prion 
diseases is unknown. Therefore, the possibility of transmission of prion disease 
through other food animals cannot be ruled out. There is evidence that vCJD can 
be transmitted through blood transfusion. There is likely a pool of unknown size 
of asymptomatic individuals infected with vCJD, and there may be asymptomatic 
individuals infected with the CWD equivalent. These circumstances represent a 
potential threat to blood, blood products, and plasma supplies. 
==================================
In the USA, under the Food and Drug Administration’s BSE Feed Regulation 
(21 CFR 589.2000) most material (exceptions include milk, tallow, and gelatin) 
from deer and elk is prohibited for use in feed for ruminant animals. With 
regards to feed for non-ruminant animals, under FDA law, CWD positive deer may 
not be used for any animal feed or feed ingredients. For elk and deer considered 
at high risk for CWD, the FDA recommends that these animals do not enter the 
animal feed system. 
***However, this recommendation is guidance and not a requirement by law. 
================================= 
Draft Guidance on Use of Material From Deer and Elk in Animal Feed; CVM 
Updates on Deer and Elk Withdrawn FDA Veterinarian Newsletter July/August 2003 
Volume XVIII, No 4
FDA has announced the availability of a draft guidance for industry 
entitled “Use of Material from Deer and Elk in Animal Feed.” This draft guidance 
document (GFI #158), when finalized, will describe FDA’s current thinking 
regarding the use in animal feed of material from deer and elk that are positive 
for Chronic Wasting Disease (CWD) or that are at high risk for CWD.
CWD is a neurological (brain) disease of farmed and wild deer and elk that 
belong in the cervidae animal family (cervids). Only deer and elk are known to 
be susceptible to CWD by natural transmission. The disease has been found in 
farmed and wild mule deer, white-tailed deer, North American elk, and farmed 
black-tailed deer. CWD belongs to a family of animal and human diseases called 
transmissible spongiform encephalopathies (TSEs). TSEs are very rare, but are 
always fatal.
This draft Level 1 guidance, when finalized, will represent the Agency’s 
current thinking on the topic. It does not create or confer any rights for or on 
any person and does not operate to bind FDA or the public. An alternate method 
may be used as long as it satisfies the requirements of applicable statutes and 
regulations.
Draft guidance #158 is posted on the FDA/Center for Veterinary Medicine 
Home Page. Single copies of the draft guidance may be obtained from the FDA 
Veterinarian.
- - Page Last Updated: 04/16/2013 
CONTAINS NON-BINDING RECOMMENDATIONS
158
Guidance for Industry
Use of Material from Deer and Elk in Animal Feed
Comments and suggestions regarding the document should be submitted to 
Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 
Fishers Lane, Rm. 1061, Rockville, MD 20852. Submit electronic comments to http://www.regulations.gov. All comments 
should be identified with the Docket No. 03D-0186.
For questions regarding this guidance, contact Burt Pritchett, Center for 
Veterinary Medicine (HFV- 222), Food and Drug Administration, 7519 Standish 
Place, Rockville, MD 20855, 240-453-6860, E-mail: burt.pritchett@fda.hhs.gov. 
Additional copies of this guidance document may be requested from the 
Communications Staff (HFV-12), Center for Veterinary Medicine, Food and Drug 
Administration, 7519 Standish Place, Rockville, MD 20855, and may be viewed on 
the Internet at http://www.fda.gov/AnimalVeterinary/GuidanceComplianceEnforcement/GuidanceforIndustry/default.htm.
U.S. Department of Health and Human Services
Food and Drug Administration Center for Veterinary Medicine September 15, 
2003
CONTAINS NON-BINDING RECOMMENDATIONS
158
Guidance for Industry1
Use of Material from Deer and Elk in Animal Feed
This guidance represents the Food and Drug Administration’s current 
thinking on the use of material from deer and elk in animal feed. It does not 
create or confer any rights for or on any person and does not operate to bind 
FDA or the public. You can use an alternative approach if the approach satisfies 
the requirements of applicable statutes or regulations. If you want to discuss 
an alternative approach, contact the FDA staff responsible for implementing this 
guidance. If you cannot identify the appropriate FDA staff, call the appropriate 
number listed on the title page of this guidance. 
I. Introduction 
FDA’s guidance documents, including this guidance, do not establish legally 
enforceable responsibilities. Instead, guidances describe the Agency’s current 
thinking on a topic and should be viewed only as recommendations, unless 
specific regulatory or statutory requirements are cited. The use of the word 
“should” in Agency guidances means that something is suggested or recommended, 
but not required. 
Under FDA’s BSE feed regulation (21 CFR 589.2000) most material from deer 
and elk is prohibited for use in feed for ruminant animals. This guidance 
document describes FDA’s recommendations regarding the use in all animal feed of 
all material from deer and elk that are positive for Chronic Wasting Disease 
(CWD) or are considered at high risk for CWD. The potential risks from CWD to 
humans or non-cervid animals such as poultry and swine are not well understood. 
However, because of recent recognition that CWD is spreading rapidly in 
white-tailed deer, and because CWD’s route of transmission is poorly understood, 
FDA is making recommendations regarding the use in animal feed of rendered 
materials from deer and elk that are CWD-positive or that are at high risk for 
CWD.
II. Background
CWD is a neurological (brain) disease of farmed and wild deer and elk that 
belong in the animal family cervidae (cervids). Only deer and elk are known to 
be susceptible to CWD by natural transmission. The disease has been found in 
farmed and wild mule deer,
1 This guidance has been prepared by the Division of Animal Feeds in the 
Center for Veterinary Medicine (CVM) at the Food and Drug Administration.
1
CONTAINS NON-BINDING RECOMMENDATIONS
2
white-tailed deer, North American elk, and in farmed black-tailed deer. CWD 
belongs to a family of animal and human diseases called transmissible spongiform 
encephalopathies (TSEs). These include bovine spongiform encephalopathy (BSE or 
“mad cow” disease) in cattle; scrapie in sheep and goats; and classical and 
variant Creutzfeldt-Jakob diseases (CJD and vCJD) in humans. There is no known 
treatment for these diseases, and there is no vaccine to prevent them. In 
addition, although validated postmortem diagnostic tests are available, there 
are no validated diagnostic tests for CWD that can be used to test for the 
disease in live animals.
III.
Use in animal feed of material from CWD-positive deer and elk
Material from CWD-positive animals may not be used in any animal feed or 
feed ingredients. Pursuant to Sec. 402(a)(5) of the Federal Food, Drug, and 
Cosmetic Act, animal feed and feed ingredients containing material from a 
CWD-positive animal would be considered adulterated. FDA recommends that any 
such adulterated feed or feed ingredients be recalled or otherwise removed from 
the marketplace.
IV.
Use in animal feed of material from deer and elk considered at high risk 
for CWD
Deer and elk considered at high risk for CWD include: (1) animals from 
areas declared by State officials to be endemic for CWD and/or to be CWD 
eradication zones; and (2) deer and elk that at some time during the 60-month 
period immediately before the time of slaughter were in a captive herd that 
contained a CWD-positive animal.
FDA recommends that materials from deer and elk considered at high risk for 
CWD no longer be entered into the animal feed system. Under present 
circumstances, FDA is not recommending that feed made from deer and elk from a 
non-endemic area be recalled if a State later declares the area endemic for CWD 
or a CWD eradication zone. In addition, at this time, FDA is not recommending 
that feed made from deer and elk believed to be from a captive herd that 
contained no CWD-positive animals be recalled if that herd is subsequently found 
to contain a CWD-positive animal. V. Use in animal feed of material from deer 
and elk NOT considered at high risk for CWD
FDA continues to consider materials from deer and elk NOT considered at 
high risk for CWD to be acceptable for use in NON-RUMINANT animal feeds in 
accordance with current agency regulations, 21 CFR 589.2000. Deer and elk not 
considered at high risk include: (1) deer and elk from areas not declared by 
State officials to be endemic for CWD and/or to be CWD eradication zones; and 
(2) deer and elk that were not at some time during the 60-month period 
immediately before the time of slaughter in a captive herd that contained a 
CWD-positive animal. 
that voluntary mad cow feed ban that became law, how did that work out for 
us $ 
***e) "Big Jim's" BBB Deer Ration, Big Buck Blend, Recall # V-104-6; 
***
ENFORCEMENT REPORT FOR AUGUST 2, 2006 
please note, considering .005 grams is lethal, I do not know how much of 
this 125 TONS of banned mad cow protein was part of the ;
e) "Big Jim's" BBB Deer Ration, Big Buck Blend, Recall # V-104-6; 
bbbut, this was about 10 years post mad cow feed ban from 1997. 10 years 
later, and still feeding banned mad cow protein to cervids??? 
considering that .005 gram is lethal to several bovines, and we know that 
the oral consumption of CWD tainted products is very efficient mode of 
transmission of CWD. 
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 
### 
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. *** 
see page 176 of 201 pages...tss 
*** Singeltary reply ; Molecular, Biochemical and Genetic Characteristics 
of BSE in Canada Singeltary reply ; 
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 
2013
Sunday, December 15, 2013 
FDA PART 589 -- SUBSTANCES PROHIBITED FROM USE IN ANIMAL FOOD OR FEED 
VIOLATIONS OFFICIAL ACTION INDICATED OIA UPDATE DECEMBER 2013 UPDATE
Tuesday, December 23, 2014 
FDA PART 589 -- SUBSTANCES PROHIBITED FROM USE IN ANIMAL FOOD OR FEED 
VIOLATIONS OFFICIAL ACTION INDICATED OAI UPDATE DECEMBER 2014 BSE TSE PRION 
 DOCKET-- 03D-0186 -- FDA Issues Draft Guidance on Use of Material From 
Deer and Elk in Animal Feed; Availability Date: Fri, 16 May 2003 11:47:37 -0500 
EMC 1 Terry S. Singeltary Sr. Vol #: 1 http://www.fda.gov/ohrms/dockets/dailys/03/Jun03/060903/060903.htm
 PLEASE SEE FULL TEXT SUBMISSION ; http://madcowfeed.blogspot.com/2008/07/docket-03d-0186-fda-issues-draft.html 
> First transmission of CWD to transgenic mice over-expressing bovine 
prion protein gene (TgSB3985) 
PRION 2014 - PRIONS: EPIGENETICS and NEURODEGENERATIVE DISEASES – Shaping 
up the future of prion research
Animal TSE Workshop 10.40 – 11.05 Talk Dr. L. Cervenakova First 
transmission of CWD to transgenic mice over-expressing bovine prion protein gene 
(TgSB3985) 
P.126: Successful transmission of chronic wasting disease (CWD) into mice 
over-expressing bovine prion protein (TgSB3985) 
Larisa Cervenakova,1 Christina J Sigurdson,2 Pedro Piccardo,3 Oksana 
Yakovleva,1 Irina Vasilyeva,1 Jorge de Castro,1 Paula Saá,1 and Anton Cervenak1 
1American Red Cross, Holland Laboratory; Rockville, MD USA; 2University of 
California; San Diego, CA USA; 3Lab TSE/OBRR /CBER/FDA; Rockville, MD USA 
Keywords: chronic wasting disease, transmission, transgenic mouse, bovine 
prion protein 
Background. CWD is a disease affecting wild and farmraised cervids in North 
America. Epidemiological studies provide no evidence of CWD transmission to 
humans. Multiple attempts have failed to infect transgenic mice expressing human 
PRNP gene with CWD. The extremely low efficiency of PrPCWD to convert normal 
human PrPC in vitro provides additional evidence that transmission of CWD to 
humans cannot be easily achieved. However, a concern about the risk of CWD 
transmission to humans still exists. This study aimed to establish and 
characterize an experimental model of CWD in TgSB3985 mice with the following 
attempt of transmission to TgHu mice. 
Materials and Methods. TgSB3985 mice and wild-type FVB/ NCrl mice were 
intracranially injected with 1% brain homogenate from a CWD-infected Tga20 mouse 
(CWD/Tga20). TgSB3985 and TgRM (over-expressing human PrP) were similarly 
injected with 5% brain homogenates from CWD-infected white-tailed deer (CWD/WTD) 
or elk (CWD/Elk). Animals were observed for clinical signs of neurological 
disease and were euthanized when moribund. Brains and spleens were removed from 
all mice for PrPCWD detection by Western blotting (WB). A histological analysis 
of brains from selected animals was performed: brains were scored for the 
severity of spongiform change, astrogliosis, and PrPCWD deposition in ten brain 
regions. 
Results. Clinical presentation was consistent with TSE. More than 90% of 
TgSB3985 and wild-type mice infected with CWD/Tga20, tested positive for PrPres 
in the brain but only mice in the latter group carried PrPCWD in their spleens. 
We found evidence for co-existence or divergence of two CWD/ Tga20 strains based 
on biochemical and histological profiles. In TgSB3985 mice infected with CWD-elk 
or CWD-WTD, no animals tested positive for PrPCWD in the brain or in the spleen 
by WB. However, on neuropathological examination we found presence of amyloid 
plaques that stained positive for PrPCWD in three CWD/WTD- and two 
CWD/Elk-infected TgSB3985 mice. The neuropathologic profiles in CWD/WTD- and 
CWD/Elkinfected mice were similar but unique as compared to profiles of BSE, 
BSE-H or CWD/Tg20 agents propagated in TgSB3985 mice. None of CWD-infected TgRM 
mice tested positive for PrPCWD by WB or by immunohistochemical detection. 
Conclusions. To our knowledge, this is the first established experimental 
model of CWD in TgSB3985. We found evidence for co-existence or divergence of 
two CWD strains adapted to Tga20 mice and their replication in TgSB3985 mice. 
Finally, we observed phenotypic differences between cervid-derived CWD and 
CWD/Tg20 strains upon propagation in TgSB3985 mice. Further studies are underway 
to characterize these strains. 
Thursday, November 21, 2013 
*** Assessing the susceptibility of transgenic mice over-expressing deer 
prion protein to bovine spongiform encephalopathy 
The present study was designed to assess the susceptibility of the 
prototypic mouse line, Tg(CerPrP)1536+/- to bovine spongiform encephalopathy 
(BSE) prions, which have the ability to overcome species barriers. 
Tg(CerPrP)1536+/- mice challenged with red deer-adapted BSE resulted in a 
90-100% attack rates, BSE from cattle failed to transmit, indicating agent 
adaptation in the deer. 
TSS 
UPDATED CORRESPONDENCE FROM AUTHORS OF THIS STUDY I.E. COLBY, PRUSINER ET 
AL, ABOUT MY CONCERNS OF THE DISCREPANCY BETWEEN THEIR FIGURES AND MY FIGURES OF 
THE STUDIES ON CWD TRANSMISSION TO CATTLE ; 
CWD to cattle figures CORRECTION 
Greetings, 
I believe the statement and quote below is incorrect ; 
"CWD has been transmitted to cattle after intracerebral inoculation, 
although the infection rate was low (4 of 13 animals [Hamir et al. 2001]). This 
finding raised concerns that CWD prions might be transmitted to cattle grazing 
in contaminated pastures." 
Please see ; 
Within 26 months post inoculation, 12 inoculated animals had lost weight, 
revealed abnormal clinical signs, and were euthanatized. Laboratory tests 
revealed the presence of a unique pattern of the disease agent in tissues of 
these animals. These findings demonstrate that when CWD is directly inoculated 
into the brain of cattle, 86% of inoculated cattle develop clinical signs of the 
disease. 
" although the infection rate was low (4 of 13 animals [Hamir et al. 
2001]). " 
shouldn't this be corrected, 86% is NOT a low rate. ... 
kindest regards, 
Terry S. Singeltary Sr. P.O. Box 42 Bacliff, Texas USA 77518 
Thank you!
Thanks so much for your updates/comments. We intend to publish as rapidly 
as possible all updates/comments that contribute substantially to the topic 
under discussion. 
re-Prions David W. Colby1,* and Stanley B. Prusiner1,2 + Author 
Affiliations 
1Institute for Neurodegenerative Diseases, University of California, San 
Francisco, San Francisco, California 94143 2Department of Neurology, University 
of California, San Francisco, San Francisco, California 94143 Correspondence: 
stanley@ind.ucsf.edu 
Mule deer, white-tailed deer, and elk have been reported to develop CWD. As 
the only prion disease identified in free-ranging animals, CWD appears to be far 
more communicable than other forms of prion disease. CWD was first described in 
1967 and was reported to be a spongiform encephalopathy in 1978 on the basis of 
histopathology of the brain. Originally detected in the American West, CWD has 
spread across much of North America and has been reported also in South Korea. 
In captive populations, up to 90% of mule deer have been reported to be positive 
for prions (Williams and Young 1980). The incidence of CWD in cervids living in 
the wild has been estimated to be as high as 15% (Miller et al. 2000). The 
development of transgenic (Tg) mice expressing cervid PrP, and thus susceptible 
to CWD, has enhanced detection of CWD and the estimation of prion titers 
(Browning et al. 2004; Tamgüney et al. 2006). Shedding of prions in the feces, 
even in presymptomatic deer, has been identified as a likely source of infection 
for these grazing animals (Williams and Miller 2002; Tamgüney et al. 2009b). CWD 
has been transmitted to cattle after intracerebral inoculation, although the 
infection rate was low (4 of 13 animals [Hamir et al. 2001]). This finding 
raised concerns that CWD prions might be transmitted to cattle grazing in 
contaminated pastures. 
snip... 
----- Original Message ----- 
From: David Colby To: flounder9@verizon.net 
Cc: stanley@XXXXXXXX 
Sent: Tuesday, March 01, 2011 8:25 AM 
Subject: Re: FW: re-Prions David W. Colby1,* and Stanley B. Prusiner1,2 + 
Author Affiliations 
Dear Terry Singeltary, 
Thank you for your correspondence regarding the review article Stanley 
Prusiner and I recently wrote for Cold Spring Harbor Perspectives. Dr. Prusiner 
asked that I reply to your message due to his busy schedule. We agree that the 
transmission of CWD prions to beef livestock would be a troubling development 
and assessing that risk is important. In our article, we cite a peer-reviewed 
publication reporting confirmed cases of laboratory transmission based on 
stringent criteria. The less stringent criteria for transmission described in 
the abstract you refer to lead to the discrepancy between your numbers and ours 
and thus the interpretation of the transmission rate. We stand by our assessment 
of the literature--namely that the transmission rate of CWD to bovines appears 
relatively low, but we recognize that even a low transmission rate could have 
important implications for public health and we thank you for bringing attention 
to this matter. Warm Regards, David Colby -- David Colby, PhDAssistant Professor 
Department of Chemical Engineering University of Delaware 
===========END...TSS============== 
SNIP...SEE FULL TEXT ; 
UPDATED DATA ON 2ND CWD STRAIN Wednesday, September 08, 2010 CWD PRION 
CONGRESS SEPTEMBER 8-11 2010 
Sunday, August 19, 2012 
Susceptibility of cattle to the agent of chronic wasting disease from elk 
after intracranial inoculation 2012 
Research Project: TRANSMISSION, DIFFERENTIATION, AND PATHOBIOLOGY OF 
TRANSMISSIBLE SPONGIFORM ENCEPHALOPATHIES Location: Virus and Prion Research 
Unit 
these cattle ranchers supporting these shooting pens, if there are any, 
could be in terrible shape if a strain of cwd was to jump to cattle...just 
saying.
Title: Transmission of chronic wasting disease of mule deer to Suffolk 
sheep following intracerebral inoculation 
Authors 
item Hamir, Amirali item Kunkle, Robert item Cutlip, Randall - ARS RETIRED 
item Miller, Janice - ARS RETIRED item Williams, Elizabeth - UNIV OF WYOMING, 
LARAMIE item Richt, Juergen 
Submitted to: Journal of Veterinary Diagnostic Investigation Publication 
Type: Peer Reviewed Journal Publication Acceptance Date: June 20, 2006 
Publication Date: November 1, 2006 Citation: Hamir, A.N., Kunkle, R.A., Cutlip, 
R.C., Miller, J.M., Williams, E.S., Richt, J.A. 2006. Transmission of chronic 
wasting disease of mule deer to Suffolk sheep following intracerebral 
inoculation. Journal of Veterinary Diagnostic Investigation. 18(6):558-565. 
Interpretive Summary: Chronic wasting disease (CWD) has been identified in 
captive and free ranging deer and elk since 1967. To determine the 
transmissibility of CWD to sheep and to provide information about the disease 
and tests for detection of CWD in sheep, 8 lambs were inoculated with brain 
suspension from mule deer naturally affected with CWD. Two other lambs were kept 
as controls. Only 1 sheep developed clinical disease at 35 months after 
inoculation. The study was terminated at 72 months after the inoculation. At 
that time one other sheep was found to be positive for the disease. It is 
proposed that the host's genetic makeup may play a role in transmission of the 
disease to domestic sheep. Impact. This is the first study which shows that it 
is possible to transmit CWD to a small number of sheep. Technical Abstract: 
Chronic wasting disease (CWD) has been identified in captive and free-ranging 
cervids since 1967. To determine the transmissibility of CWD to sheep and to 
provide information about clinical course, lesions, and suitability of currently 
used diagnostic procedures for detection of CWD in sheep, 8 Suffolk lambs (4 QQ 
and 4 QR at codon 171 of prion protein (PRNP) gene) were inoculated 
intracerebrally with brain suspension from mule deer naturally affected with CWD 
(CWD**md). Two other lambs (1 QQ and 1 QR at codon 171 of PRNP gene) were kept 
as non-inoculated controls. Within 36 months post inoculation (MPI), 2 animals 
became recumbent and were euthanized. However, only 1 sheep (euthanized at 35 
MPI) had shown clinical signs that were consistent with those of scrapie. 
Microscopic lesions of spongiform encephalopathy (SE) were seen in this sheep 
and its tissues were positive for the abnormal prion protein (PrPres) by 
immunohistochemistry and Western blot. Retrospective examination of the PRNP 
genotype of this animal revealed that it was heterozygous (AV) at codon 136. In 
the next 24 months, 3 other sheep were euthanized because of conditions 
unrelated to TSE. The remaining 3 sheep remained non-clinical at the termination 
of the study (72 MPI) and were euthanized at that time. One of these 3 revealed 
SE and its tissues were positive for PrPres. These findings demonstrate that it 
is possible to transmit CWD**md agent to sheep via the intracerebral route. 
However, the host genotype may play a significant part in successful 
transmission and incubation period of this agent. 
Thus far, among domestic animals, CWDmd has been transmitted by the 
intracerebral route to a goat18 and cattle.5–7 The present findings demonstrate 
that it is also possible to transmit CWDmd agent to sheep via the intracerebral 
route. However, the only sheep to develop clinical TSE within 35 MPI was 
genotypically AV at PRNP codon 136, suggesting that host genotype may play a 
notable part in successful transmission of the disease in this species. Although 
in Suffolk sheep the AV variant at codon 136 is very rare,17 selective breeding 
of Suffolk sheep with this codon has begun in the hope of testing this 
differential susceptibility hypothesis in a future study of CWDmd transmission 
to sheep. 
2012 
PO-039: A comparison of scrapie and chronic wasting disease in white-tailed 
deer 
Justin Greenlee, Jodi Smith, Eric Nicholson US Dept. Agriculture; 
Agricultural Research Service, National Animal Disease Center; Ames, IA USA 
snip...
The results of this study suggest that there are many similarities in the 
manifestation of CWD and scrapie in WTD after IC inoculation including early and 
widespread presence of PrPSc in lymphoid tissues, clinical signs of depression 
and weight loss progressing to wasting, and an incubation time of 21-23 months. 
Moreover, western blots (WB) done on brain material from the obex region have a 
molecular profile similar to CWD and distinct from tissues of the cerebrum or 
the scrapie inoculum. However, results of microscopic and IHC examination 
indicate that there are differences between the lesions expected in CWD and 
those that occur in deer with scrapie: amyloid plaques were not noted in any 
sections of brain examined from these deer and the pattern of immunoreactivity 
by IHC was diffuse rather than plaque-like. 
*** After a natural route of exposure, 100% of WTD were susceptible to 
scrapie. 
Deer developed clinical signs of wasting and mental depression and were 
necropsied from 28 to 33 months PI. Tissues from these deer were positive for 
PrPSc by IHC and WB. Similar to IC inoculated deer, samples from these deer 
exhibited two different molecular profiles: samples from obex resembled CWD 
whereas those from cerebrum were similar to the original scrapie inoculum. On 
further examination by WB using a panel of antibodies, the tissues from deer 
with scrapie exhibit properties differing from tissues either from sheep with 
scrapie or WTD with CWD. Samples from WTD with CWD or sheep with scrapie are 
strongly immunoreactive when probed with mAb P4, however, samples from WTD with 
scrapie are only weakly immunoreactive. In contrast, when probed with mAb’s 6H4 
or SAF 84, samples from sheep with scrapie and WTD with CWD are weakly 
immunoreactive and samples from WTD with scrapie are strongly positive. This 
work demonstrates that WTD are highly susceptible to sheep scrapie, but on first 
passage, scrapie in WTD is differentiable from CWD. 
2011 
*** After a natural route of exposure, 100% of white-tailed deer were 
susceptible to scrapie. 
***please read this*** 
98 | Veterinary Record | January 24, 2015
EDITORIAL
Scrapie: a particularly persistent pathogen
Cristina Acín
Resistant prions in the environment have been the sword of Damocles for 
scrapie control and eradication. Attempts to establish which physical and 
chemical agents could be applied to inactivate or moderate scrapie infectivity 
were initiated in the 1960s and 1970s,with the first study of this type focusing 
on the effect of heat treatment in reducing prion infectivity (Hunter and 
Millson 1964). Nowadays, most of the chemical procedures that aim to inactivate 
the prion protein are based on the method developed by Kimberlin and 
collaborators (1983). This procedure consists of treatment with 20,000 parts per 
million free chlorine solution, for a minimum of one hour, of all surfaces that 
need to be sterilised (in laboratories, lambing pens, slaughterhouses, and so 
on). Despite this, veterinarians and farmers may still ask a range of questions, 
such as ‘Is there an official procedure published somewhere?’ and ‘Is there an 
international organisation which recommends and defines the exact method of 
scrapie decontamination that must be applied?’
From a European perspective, it is difficult to find a treatment that could 
be applied, especially in relation to the disinfection of surfaces in lambing 
pens of affected flocks. A 999/2001 EU regulation on controlling spongiform 
encephalopathies (European Parliament and Council 2001) did not specify a 
particular decontamination measure to be used when an outbreak of scrapie is 
diagnosed. There is only a brief recommendation in Annex VII concerning the 
control and eradication of transmissible spongiform encephalopathies (TSE 
s).
Chapter B of the regulation explains the measures that must be applied if 
new caprine animals are to be introduced to a holding where a scrapie outbreak 
has previously been diagnosed. In that case, the statement indicates that 
caprine animals can be introduced ‘provided that a cleaning and disinfection of 
all animal housing on the premises has been carried out following 
destocking’.
Issues around cleaning and disinfection are common in prion prevention 
recommendations, but relevant authorities, veterinarians and farmers may have 
difficulties in finding the specific protocol which applies. The European Food 
and Safety Authority (EFSA ) published a detailed report about the efficacy of 
certain biocides, such as sodium hydroxide, sodium hypochlorite, guanidine and 
even a formulation of copper or iron metal ions in combination with hydrogen 
peroxide, against prions (EFSA 2009). The report was based on scientific 
evidence (Fichet and others 2004, Lemmer and others 2004, Gao and others 2006, 
Solassol and others 2006) but unfortunately the decontamination measures were 
not assessed under outbreak conditions.
The EFSA Panel on Biological Hazards recently published its conclusions on 
the scrapie situation in the EU after 10 years of monitoring and control of the 
disease in sheep and goats (EFSA 2014), and one of the most interesting findings 
was the Icelandic experience regarding the effect of disinfection in scrapie 
control. The Icelandic plan consisted of: culling scrapie-affected sheep or the 
whole flock in newly diagnosed outbreaks; deep cleaning and disinfection of 
stables, sheds, barns and equipment with high pressure washing followed by 
cleaning with 500 parts per million of hypochlorite; drying and treatment with 
300 ppm of iodophor; and restocking was not permitted for at least two years. 
Even when all of these measures were implemented, scrapie recurred on several 
farms, indicating that the infectious agent survived for years in the 
environment, even as many as 16 years after restocking (Georgsson and others 
2006).
In the rest of the countries considered in the EFSA (2014) report, 
recommendations for disinfection measures were not specifically defined at the 
government level. In the report, the only recommendation that is made for sheep 
is repopulation with sheep with scrapie-resistant genotypes. This reduces the 
risk of scrapie recurrence but it is difficult to know its effect on the 
infection.
Until the EFSA was established (in May 2003), scientific opinions about TSE 
s were provided by the Scientific Steering Committee (SSC) of the EC, whose 
advice regarding inactivation procedures focused on treating animal waste at 
high temperatures (150°C for three hours) and high pressure alkaline hydrolysis 
(SSC 2003). At the same time, the TSE Risk Management Subgroup of the Advisory 
Committee on Dangerous Pathogens (ACDP) in the UK published guidance on safe 
working and the prevention of TSE infection. Annex C of the ACDP report 
established that sodium hypochlorite was considered to be effective, but only if 
20,000 ppm of available chlorine was present for at least one hour, which has 
practical limitations such as the release of chlorine gas, corrosion, 
incompatibility with formaldehyde, alcohols and acids, rapid inactivation of its 
active chemicals and the stability of dilutions (ACDP 2009).
In an international context, the World Organisation for Animal Health (OIE) 
does not recommend a specific disinfection protocol for prion agents in its 
Terrestrial Code or Manual. Chapter 4.13 of the Terrestrial Code, General 
recommendations on disinfection and disinsection (OIE 2014), focuses on 
foot-and-mouth disease virus, mycobacteria and Bacillus anthracis, but not on 
prion disinfection. Nevertheless, the last update published by the OIE on bovine 
spongiform encephalopathy (OIE 2012) indicates that few effective 
decontamination techniques are available to inactivate the agent on surfaces, 
and recommends the removal of all organic material and the use of sodium 
hydroxide, or a sodium hypochlorite solution containing 2 per cent available 
chlorine, for more than one hour at 20ºC.
The World Health Organization outlines guidelines for the control of TSE s, 
and also emphasises the importance of mechanically cleaning surfaces before 
disinfection with sodium hydroxide or sodium hypochlorite for one hour (WHO 
1999).
Finally, the relevant agencies in both Canada and the USA suggest that the 
best treatments for surfaces potentially contaminated with prions are sodium 
hydroxide or sodium hypochlorite at 20,000 ppm. This is a 2 per cent solution, 
while most commercial household bleaches contain 5.25 per cent sodium 
hypochlorite. It is therefore recommended to dilute one part 5.25 per cent 
bleach with 1.5 parts water (CDC 2009, Canadian Food Inspection Agency 
2013).
So what should we do about disinfection against prions? First, it is 
suggested that a single protocol be created by international authorities to 
homogenise inactivation procedures and enable their application in all 
scrapie-affected countries. Sodium hypochlorite with 20,000 ppm of available 
chlorine seems to be the procedure used in most countries, as noted in a paper 
summarised on p 99 of this issue of Veterinary Record (Hawkins and others 2015). 
But are we totally sure of its effectiveness as a preventive measure in a 
scrapie outbreak? Would an in-depth study of the recurrence of scrapie disease 
be needed?
What we can conclude is that, if we want to fight prion diseases, and 
specifically classical scrapie, we must focus on the accuracy of diagnosis, 
monitoring and surveillance; appropriate animal identification and control of 
movements; and, in the end, have homogeneous and suitable protocols to 
decontaminate and disinfect lambing barns, sheds and equipment available to 
veterinarians and farmers. Finally, further investigations into the resistance 
of prion proteins in the diversity of environmental surfaces are required.
References
snip...
98 | Veterinary Record | January 24, 2015
Persistence of ovine scrapie infectivity in a farm environment following 
cleaning and decontamination 
Steve A. C. Hawkins, MIBiol, Pathology Department1, Hugh A. Simmons, BVSc 
MRCVS, MBA, MA Animal Services Unit1, Kevin C. Gough, BSc, PhD2 and Ben C. 
Maddison, BSc, PhD3 + Author Affiliations
1Animal and Plant Health Agency, Woodham Lane, New Haw, Addlestone, Surrey 
KT15 3NB, UK 2School of Veterinary Medicine and Science, The University of 
Nottingham, Sutton Bonington, Loughborough, Leicestershire LE12 5RD, UK 3ADAS 
UK, School of Veterinary Medicine and Science, The University of Nottingham, 
Sutton Bonington, Loughborough, Leicestershire LE12 5RD, UK E-mail for 
correspondence: ben.maddison@adas.co.uk Abstract Scrapie of sheep/goats and 
chronic wasting disease of deer/elk are contagious prion diseases where 
environmental reservoirs are directly implicated in the transmission of disease. 
In this study, the effectiveness of recommended scrapie farm decontamination 
regimens was evaluated by a sheep bioassay using buildings naturally 
contaminated with scrapie. Pens within a farm building were treated with either 
20,000 parts per million free chorine solution for one hour or were treated with 
the same but were followed by painting and full re-galvanisation or replacement 
of metalwork within the pen. Scrapie susceptible lambs of the PRNP genotype 
VRQ/VRQ were reared within these pens and their scrapie status was monitored by 
recto-anal mucosa-associated lymphoid tissue. All animals became infected over 
an 18-month period, even in the pen that had been subject to the most stringent 
decontamination process. These data suggest that recommended current guidelines 
for the decontamination of farm buildings following outbreaks of scrapie do 
little to reduce the titre of infectious scrapie material and that environmental 
recontamination could also be an issue associated with these premises. 
SNIP...
Discussion
Thorough pressure washing of a pen had no effect on the amount of 
bioavailable scrapie infectivity (pen B). The routine removal of prions from 
surfaces within a laboratory setting is treatment for a minimum of one hour with 
20,000 ppm free chlorine, a method originally based on the use of brain 
macerates from infected rodents to evaluate the effectiveness of decontamination 
(Kimberlin and others 1983). Further studies have also investigated the 
effectiveness of hypochlorite disinfection of metal surfaces to simulate the 
decontamination of surgical devices within a hospital setting. Such treatments 
with hypochlorite solution were able to reduce infectivity by 5.5 logs to lower 
than the sensitivity of the bioassay used (Lemmer and others 2004). Analogous 
treatment of the pen surfaces did not effectively remove the levels of scrapie 
infectivity over that of the control pens, indicating that this method of 
decontamination is not effective within a farm setting. This may be due to the 
high level of biological matrix that is present upon surfaces within the farm 
environment, which may reduce the amount of free chlorine available to 
inactivate any infectious prion. Remarkably 1/5 sheep introduced into pen D had 
also became scrapie positive within nine months, with all animals in this pen 
being RAMALT positive by 18 months of age. Pen D was no further away from the 
control pen (pen A) than any of the other pens within this barn. Localised hot 
spots of infectivity may be present within scrapie-contaminated environments, 
but it is unlikely that pen D area had an amount of scrapie contamination that 
was significantly different than the other areas within this building. 
Similarly, there were no differences in how the biosecurity of pen D was 
maintained, or how this pen was ventilated compared with the other pens. This 
observation, perhaps, indicates the slower kinetics of disease uptake within 
this pen and is consistent with a more thorough prion removal and 
recontamination. These observations may also account for the presence of 
inadvertent scrapie cases within other studies, where despite stringent 
biosecurity, control animals have become scrapie positive during challenge 
studies using barns that also housed scrapie-affected animals (Ryder and others 
2009). The bioassay data indicate that the exposure of the sheep to a farm 
environment after decontamination efforts thought to be effective in removing 
scrapie is sufficient for the animals to become infected with scrapie. The main 
exposure routes within this scenario are likely to be via the oral route, during 
feeding and drinking, and respiratory and conjunctival routes. It has been 
demonstrated that scrapie infectivity can be efficiently transmitted via the 
nasal route in sheep (Hamir and others 2008), as is the case for CWD in both 
murine models and in white-tailed deer (Denkers and others 2010, 2013). 
Recently, it has also been demonstrated that CWD prions presented as dust when 
bound to the soil mineral montmorillonite can be infectious via the nasal route 
(Nichols and others 2013). When considering pens C and D, the actual source of 
the infectious agent in the pens is not known, it is possible that biologically 
relevant levels of prion survive on surfaces during the decontamination regimen 
(pen C). With the use of galvanising and painting (pen D) covering and sealing 
the surface of the pen, it is possible that scrapie material recontaminated the 
pens by the movement of infectious prions contained within dusts originating 
from other parts of the barn that were not decontaminated or from other areas of 
the farm.
Given that scrapie prions are widespread on the surfaces of affected farms 
(Maddison and others 2010a), irrespective of the source of the infectious prions 
in the pens, this study clearly highlights the difficulties that are faced with 
the effective removal of environmentally associated scrapie infectivity. This is 
likely to be paralleled in CWD which shows strong similarities to scrapie in 
terms of both the dissemination of prions into the environment and the facile 
mode of disease transmission. These data further contribute to the understanding 
that prion diseases can be highly transmissible between susceptible individuals 
not just by direct contact but through highly stable environmental reservoirs 
that are refractory to decontamination.
The presence of these environmentally associated prions in farm buildings 
make the control of these diseases a considerable challenge, especially in 
animal species such as goats where there is lack of genetic resistance to 
scrapie and, therefore, no scope to re-stock farms with animals that are 
resistant to scrapie.
Scrapie Sheep Goats Transmissible spongiform encephalopathies (TSE) 
Accepted October 12, 2014. Published Online First 31 October 2014 
Monday, November 3, 2014 
Persistence of ovine scrapie infectivity in a farm environment following 
cleaning and decontamination
PPo3-22:
Detection of Environmentally Associated PrPSc on a Farm with Endemic 
Scrapie
Ben C. Maddison,1 Claire A. Baker,1 Helen C. Rees,1 Linda A. Terry,2 Leigh 
Thorne,2 Susan J. Belworthy2 and Kevin C. Gough3 1ADAS-UK LTD; Department of 
Biology; University of Leicester; Leicester, UK; 2Veterinary Laboratories 
Agency; Surry, KT UK; 3Department of Veterinary Medicine and Science; University 
of Nottingham; Sutton Bonington, Loughborough UK
Key words: scrapie, evironmental persistence, sPMCA
Ovine scrapie shows considerable horizontal transmission, yet the routes of 
transmission and specifically the role of fomites in transmission remain poorly 
defined. Here we present biochemical data demonstrating that on a 
scrapie-affected sheep farm, scrapie prion contamination is widespread. It was 
anticipated at the outset that if prions contaminate the environment that they 
would be there at extremely low levels, as such the most sensitive method 
available for the detection of PrPSc, serial Protein Misfolding Cyclic 
Amplification (sPMCA), was used in this study. We investigated the distribution 
of environmental scrapie prions by applying ovine sPMCA to samples taken from a 
range of surfaces that were accessible to animals and could be collected by use 
of a wetted foam swab. Prion was amplified by sPMCA from a number of these 
environmental swab samples including those taken from metal, plastic and wooden 
surfaces, both in the indoor and outdoor environment. At the time of sampling 
there had been no sheep contact with these areas for at least 20 days prior to 
sampling indicating that prions persist for at least this duration in the 
environment. These data implicate inanimate objects as environmental reservoirs 
of prion infectivity which are likely to contribute to disease transmission. 
*** We conclude that TSE infectivity is likely to survive burial for long 
time periods with minimal loss of infectivity and limited movement from the 
original burial site. However PMCA results have shown that there is the 
potential for rainwater to elute TSE related material from soil which could lead 
to the contamination of a wider area. These experiments reinforce the importance 
of risk assessment when disposing of TSE risk materials. 
*** The results show that even highly diluted PrPSc can bind efficiently to 
polypropylene, stainless steel, glass, wood and stone and propagate the 
conversion of normal prion protein. For in vivo experiments, hamsters were ic 
injected with implants incubated in 1% 263K-infected brain homogenate. Hamsters, 
inoculated with 263K-contaminated implants of all groups, developed typical 
signs of prion disease, whereas control animals inoculated with non-contaminated 
materials did not.
PRION 2014 CONFERENCE
CHRONIC WASTING DISEASE CWD 
A FEW FINDINGS ; 
Conclusions. To our knowledge, this is the first established experimental 
model of CWD in TgSB3985. We found evidence for co-existence or divergence of 
two CWD strains adapted to Tga20 mice and their replication in TgSB3985 mice. 
Finally, we observed phenotypic differences between cervid-derived CWD and 
CWD/Tg20 strains upon propagation in TgSB3985 mice. Further studies are underway 
to characterize these strains. 
We conclude that TSE infectivity is likely to survive burial for long time 
periods with minimal loss of infectivity and limited movement from the original 
burial site. However PMCA results have shown that there is the potential for 
rainwater to elute TSE related material from soil which could lead to the 
contamination of a wider area. These experiments reinforce the importance of 
risk assessment when disposing of TSE risk materials. 
The results show that even highly diluted PrPSc can bind efficiently to 
polypropylene, stainless steel, glass, wood and stone and propagate the 
conversion of normal prion protein. For in vivo experiments, hamsters were ic 
injected with implants incubated in 1% 263K-infected brain homogenate. Hamsters, 
inoculated with 263K-contaminated implants of all groups, developed typical 
signs of prion disease, whereas control animals inoculated with non-contaminated 
materials did not.
Our data establish that meadow voles are permissive to CWD via peripheral 
exposure route, suggesting they could serve as an environmental reservoir for 
CWD. Additionally, our data are consistent with the hypothesis that at least two 
strains of CWD circulate in naturally-infected cervid populations and provide 
evidence that meadow voles are a useful tool for CWD strain typing. 
Conclusion. CWD prions are shed in saliva and urine of infected deer as 
early as 3 months post infection and throughout the subsequent >1.5 year 
course of infection. In current work we are examining the relationship of 
prionemia to excretion and the impact of excreted prion binding to surfaces and 
particulates in the environment.
Conclusion. CWD prions (as inferred by prion seeding activity by RT-QuIC) 
are shed in urine of infected deer as early as 6 months post inoculation and 
throughout the subsequent disease course. Further studies are in progress 
refining the real-time urinary prion assay sensitivity and we are examining more 
closely the excretion time frame, magnitude, and sample variables in 
relationship to inoculation route and prionemia in naturally and experimentally 
CWD-infected cervids.
Conclusions. Our results suggested that the odds of infection for CWD is 
likely controlled by areas that congregate deer thus increasing direct 
transmission (deer-to-deer interactions) or indirect transmission 
(deer-to-environment) by sharing or depositing infectious prion proteins in 
these preferred habitats. Epidemiology of CWD in the eastern U.S. is likely 
controlled by separate factors than found in the Midwestern and endemic areas 
for CWD and can assist in performing more efficient surveillance efforts for the 
region.
Conclusions. During the pre-symptomatic stage of CWD infection and 
throughout the course of disease deer may be shedding multiple LD50 doses per 
day in their saliva. CWD prion shedding through saliva and excreta may account 
for the unprecedented spread of this prion disease in nature. 
see full text and more ; 
Monday, June 23, 2014 
*** PRION 2014 CONFERENCE CHRONIC WASTING DISEASE CWD 
*** Infectious agent of sheep scrapie may persist in the environment for at 
least 16 years*** 
Gudmundur Georgsson1, Sigurdur Sigurdarson2 and Paul Brown3 
New studies on the heat resistance of hamster-adapted scrapie agent: 
Threshold survival after ashing at 600°C suggests an inorganic template of 
replication 
Prion Infected Meat-and-Bone Meal Is Still Infectious after Biodiesel 
Production 
Detection of protease-resistant cervid prion protein in water from a 
CWD-endemic area 
A Quantitative Assessment of the Amount of Prion Diverted to Category 1 
Materials and Wastewater During Processing 
Rapid assessment of bovine spongiform encephalopathy prion inactivation by 
heat treatment in yellow grease produced in the industrial manufacturing process 
of meat and bone meals 
Sunday, December 21, 2014 
Mucosal immunization with an attenuated Salmonella vaccine partially 
protects white-tailed deer from chronic wasting disease 
Friday, December 19, 2014 
Pan-Provincial Vaccine Enterprise Inc. (PREVENT) Conducting a Chronic 
Wasting Disease (CWD) Vaccine Efficacy Trial in Elk 
CHRONIC WASTING DISEASE CWD TSE PRION, how much does it pay to find CWD 
$$$
CWD, spreading it around...
for the game farm industry, and their constituents, to continue to believe 
that they are _NOT_, and or insinuate that they have _NEVER_ been part of the 
problem, will only continue to help spread cwd. the game farming industry, from 
the shooting pens, to the urine mills, the antler mills, the sperm mills, velvet 
mills, shooting pens, to large ranches, are not the only problem, but it is 
painfully obvious that they have been part of the problem for decades and 
decades, just spreading it around, as with transportation and or exportation and 
or importation of cervids from game farming industry, and have been proven to 
spread cwd. no one need to look any further than South Korea blunder ; 
=========================================== 
spreading cwd around...
Between 1996 and 2002, chronic wasting disease was diagnosed in 39 herds of 
farmed elk in Saskatchewan in a single epidemic. All of these herds were 
depopulated as part of the Canadian Food Inspection Agency’s (CFIA) disease 
eradication program. Animals, primarily over 12 mo of age, were tested for the 
presence CWD prions following euthanasia. Twenty-one of the herds were linked 
through movements of live animals with latent CWD from a single infected source 
herd in Saskatchewan, 17 through movements of animals from 7 of the secondarily 
infected herds. 
***The source herd is believed to have become infected via importation of 
animals from a game farm in South Dakota where CWD was subsequently diagnosed 
(7,4). A wide range in herd prevalence of CWD at the time of herd depopulation 
of these herds was observed. Within-herd transmission was observed on some 
farms, while the disease remained confined to the introduced animals on other 
farms. 
spreading cwd around...
Friday, May 13, 2011 
Chronic Wasting Disease (CWD) outbreaks and surveillance program in the 
Republic of Korea 
Chronic Wasting Disease (CWD) outbreaks and surveillance program in the 
Republic of Korea 
Hyun-Joo Sohn, Yoon-Hee Lee, Min-jeong Kim, Eun-Im Yun, Hyo-Jin Kim, 
Won-Yong Lee, Dong-Seob Tark, In- Soo Cho, Foreign Animal Disease Research 
Division, National Veterinary Research and Quarantine Service, Republic of Korea 
Chronic wasting disease (CWD) has been recognized as an important prion 
disease in native North America deer and Rocky mountain elks. The disease is a 
unique member of the transmissible spongiform encephalopathies (TSEs), which 
naturally affects only a few species. CWD had been limited to USA and Canada 
until 2000. 
On 28 December 2000, information from the Canadian government showed that a 
total of 95 elk had been exported from farms with CWD to Korea. These consisted 
of 23 elk in 1994 originating from the so-called “source farm” in Canada, and 72 
elk in 1997, which had been held in pre export quarantine at the “source 
farm”.Based on export information of CWD suspected elk from Canada to Korea, CWD 
surveillance program was initiated by the Ministry of Agriculture and Forestry 
(MAF) in 2001. 
All elks imported in 1997 were traced back, however elks imported in 1994 
were impossible to identify. CWD control measures included stamping out of all 
animals in the affected farm, and thorough cleaning and disinfection of the 
premises. In addition, nationwide clinical surveillance of Korean native 
cervids, and improved measures to ensure reporting of CWD suspect cases were 
implemented. 
Total of 9 elks were found to be affected. CWD was designated as a 
notifiable disease under the Act for Prevention of Livestock Epidemics in 2002. 
Additional CWD cases - 12 elks and 2 elks - were diagnosed in 2004 and 
2005. 
Since February of 2005, when slaughtered elks were found to be positive, 
all slaughtered cervid for human consumption at abattoirs were designated as 
target of the CWD surveillance program. Currently, CWD laboratory testing is 
only conducted by National Reference Laboratory on CWD, which is the Foreign 
Animal Disease Division (FADD) of National Veterinary Research and Quarantine 
Service (NVRQS). 
In July 2010, one out of 3 elks from Farm 1 which were slaughtered for the 
human consumption was confirmed as positive. Consequently, all cervid – 54 elks, 
41 Sika deer and 5 Albino deer – were culled and one elk was found to be 
positive. Epidemiological investigations were conducted by Veterinary 
Epidemiology Division (VED) of NVRQS in collaboration with provincial veterinary 
services. 
Epidemiologically related farms were found as 3 farms and all cervid at 
these farms were culled and subjected to CWD diagnosis. Three elks and 5 
crossbreeds (Red deer and Sika deer) were confirmed as positive at farm 2. 
All cervids at Farm 3 and Farm 4 – 15 elks and 47 elks – were culled and 
confirmed as negative. 
Further epidemiological investigations showed that these CWD outbreaks were 
linked to the importation of elks from Canada in 1994 based on circumstantial 
evidences. 
In December 2010, one elk was confirmed as positive at Farm 5. 
Consequently, all cervid – 3 elks, 11 Manchurian Sika deer and 20 Sika deer – 
were culled and one Manchurian Sika deer and seven Sika deer were found to be 
positive. This is the first report of CWD in these sub-species of deer. 
Epidemiological investigations found that the owner of the Farm 2 in CWD 
outbreaks in July 2010 had co-owned the Farm 5. 
In addition, it was newly revealed that one positive elk was introduced 
from Farm 6 of Jinju-si Gyeongsang Namdo. All cervid – 19 elks, 15 crossbreed 
(species unknown) and 64 Sika deer – of Farm 6 were culled, but all confirmed as 
negative. 
Thursday, July 03, 2014 
How Chronic Wasting Disease is affecting deer population and what’s the 
risk to humans and pets? 
CWD, spreading it around...
Tuesday, January 06, 2015 
APHIS Provides Additional Information on Chronic Wasting Disease (CWD) 
Indemnity Requests January 5, 2015 05:26 PM EST
CWD TO HUMANS, AND RISK FACTORS THERE FROM (see latest science) 
Tuesday, November 04, 2014 
*** Six-year follow-up of a point-source exposure to CWD contaminated 
venison in an Upstate New York community: risk behaviours and health outcomes 
2005–2011 
Saturday, January 31, 2015 
RAPID ADVICE 17-2014 : Evaluation of the risk for public health of casings 
in countries with a “negligible risk status for BSE” and on the risk of 
modification of the list of specified risk materials (SRM) with regard to BSE 
 Friday, January 23, 2015 
*** Replacement of soybean meal in compound feed by European protein 
sources and relaxing the mad cow ban $
Saturday, January 24, 2015 
Bovine Spongiform Encephalopathy: Atypical Pros and Cons 
 Comment from Terry Singeltary Sr. This is a Comment on the Animal and 
Plant Health Inspection Service (APHIS) Notice: Agency Information Collection 
Activities; Proposals, Submissions, and Approvals: Bovine Spongiform 
Encephalopathy; Importation of Animals and Animal Products
 For related information, Open Docket Folder 
--------------------------------------------------------------------------
 Show agency attachment(s) AttachmentsView All (0) Empty
--------------------------------------------------------------------------
 Comment View document:Docket No. APHIS-2014-0107 Bovine Spongiform 
Encephalopathy; Importation of Animals and Animal Products Singeltary Submission 
;
 I believe that there is more risk to the world from Transmissible 
Spongiform Encephalopathy TSE prion aka mad cow type disease now, coming from 
the United States and all of North America, than there is risk coming to the USA 
and North America, from other Countries. I am NOT saying I dont think there is 
any risk for the BSE type TSE prion coming from other Countries, I am just 
saying that in 2015, why is the APHIS/USDA/FSIS/FDA still ignoring these present 
mad cow risk factors in North America like they are not here? 
 North America has more strains of TSE prion disease, in more species 
(excluding zoo animals in the early BSE days, and excluding the Feline TSE and 
or Canine TSE, because they dont look, and yes, there has been documented 
evidence and scientific studies, and DEFRA Hound study, that shows the canine 
spongiform encephalopathy is very possible, if it has not already happened, just 
not documented), then any other Country in the world. Mink TME, Deer Elk cervid 
CWD (multiple strains), cBSE cattle, atypical L-type BSE cattle, atypical H-type 
BSE cattle, atyical HG type BSE cow (the only cow documented in the world to 
date with this strain), typical sheep goat Scrapie (multiple strains), and the 
atypical Nor-98 Scrapie, which has been linked to sporadic CJD, Nor-98 atypical 
Scrapie has spread from coast to coast. sporadic CJD on the rise, with different 
strains mounting, victims becoming younger, with the latest nvCJD human mad cow 
case being documented in Texas again, this case, NOT LINKED TO EUROPEAN TRAVEL 
CDC. 
 typical BSE can propagate as nvCJD and or sporadic CJD (Collinge et al), 
and sporadic CJD has now been linked to atypical BSE, Scrapie and atypical 
Scrapie, and scientist are very concerned with CWD TSE prion in the Cervid 
populations. in my opinion, the BSE MRR policy, which overtook the BSE GBR risk 
assessments for each country, and then made BSE confirmed countries legal to 
trade mad cow disease, which was all brought forth AFTER that fateful day 
December 23, 2003, when the USA lost its gold card i.e. BSE FREE status, thats 
the day it all started. once the BSE MRR policy was shoved down every countries 
throat by USDA inc and the OIE, then the legal trading of Scrapie was validated 
to be a legal trading commodity, also shoved through by the USDA inc and the 
OIE, the world then lost 30 years of attempted eradication of the BSE TSE prion 
disease typical and atypical strains, and the BSE TSE Prion aka mad cow type 
disease was thus made a legal trading commodity, like it or not. its all about 
money now folks, trade, to hell with human health with a slow incubating 
disease, that is 100% fatal once clinical, and forget the fact of exposure, 
sub-clinical infection, and friendly fire there from i.e. iatrogenic TSE prion 
disease, the pass it forward mode of the TSE PRION aka mad cow type disease. its 
all going to be sporadic CJD or sporadic ffi, or sporadic gss, or now the 
infamous VPSPr. ...problem solved $$$ 
 the USDA/APHIS/FSIS/FDA triple mad cow BSE firewall, well, that was 
nothing but ink on paper. 
 for this very reason I believe the BSE MRR policy is a total failure, and 
that this policy should be immediately withdrawn, and set back in place the BSE 
GBR Risk Assessments, with the BSE GBR risk assessments set up to monitor all 
TSE PRION disease in all species of animals, and that the BSE GBR risk 
assessments be made stronger than before. 
 lets start with the recent notice that beef from Ireland will be coming to 
America. 
 Ireland confirmed around 1655 cases of mad cow disease. with the highest 
year confirming about 333 cases in 2002, with numbers of BSE confirmed cases 
dropping from that point on, to a documentation of 1 confirmed case in 2013, to 
date. a drastic decrease in the feeding of cows to cows i.e. the ruminant mad 
cow feed ban, and the enforcement of that ban, has drastically reduced the 
number of BSE cases in Europe, minus a few BABs or BARBs. a far cry from the 
USDA FDA triple BSE firewall, which was nothing more than ink on paper, where in 
2007, in one week recall alone, some 10 MILLION POUNDS OF BANNED POTENTIAL MAD 
COW FEED WENT OUT INTO COMMERCE IN THE USA. this is 10 years post feed ban. in 
my honest opinion, due to the blatant cover up of BSE TSE prion aka mad cow 
disease in the USA, we still have no clue as to the true number of cases of BSE 
mad cow disease in the USA or North America as a whole. ...just saying. 
 Number of reported cases of bovine spongiform encephalopathy (BSE) in 
farmed cattle worldwide* (excluding the United Kingdom) 
 Country/Year 
 snip...please see attached pdf file, with references of breaches in the 
USA triple BSE mad cow firewalls, and recent science on the TSE prion disease. 
...TSS No documents available. AttachmentsView All (1) Empty Docket No. 
APHIS-2014-0107 Bovine Spongiform Encephalopathy; Importation of Animals and 
Animal Products Singeltary Submission View Attachment: 
 Sunday, January 11, 2015 
Docket No. APHIS-2014-0107 Bovine Spongiform Encephalopathy; Importation of 
Animals and Animal Products Singeltary Submission 
 *** HUMAN MAD COW DISEASE nvCJD TEXAS CASE NOT LINKED TO EUROPEAN TRAVEL 
CDC ***
Sunday, November 23, 2014 
*** Confirmed Variant Creutzfeldt-Jakob Disease (variant CJD) Case in Texas 
in June 2014 confirmed as USA case NOT European *** 
the patient had resided in Kuwait, Russia and Lebanon. The completed 
investigation did not support the patient's having had extended travel to 
European countries, including the United Kingdom, or travel to Saudi Arabia. The 
specific overseas country where this patient’s infection occurred is less clear 
largely because the investigation did not definitely link him to a country where 
other known vCJD cases likely had been infected. 
Sunday, December 14, 2014 
*** ALERT new variant Creutzfeldt Jakob Disease nvCJD or vCJD, sporadic CJD 
strains, TSE prion aka Mad Cow Disease United States of America Update December 
14, 2014 Report ***
Thursday, January 15, 2015 
41-year-old Navy Commander with sporadic Creutzfeldt–Jakob disease CJD TSE 
Prion: Case Report 
Subject: *** Becky Lockhart 46, Utah’s first female House speaker, dies 
diagnosed with the extremely rare Creutzfeldt-Jakob disease aka mad cow type 
disease
what is CJD ? just ask USDA inc., and the OIE, they are still feeding the 
public and the media industry fed junk science that is 30 years old. 
why doesn’t some of you try reading the facts, instead of rubber stamping 
everything the USDA inc says.
sporadic CJD has now been linked to BSE aka mad cow disease, Scrapie, and 
there is much concern now for CWD and risk factor for humans. 
My sincere condolences to the family and friends of the House Speaker Becky 
Lockhart. I am deeply saddened hear this. 
with that said, with great respect, I must ask each and every one of you 
Politicians that are so deeply saddened to hear of this needless death of the 
Honorable House Speaker Becky Lockhart, really, cry me a friggen river. I am 
seriously going to ask you all this...I have been diplomatic for about 17 years 
and it has got no where. people are still dying. so, are you all stupid or 
what??? how many more need to die ??? how much is global trade of beef and other 
meat products that are not tested for the TSE prion disease, how much and how 
many bodies is this market worth? 
Saturday, January 17, 2015 
*** Becky Lockhart 46, Utah’s first female House speaker, dies diagnosed 
with the extremely rare Creutzfeldt-Jakob disease
Thursday, January 22, 2015 
Transmission properties of atypical Creutzfeldt-Jakob disease: a clue to 
disease etiology?
Tuesday, December 30, 2014 
TSEAC USA Reason For Recalls Blood products, collected from a donors 
considered to be at increased risk for Creutzfeldt-Jakob Disease (CJD), were 
distributed END OF YEAR REPORT 2014
who’s kidding whom $$$ i.e. USDA INC AND THE OIE 
2014 
***Moreover, L-BSE has been transmitted more easily to transgenic mice 
overexpressing a human PrP [13,14] or to primates [15,16] than C-BSE. 
***It has been suggested that some sporadic CJD subtypes in humans may 
result from an exposure to the L-BSE agent. 
*** Lending support to this hypothesis, pathological and biochemical 
similarities have been observed between L-BSE and an sCJD subtype (MV genotype 
at codon 129 of PRNP) [17], and between L-BSE infected non-human primate and 
another sCJD subtype (MM genotype) [15]. 
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... 
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... 
Saturday, December 13, 2014 
Terry S. Singeltary Sr. Publications TSE prion disease 
Diagnosis and Reporting of Creutzfeldt-Jakob Disease 
Singeltary, Sr et al. JAMA.2001; 285: 733-734. Vol. 285 No. 6, February 14, 
2001 JAMA
snip...
TSS
0>
No comments:
Post a Comment
Note: Only a member of this blog may post a comment.