National List of Reportable Animal Diseases (NLRAD) proposed rule CWD, Scrapie, BSE, TSE, Prion Disease Singeltary Submission Docket APHIS-2017-0002
August, 7, 2020
Greetings APHIS et al, i would kindly like to comment on National List of Reportable Animal Diseases (NLRAD) proposed rule Docket APHIS-2017-0002.
I kindly wish to remind you that Transmissible Spongiform Encephalopathy TSE Prion disease is mutating and spreading around the globe. The USA just documented another case of the atypical Nor-98 Scrapie, a case of atypical BSE in Florida just a year or so ago here, CWD TSE Prion spreading across the USA, the recent findings that CWD TSE Prion of cervids, and Sheep Scrapie can transmit to PIGS by the oral routes, and with the outbreak of a new TSE Prion disease in a new livestock species in Camels, a rather large outbreak, i believe it is paramount that the revised National List of Reportable Animal Diseases (NLRAD), address all these concerns. IF you will see, the Bovine Spongiform Encephalopathy BSE animal feeds for ruminants rule, 21 CFR 589.200, this feed ban was nothing but ink on paper, failed year after year after year, with these banned products fed out into commerce. WE must continue to be vigilant on protecting livestock and humans from this deadly TSE Prion pathogen, it has NOT gone away, or disappeared. Thank You...
Terry S. Singeltary Sr.
NEW TRANSMISSIBLE SPONGIFORM ENCEPHALOPATHY TSE PRION DISEASE (MAD CAMEL DISEASE) IN A NEW SPECIES
NEW OUTBREAK OF TRANSMISSIBLE SPONGIFORM ENCEPHALOPATHY TSE PRION DISEASE IN A NEW SPECIES
Subject: Prion Disease in Dromedary Camels, Algeria
Our identification of this prion disease in a geographically widespread livestock species requires urgent enforcement of surveillance and assessment of the potential risks to human and animal health.
***> IMPORTS AND EXPORTS <***
SEE MASSIVE AMOUNTS OF BANNED ANIMAL PROTEIN AKA MAD COW FEED IN COMMERCE USA DECADES AFTER POST BAN
cwd scrapie pigs oral routes
***> However, at 51 months of incubation or greater, 5 animals were positive by one or more diagnostic methods. Furthermore, positive bioassay results were obtained from all inoculated groups (oral and intracranial; market weight and end of study) suggesting that swine are potential hosts for the agent of scrapie. <***
>*** Although the current U.S. feed ban is based on keeping tissues from TSE infected cattle from contaminating animal feed, swine rations in the U.S. could contain animal derived components including materials from scrapie infected sheep and goats. These results indicating the susceptibility of pigs to sheep scrapie, coupled with the limitations of the current feed ban, indicates that a revision of the feed ban may be necessary to protect swine production and potentially human health. <***
***> Results: PrPSc was not detected by EIA and IHC in any RPLNs. All tonsils and MLNs were negative by IHC, though the MLN from one pig in the oral <6 month group was positive by EIA. PrPSc was detected by QuIC in at least one of the lymphoid tissues examined in 5/6 pigs in the intracranial <6 months group, 6/7 intracranial >6 months group, 5/6 pigs in the oral <6 months group, and 4/6 oral >6 months group. Overall, the MLN was positive in 14/19 (74%) of samples examined, the RPLN in 8/18 (44%), and the tonsil in 10/25 (40%).
***> Conclusions: This study demonstrates that PrPSc accumulates in lymphoid tissues from pigs challenged intracranially or orally with the CWD agent, and can be detected as early as 4 months after challenge. CWD-infected pigs rarely develop clinical disease and if they do, they do so after a long incubation period.
This raises the possibility that CWD-infected pigs could shed prions into their environment long before they develop clinical disease.
Furthermore, lymphoid tissues from CWD-infected pigs could present a potential source of CWD infectivity in the animal and human food chains.
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.
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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.
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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).
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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.
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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.
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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.
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the feds just released this statement and you should read this very carefully about the mad cow feed ban that never was, and still isn't, and why this is so important, since USDA APHIS ARS Scientist recent transmitted Chronic Wasting Disease CWD TSE Prion, BY ORAL ROUTES, to PIGS AND SHEEP. this is terrible news, and proves the mad cow feed ban never worked, especially since it really never existed;
ponder this; ***> Adriano Aguzzi...''We even showed that a prion AEROSOL will infect 100% of mice within 10 seconds of exposure''
SUNDAY, SEPTEMBER 1, 2019
FDA Reports on VFD Compliance
Before and after the current Veterinary Feed Directive (VFD) rules took full effect in January, 2017, the FDA focused primarily on education and outreach to help feed mills, veterinarians and producers understand and comply with the requirements. Since then, FDA has gradually increased the number of VFD inspections and initiated enforcement actions when necessary.
***> Wednesday, January 23, 2019
***> CFIA SFCR Guidance on Specified risk material (SRM) came into force on January 15, 2019 <***
THURSDAY, JULY 20, 2017
USDA OIE Alabama Atypical L-type BASE Bovine Spongiform Encephalopathy BSE animal feeds for ruminants rule, 21 CFR 589.200
WEDNESDAY, APRIL 24, 2019
***> USDA Announces Atypical Bovine Spongiform Encephalopathy Detection Aug 29, 2018 A Review of Science 2019 <***
MONDAY, JANUARY 09, 2017
Oral Transmission of L-Type Bovine Spongiform Encephalopathy Agent among Cattle
CDC Volume 23, Number 2—February 2017
*** Consumption of L-BSE–contaminated feed may pose a risk for oral transmission of the disease agent to cattle.
*** Consumption of L-BSE–contaminated feed may pose a risk for oral transmission of the disease agent to cattle.
TUESDAY, AUGUST 28, 2018
USDA finds BSE infection in Florida cow 08/28/18 6:43 PM
http://animalhealthreportpriontse..blogspot.com/2018/08/usda-finds-bse-infection-in-florida-cow.html
WEDNESDAY, AUGUST 29, 2018
USDA Announces Atypical Bovine Spongiform Encephalopathy Detection USDA 08/29/2018 10:00 AM EDT
WEDNESDAY, AUGUST 29, 2018
Transmissible Spongiform Encephalopathy TSE Prion Atypical BSE Confirmed Florida Update USA August 28, 2018
***> P.108: Successful oral challenge of adult cattle with classical BSE
Sandor Dudas1,*, Kristina Santiago-Mateo1, Tammy Pickles1, Catherine Graham2, and Stefanie Czub1 1Canadian Food Inspection Agency; NCAD Lethbridge; Lethbridge, Alberta, Canada; 2Nova Scotia Department of Agriculture; Pathology Laboratory; Truro, Nova Scotia, Canada
Classical Bovine spongiform encephalopathy (C-type BSE) is a feed- and food-borne fatal neurological disease which can be orally transmitted to cattle and humans. Due to the presence of contaminated milk replacer, it is generally assumed that cattle become infected early in life as calves and then succumb to disease as adults. Here we challenged three 14 months old cattle per-orally with 100 grams of C-type BSE brain to investigate age-related susceptibility or resistance. During incubation, the animals were sampled monthly for blood and feces and subjected to standardized testing to identify changes related to neurological disease. At 53 months post exposure, progressive signs of central nervous system disease were observed in these 3 animals, and they were euthanized. Two of the C-BSE animals tested strongly positive using standard BSE rapid tests, however in 1 C-type challenged animal, Prion 2015 Poster Abstracts S67 PrPsc was not detected using rapid tests for BSE. Subsequent testing resulted in the detection of pathologic lesion in unusual brain location and PrPsc detection by PMCA only.
***Our study demonstrates susceptibility of adult cattle to oral transmission of classical BSE.
We are further examining explanations for the unusual disease presentation in the third challenged animal.
***our findings suggest that possible transmission risk of H-type BSE to sheep and human. Bioassay will be required to determine whether the PMCA products are infectious to these animals.
P.86: Estimating the risk of transmission of BSE and scrapie to ruminants and humans by protein misfolding cyclic amplification
Morikazu Imamura, Naoko Tabeta, Yoshifumi Iwamaru, and Yuichi Murayama
National Institute of Animal Health; Tsukuba, Japan
To assess the risk of the transmission of ruminant prions to ruminants and humans at the molecular level, we investigated the ability of abnormal prion protein (PrPSc) of typical and atypical BSEs (L-type and H-type) and typical scrapie to convert normal prion protein (PrPC) from bovine, ovine, and human to proteinase K-resistant PrPSc-like form (PrPres) using serial protein misfolding cyclic amplification (PMCA).
Six rounds of serial PMCA was performed using 10% brain homogenates from transgenic mice expressing bovine, ovine or human PrPC in combination with PrPSc seed from typical and atypical BSE- or typical scrapie-infected brain homogenates from native host species. In the conventional PMCA, the conversion of PrPC to PrPres was observed only when the species of PrPC source and PrPSc seed matched. However, in the PMCA with supplements (digitonin, synthetic polyA and heparin), both bovine and ovine PrPC were converted by PrPSc from all tested prion strains. On the other hand, human PrPC was converted by PrPSc from typical and H-type BSE in this PMCA condition.
Although these results were not compatible with the previous reports describing the lack of transmissibility of H-type BSE to ovine and human transgenic mice, our findings suggest that possible transmission risk of H-type BSE to sheep and human. Bioassay will be required to determine whether the PMCA products are infectious to these animals.
***> why do we not want to do TSE transmission studies on chimpanzees $
5. A positive result from a chimpanzee challenged severly would likely create alarm in some circles even if the result could not be interpreted for man.
***> I have a view that all these agents could be transmitted provided a large enough dose by appropriate routes was given and the animals kept long enough.
***> Until the mechanisms of the species barrier are more clearly understood it might be best to retain that hypothesis.
snip...
R. BRADLEY
WEDNESDAY, JUNE 10, 2020
Radical Change in Zoonotic Abilities of Atypical BSE Prion Strains as Evidenced by Crossing of Sheep Species Barrier in Transgenic Mice
MONDAY, JULY 27, 2020
APHIS USDA Nor98-like scrapie was confirmed in a sheep sampled at slaughter in May 2020
TUESDAY, AUGUST 04, 2020
Genetic and evolutionary considerations of the Chronic Wasting Disease – Human species barrier
-----Original Message-----
From: Terry Singeltary <flounder9@verizon.net>
To: aasv@aasv.org <aasv@aasv.org>; NLRAD.NAHRS@usda.gov <NLRAD.NAHRS@usda.gov>
Cc: snelson@aasv.org <snelson@aasv.org>; WagstromL@nppc.org <WagstromL@nppc.org>; psundberg@swinehealth.org <psundberg@swinehealth.org>
Sent: Mon, Aug 3, 2020 11:56 am
Subject: National List of Reportable Animal Diseases (NLRAD) proposed rule CWD, Scrapie, BSE, TSE, Prion Disease Singeltary Submission Docket APHIS-2017-0002
From: Terry Singeltary <flounder9@verizon.net>
To: aasv@aasv.org <aasv@aasv.org>; NLRAD.NAHRS@usda.gov <NLRAD.NAHRS@usda.gov>
Cc: snelson@aasv.org <snelson@aasv.org>; WagstromL@nppc.org <WagstromL@nppc.org>; psundberg@swinehealth.org <psundberg@swinehealth.org>
Sent: Mon, Aug 3, 2020 11:56 am
Subject: National List of Reportable Animal Diseases (NLRAD) proposed rule CWD, Scrapie, BSE, TSE, Prion Disease Singeltary Submission Docket APHIS-2017-0002
National List of Reportable Animal Diseases (NLRAD) proposed rule CWD, Scrapie, BSE, TSE, Prion Disease Singeltary Submission Docket APHIS-2017-0002
Regulatory Analysis and Development Policy and Program Development Division Animal and Plant Health Inspection Service Station 3A-03.8, 4700 River Road Unit 118 Riverdale, MD 20737-1238
Submitted electronically to docket APHIS-2017-0002 at http://www.regulations.gov
July 29, 2020
To Whom It May Concern:
We would like to thank the United States Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) for the opportunity to comment on the National List of Reportable Animal Diseases (NLRAD) proposed rule. The National Pork Producers Council (NPPC) is the global voice for the US pork industry and consists of 42 affiliated state organizations representing America’s 60,000 pork producers. The American Association of Swine Veterinarians (AASV) is a professional association of veterinarians specializing in swine health, welfare, and production. Over 1,500 AASV members represent all facets of the veterinary profession including practice, research, allied industry, public health, government, academia, and education. The Swine Health Information Center (SHIC) has a mission to protect and enhance the health of the United States swine herd through coordinated global disease monitoring, targeted research investments that minimize the impact of future disease threats, and analysis of swine health data. SHIC works directly with the pork industry and public and private industry partners and organizations to facilitate effective and coordinated response to emerging swine diseases.
NPPC, AASV and SHIC support APHIS in its efforts to ensure that the United States is compliant with its reporting obligations as a member of the World Animal Health Organization (OIE) and has a rational, consistent procedure for collecting and responding to information concerning animal diseases of concern. The adoption of the NLRAD will satisfy this need. However, we do have some concerns with the NLRAD proposal that we encourage APHIS to address. The NLRAD has a discrete purpose: to collect and collate information concerning the diagnoses of specific named animal diseases and conditions. The pork industry also recognizes that APHIS has a legitimate need to solicit information about unusual animal health events from a wide range of stakeholders. However, we have significant concerns about conflating these two needs under one NLRAD reporting mechanism. We suggest that APHIS develop a second portal under the National Animal Health Monitoring System (NAHMS) umbrella to collect voluntary reports of suspicious animal health events. For clarity, we will address “suspicious animal health events,” “notifiable diseases and conditions,” and “monitored diseases” requirements separately.
Suspicious Animal Health Events
NPPC, AASV and SHIC concur with APHIS that under-reporting of notifiable animal diseases within the United States can have significant domestic and international ramifications. However, it must be acknowledged that false or premature reports can similarly have damaging consequences. For these reasons, animal health professionals, or indeed any individuals other than veterinarians, should not be obligated to report under the NLRAD when they are not credentialled to make a diagnosis of a specific animal disease. We also have significant concern with requiring veterinarians to report information concerning animal health events that do not meet the case definition of a disease or condition named on the NLRAD, especially since there is no defined response plan for such reports.
The pork industry appreciates APHIS’ rationale in wanting to collect information that falls under the “emerging disease” criteria in the proposed NLRAD rule. However, the proposed criteria are highly subjective—too subjective to mandate reporting. Requiring the reporting of an epidemiological change of a known (but not notifiable) animal disease, for example, creates a significant burden on veterinarians, other animal health professionals, APHIS, and state animal health agencies. For veterinarians and other animal health professionals, it removes discretion in determining the significance of clinical, diagnostic, and/or field observations. For APHIS and state animal health agencies, it will result in a significant increase of reports with no clear methodology or identified resources for analysis and response.
We strongly suggest that APHIS develop an additional portal to receive voluntary reports of suspicious animal health events. This portal could be utilized by veterinarians to report information that falls under the “emerging” classification in the proposed NLRAD rule when, in their professional judgement, they encounter an animal health event that is not classified under the NLRAD but that merits the attention of animal health officials.
Crucially, this system could also be used by other individuals—animal health professionals, producers, or other members of the public with specialized knowledge—to report suspicious animal health events.
Such a portal would have a logical home under the Center for Epidemiology and Animal Health’s Risk Identification Unit. It would provide APHIS with needed information without compromising the intent or utility of the proposed NLRAD system. APHIS must also ensure that information provided is secured, and that confidential information is fully protected. At the same time, validated reports of suspicious animal health events should be shared in summary form with animal industries and other animal health stakeholders.
Notifiable Diseases and Conditions
It is critical that APHIS implement a NLRAD system that has clear, carefully delineated reporting requirements, prevents duplicity of reporting, and that is fully resourced. As indicated above, the pork industry does not feel that this can be accomplished by folding in broader surveillance needs. These needs can be addressed by breaking down the NLRAD proposal into three components: what is to be reported, who is to report it, and how it is to be reported. What is to be reported: Reporting should only be mandated for specific diseases or conditions explicitly listed on the NLRAD. APHIS has indicated that it will publish case definitions for each listed disease and has proposed a process to amend the list itself when new diseases or conditions need to be added. These are appropriate and needed enhancements. It is critical that there be a clear case definition for every disease or condition listed on the NLRAD. What is missing is clarity around response to the report. A veterinary diagnostic laboratory or veterinarian making report of a notifiable animal disease or condition should be provided information concerning the likely response to said report.
A response plan must be published for each and every disease or condition. The case definition document should be extended to contain this information, or a companion document created specific to each response. For diseases or conditions with extensive response plans published elsewhere, these can be referenced and succinctly summarized. If the mandated response is a foreign animal disease investigation, this should be stated. If the report is only required to satisfy national reporting requirements to the OIE, this should be clearly indicated.
In other words, the likely response (realizing that not all mitigating circumstances can be addressed) to a report should be clearly stated for everything listed on the NLRAD. The response document should also clearly state the recommended and/or required actions for the reporter to take or convey as appropriate to the attending veterinarian or owner of the affected animals.
The pork industry does not support formal sub-classification of notifiable disease and conditions into “Emergency,” “Emerging,” and “Regulated” categories. While we appreciate the intent of this proposal, it unnecessarily blends response and surveillance activities with reporting requirements. As we have stated, the “emerging” category should be dealt with outside the NLRAD framework. An “emergency” categorization is irrelevant as all notifiable diseases and conditions must be immediately reported; the “regulated” category is also moot in the context of reporting requirements.
Should it be necessary, APHIS has already established under this proposal a mechanism to mandate reporting to the NLRAD for new or emerging syndromes. It can name the syndrome as a condition, establish a clear case definition, and publish it to the NLRAD. This can be accomplished rapidly and with appropriate consultation with industry and other animal health stakeholders. It will also allow for concurrent development of a response plan, and allocation of resources if needed. Again, the disease or condition should not be added to the NLRAD if a response plan has not been developed. Satisfaction of international reporting obligations is itself a response plan for endemic disease, in some cases, and this should be clearly stated if no other response is intended.
We also strongly suggest that APHIS not exclude “wildlife” from the NLRAD reporting requirements. Any disease or condition listed on the NLRAD should be reportable for any subject species, any population within that species be it wild, feral, captive or farmed.
In summary, reporting should only be mandated for specific, named diseases and conditions. Each named disease or condition should have a clear case definition. All relevant state and federal animal health authorities, as well as industry, should have common understanding of the response, if any, to the report of the disease or condition.
Who is to report it: Given the potential ramifications of a report of a notifiable disease, official reporting should be limited to both public and private veterinary diagnostic laboratories, which are credentialled to confirm the diagnosis of notifiable diseases. Veterinarians who diagnose a notifiable disease or condition without utilizing a veterinary diagnostic laboratory should also have a duty to report.
We have already suggested a mechanism by which other animal health professionals, and indeed any other individuals, can notify state and/or federal animal health officials of unusual animal health observations or events if they are not in a position to bring their concerns to the attention of a veterinarian with whom they have a relationship. This notification pathway again would be independent of that used by veterinarians to report confirmed or suspected diagnoses of discrete notifiable animal disease or conditions. Ultimately any observation of a suspicious animal health event will require the intervention of a veterinarian and/or veterinary diagnostic laboratory if substantiated. It is the laboratory or veterinarian who should officially notify if the ultimate diagnosis is reportable.
In summary, mandated reporting under the NLRAD should be limited to veterinary diagnostic laboratories that have confirmed the diagnosis of a reportable disease or condition. Veterinarians who have arrived at a confirmed or presumed diagnosis that falls under an established case definition without utilizing a veterinary diagnostic laboratory should also have a duty to report. Alternative mechanisms, distinct from NLRAD, should be developed and/or promoted for laypersons to notify animal health officials of suspicious events.
How it is to be reported: NPPC appreciates that APHIS explored a single portal for reporting, and that not all states have equally robust animal health agencies. We support that APHIS require all veterinary diagnostic laboratories, or veterinarians operating independent of such, report notifiable animal diseases and conditions to the NLRAD electronic portal as proposed upon diagnosis.
It is not clear, however, why APHIS is mandating that report also be made to the state in which the animal is located. APHIS should be in position to ensure that the state is immediately and automatically notified of a report to the NLRAD portal.
We understand, and support that many states do in fact have a reporting requirement for certain animal diseases or conditions. These should stand. Many veterinarians will prefer to notify their state animal health officials of their diagnosis as well as report to the NLRAD. This should also remain a viable option. The federal regulation should dictate federal reporting requirements; state regulations and accepted practice should dictate state reporting requirements.
As with the proposed portal for reporting suspicious animal health events, APHIS should ensure that the reporting system is secure and that confidential and identifying information is protected from public release. Reports should be summarized and provided to the animal industries and other animal health stakeholders promptly— especially if they concern non-endemic diseases or conditions.
In summary, the NLRAD should only mandate reporting to the proposed federal NLRAD portal. APHIS should ensure that the appropriate state agency is immediately notified upon receipt of a report. APHIS should let states determine their own direct reporting requirements for diagnostic laboratories, veterinarians and other animal health professionals under their jurisdiction, as is current practice.
NPPC, AASV and SHIC support the establishment of a NLRAD for notifiable animal diseases and conditions. The NLRAD should consist of a discrete list of named animal diseases and conditions, each with a published case definition and response plan. Reporting requirements should be limited to veterinarians who have a confirmed or presumed diagnosis of a disease or condition named on the NLRAD. The report should be made to the federal NLRAD portal as proposed, with states reserving the right to establish their own reporting requirements. The NLRAD should inform but not replace robust animal health monitoring and surveillance programs.
Monitored Animal Diseases
NPPC, AASV and SHIC can only support mandating state reporting of monitored animal diseases if both APHIS and states have the necessary resources to compile and transmit this information electronically, and if APHIS has the resources to analyze and contextualize this information when making it publicly available or reporting it to the OIE. In proposing the NLRAD, APHIS indicates that it expects up to a tenfold increase in reported data. While this does support the assertation that it will provide a clearer picture of the status of monitored diseases, it will be more resource intensive to manage this amount of data. APHIS should ensure that it can accomplish this without compromising other animal health programs. It also suggests that many, if not most, states are not currently voluntarily providing this information. It is even more critical that states not have to divert resources from other animal health programs to fulfill this reporting requirement. If APHIS is not in position to provide states with funding and other needed resources required to fulfill this mandate, it should not be enacted at this time. In summary, NPPC, AASV and SHIC support the establishment of a NLRAD that consists of named animal diseases and conditions with established case definitions. Reporting requirements for notifiable animal diseases and conditions should be limited to veterinary diagnostic laboratories and veterinarians, and such reports under the federal rule should be made exclusively to the proposed NLRAD portal. Mandated reporting of monitored animal diseases by states should only be enacted if states can be provided the resources needed to facilitate such reporting. APHIS should develop a voluntary portal separate and distinct from the NLRAD for receiving reports of suspicious animal health events.
Thank you for the opportunity to comment on this important topic.
Sincerely,
Harry Snelson, DVM Executive Director American Association of Swine Veterinarians
Liz Wagstrom, DVM, MS, DACVPM Chief Veterinarian National Pork Producers Council
Paul Sundberg, DVM, PhD, DACVPM Executive Director, Swine Health Information Center
U.S. National List of Reportable Animal Diseases (NLRAD) System Standards - Proposed
In summary, NPPC, AASV and SHIC support the establishment of a NLRAD that consists of named animal diseases and conditions with established case definitions. Reporting requirements for notifiable animal diseases and conditions should be limited to veterinary diagnostic laboratories and veterinarians, and such reports under the federal rule should be made exclusively to the proposed NLRAD portal. Mandated reporting of monitored animal diseases by states should only be enacted if states can be provided the resources needed to facilitate such reporting. APHIS should develop a voluntary portal separate and distinct from the NLRAD for receiving reports of suspicious animal health events...end
MY question is, who is to monitor the real threat of chronic wasting disease and or scrapie TSE Prion in Pigs, if it has not happened already and in the food supply chain for human and animals, and who is to debate what that might look like?
I believe front line inspectors, veterinarians, the ones that see different disease in the field every day SHOULD IMMEDIATELY start to investigate, report, any new livestock animal disease, any delay in reporting would only help spread the disease. there is enough bureaucracy and red tape now, a fine example is separating TSE Prion disease into different disease entities i.e. cwd, scrapie, bse, cpd (CAMEL PRION DISEASE). To bring another disease reporting entity into play would only delay action imo.
Also, state by state regulations on surveillance, tracing efforts, testing, of livestock disease, there must a a scientific standard for all to follow. you cannot have one state doing one thing, and another state doing something else, just does not work...terry
***> cattle, pigs, sheep, cwd, tse, prion, oh my!
***> In contrast, cattle are highly susceptible to white-tailed deer CWD and mule deer CWD in experimental conditions but no natural CWD infections in cattle have been reported (Sigurdson, 2008; Hamir et al., 2006).
Sheep and cattle may be exposed to CWD via common grazing areas with affected deer but so far, appear to be poorly susceptible to mule deer CWD (Sigurdson, 2008). In contrast, cattle are highly susceptible to white-tailed deer CWD and mule deer CWD in experimental conditions but no natural CWD infections in cattle have been reported (Sigurdson, 2008; Hamir et al., 2006). It is not known how susceptible humans are to CWD but given that the prion can be present in muscle, it is likely that humans have been exposed to the agent via consumption of venison (Sigurdson, 2008). Initial experimental research suggests that human susceptibility to CWD is low and there may be a robust species barrier for CWD transmission to humans (Sigurdson, 2008), however the risk appetite for a public health threat may still find this level unacceptable.
cwd scrapie pigs oral routes
***> However, at 51 months of incubation or greater, 5 animals were positive by one or more diagnostic methods. Furthermore, positive bioassay results were obtained from all inoculated groups (oral and intracranial; market weight and end of study) suggesting that swine are potential hosts for the agent of scrapie. <***
>*** Although the current U.S. feed ban is based on keeping tissues from TSE infected cattle from contaminating animal feed, swine rations in the U.S. could contain animal derived components including materials from scrapie infected sheep and goats. These results indicating the susceptibility of pigs to sheep scrapie, coupled with the limitations of the current feed ban, indicates that a revision of the feed ban may be necessary to protect swine production and potentially human health. <***
***> Results: PrPSc was not detected by EIA and IHC in any RPLNs. All tonsils and MLNs were negative by IHC, though the MLN from one pig in the oral <6 month group was positive by EIA. PrPSc was detected by QuIC in at least one of the lymphoid tissues examined in 5/6 pigs in the intracranial <6 months group, 6/7 intracranial >6 months group, 5/6 pigs in the oral <6 months group, and 4/6 oral >6 months group. Overall, the MLN was positive in 14/19 (74%) of samples examined, the RPLN in 8/18 (44%), and the tonsil in 10/25 (40%).
***> Conclusions: This study demonstrates that PrPSc accumulates in lymphoid tissues from pigs challenged intracranially or orally with the CWD agent, and can be detected as early as 4 months after challenge. CWD-infected pigs rarely develop clinical disease and if they do, they do so after a long incubation period.
This raises the possibility that CWD-infected pigs could shed prions into their environment long before they develop clinical disease.
Furthermore, lymphoid tissues from CWD-infected pigs could present a potential source of CWD infectivity in the animal and human food chains.
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
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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.
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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.
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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).
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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.
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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.
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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.
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the feds just released this statement and you should read this very carefully about the mad cow feed ban that never was, and still isn't, and why this is so important, since USDA APHIS ARS Scientist recent transmitted Chronic Wasting Disease CWD TSE Prion, BY ORAL ROUTES, to PIGS AND SHEEP. this is terrible news, and proves the mad cow feed ban never worked, especially since it really never existed;
ponder this; ***> Adriano Aguzzi...''We even showed that a prion AEROSOL will infect 100% of mice within 10 seconds of exposure''
SUNDAY, SEPTEMBER 1, 2019
FDA Reports on VFD Compliance
Before and after the current Veterinary Feed Directive (VFD) rules took full effect in January, 2017, the FDA focused primarily on education and outreach to help feed mills, veterinarians and producers understand and comply with the requirements. Since then, FDA has gradually increased the number of VFD inspections and initiated enforcement actions when necessary.
***> Wednesday, January 23, 2019
***> CFIA SFCR Guidance on Specified risk material (SRM) came into force on January 15, 2019 <***
WEDNESDAY, JUNE 10, 2020
Radical Change in Zoonotic Abilities of Atypical BSE Prion Strains as Evidenced by Crossing of Sheep Species Barrier in Transgenic Mice
Radical Change in Zoonotic Abilities of Atypical BSE Prion Strains as Evidenced by Crossing of Sheep Species Barrier in Transgenic Mice
Atypical BSE prions showed a modification in their zoonotic ability after adaptation to sheep-PrP producing agents able to infect TgMet129 and TgVal129, bearing features that make them indistinguishable of sporadic Creutzfeldt-Jakob disease prions.
our results clearly indicate that atypical BSE adaptation to an ovine-PrP sequence could modify the prion agent to potentially infect humans, showing strain features indistinguishable from those of classic sCJD prions, even though they might or might not be different agents.
However, the expanding range of TSE agents displaying the capacity to transmit in human-PrP–expressing hosts warrants the continuation of the ban on meat and bone meal recycling and underscores the ongoing need for active surveillance
A REVIEW of facts and science on scrapie zoonosis potential/likelihood and the USA incredible failure of the BSE 589.2001 FEED REGULATIONS (another colossal failure, and proven to be a sham)
1st up BSE 589.2001 FEED REGULATIONS
MONDAY, JULY 27, 2020
Experimental study using multiple strains of prion disease in cattle reveals an inverse relationship between incubation time and misfolded prion accumulation, neuroinflammation and autophagy
THURSDAY, JUNE 25, 2020
First Report of the Potential Bovine Spongiform Encephalopathy (BSE)-Related Somatic Mutation E211K of the Prion Protein Gene (PRNP) in Cattle
MONDAY, JULY 27, 2020
APHIS USDA Nor98-like scrapie was confirmed in a sheep sampled at slaughter in May 2020
TUESDAY, JULY 28, 2020
Geographic variation in the PRNP gene and its promoter, and their relationship to chronic wasting disease in North American deer
Camel prion disease
Camelus Spongiform Encephalopathy
MONDAY, JULY 6, 2020
Guidance for reporting 2020 surveillance data on Transmissible Spongiform Encephalopathies (TSE)
MONDAY, JULY 27, 2020
BSE Inquiry DFA's a review
friendly fire from all of the above
Volume 26, Number 8—August 2020
Sporadic Creutzfeldt-Jakob Disease among Physicians, Germany, 1993–2018 high proportion of physicians with sCJD were surgeons
THURSDAY, JULY 02, 2020
Variant Creutzfeldt–Jakob Disease Diagnosed 7.5 Years after Occupational Exposure
SUNDAY, MAY 26, 2019
Arguments for Alzheimer’s and Parkinson’s diseases caused by prions Stanley B. Prusiner
''From a large array of bioassays, we conclude that AD, PD, MSA, and the frontotemporal dementias, including PSP and CBD, are all prion diseases''
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P132 Aged cattle brain displays Alzheimer’s-like pathology that can be propagated in a prionlike manner
Ines Moreno-Gonzalez (1), George Edwards III (1), Rodrigo Morales (1), Claudia Duran-Aniotz (1), Mercedes Marquez (2), Marti Pumarola (2), Claudio Soto (1)
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These results may contribute to uncover a previously unsuspected etiology surrounding some cases of sporadic AD. However, the early and controversial stage of the field of prion-like transmission in non-prion diseases added to the artificial nature of the animal models utilized for these studies, indicate that extrapolation of the results to humans should not be done without further experiments.
P75 Determining transmissibility and proteome changes associated with abnormal bovine prionopathy
Dudas S (1,2), Seuberlich T (3), Czub S (1,2)
In prion diseases, it is believed that altered protein conformation encodes for different pathogenic strains. Currently 3 different strains of bovine spongiform encephalopathy (BSE) are confirmed. Diagnostic tests for BSE are able to identify animals infected with all 3 strains, however, several diagnostic laboratories have reported samples with inconclusive results which are challenging to classify. It was suggested that these may be novel strains of BSE; to determine transmissibility, brain material from index cases were inoculated into cattle.
In the first passage, cattle were intra-cranially challenged with brain homogenate from 2 Swiss animals with abnormal prionopathy. The challenged cattle incubated for 3 years and were euthanized with no clinical signs of neurologic disease. Animals were negative when tested on validated diagnostic tests but several research methods demonstrated changes in the prion conformation in these cattle, including density gradient centrifugation and immunohistochemistry. Currently, samples from the P1 animals are being tested for changes in protein levels using 2-D Fluorescence Difference Gel Electrophoresis (2D DIGE) and mass spectrometry. It is anticipated that, if a prionopathy is present, this approach should identify pathways and targets to decipher the source of altered protein conformation. In addition, a second set of cattle have been challenged with brain material from the first passage. Ideally, these cattle will be given a sufficient incubation period to provide a definitive answer to the question of transmissibility.
=====prion 2018===
***however in 1 C-type challenged animal, Prion 2015 Poster Abstracts
S67 PrPsc was not detected using rapid tests for BSE.
***Subsequent testing resulted in the detection of pathologic lesion in unusual brain location and PrPsc detection by PMCA only.
*** IBNC Tauopathy or TSE Prion disease, it appears, no one is sure ***
Posted by Terry S. Singeltary Sr. on 03 Jul 2015 at 16:53 GMT
P.9.21
Molecular characterization of BSE in Canada
Jianmin Yang 1 , Sandor Dudas 2 , Catherine Graham 2 , Markus Czub 3 , Tim McAllister 1 , Stefanie Czub 1 1 Agriculture and Agri-Food Canada Research Centre, Canada; 2 National and OIE BSE Reference Laboratory, Canada; 3 University of Calgary, Canada
Background: Three BSE types (classical and two atypical) have been identified on the basis of molecular characteristics of the misfolded protein associated with the disease. To date, each of these three types have been detected in Canadian cattle. Objectives: This study was conducted to further characterize the 16 Canadian BSE cases based on the biochemical properties of there associated PrPres.
Methods: Immuno-reactivity, molecular weight, glycoform profiles and relative proteinase K sensitivity of the PrPres from each of the 16 confirmed Canadian BSE cases was determined using modified Western blot analysis.
Results: Fourteen of the 16 Canadian BSE cases were C type, 1 was H type and 1 was L type. The Canadian H and L-type BSE cases exhibited size shifts and changes in glycosylation similar to other atypical BSE cases. PK digestion under mild and stringent conditions revealed a reduced protease resistance of the atypical cases compared to the C-type cases. N terminal-specific antibodies bound to PrPres from H type but not from C or L type. The C-terminal-specific antibodies resulted in a shift in the glycoform profile and detected a fourth band in the Canadian H-type BSE.
Discussion: The C, L and H type BSE cases in Canada exhibit molecular characteristics similar to those described for classical and atypical BSE cases from Europe and Japan. This supports the theory that the importation of BSE contaminated feedstuff is the source of C-type BSE in Canada. It also suggests a similar cause or source for atypical BSE in these countries.
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;
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Re-Evidence for human transmission of amyloid-β pathology and cerebral amyloid angiopathy
>>> The only tenable public line will be that "more research is required’’ <<<
>>> possibility on a transmissible prion remains open<<<
O.K., so it’s about 23 years later, so somebody please tell me, when is "more research is required’’ enough time for evaluation ?
Re-Evidence for human transmission of amyloid-β pathology and cerebral amyloid angiopathy
Nature 525, 247?250 (10 September 2015) doi:10.1038/nature15369 Received 26 April 2015 Accepted 14 August 2015 Published online 09 September 2015 Updated online 11 September 2015 Erratum (October, 2015)
snip...see full Singeltary Nature comment here;
Alzheimer's disease
let's not forget the elephant in the room. curing Alzheimer's would be a great and wonderful thing, but for starters, why not start with the obvious, lets prove the cause or causes, and then start to stop that. think iatrogenic, friendly fire, or the pass it forward mode of transmission. think medical, surgical, dental, tissue, blood, related transmission. think transmissible spongiform encephalopathy aka tse prion disease aka mad cow type disease...
Commentary: Evidence for human transmission of amyloid-β pathology and cerebral amyloid angiopathy
Self-Propagative Replication of Ab Oligomers Suggests Potential Transmissibility in Alzheimer Disease
*** Singeltary comment PLoS ***
Alzheimer’s disease and Transmissible Spongiform Encephalopathy prion disease, Iatrogenic, what if ?
Posted by flounder on 05 Nov 2014 at 21:27 GMT
IN CONFIDENCE
5 NOVEMBER 1992
TRANSMISSION OF ALZHEIMER TYPE PLAQUES TO PRIMATES
[9. Whilst this matter is not at the moment directly concerned with the iatrogenic CJD cases from hgH, there remains a possibility of litigation here, and this presents an added complication.
There are also results to be made available shortly
(1) concerning a farmer with CJD who had BSE animals,
(2) on the possible transmissibility of Alzheimer’s and
(3) a CMO letter on prevention of iatrogenic CJD transmission in neurosurgery, all of which will serve to increase media interest.]
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Terry S. Singeltary Sr.
