Here are the Rules!

[pandiana]

The following are the current OIE guidlines for monitoring ruminants that were published in 1997. We expect revised guidelines by May of this year I understand.

I noted particularly 3.2.13.3 which was also noted by rsomer in which the US would be under no penalty if they can prove that this US case was imported.
These guidelines are particularily interesting in light of the previous article from UPI where apparently no records of the 20,000 animals tested can be 'found'.

"b)all cases of BSE have been clearly demonstrated to originate directly from importation of live cattle originating from BSE infected countries, provided that the disease is made notifiable and suspect animals are slaughtered, investigated and, if disease is confirmed, completely destroyed and an effective and continuous surveillance and monitoring system is practised, as described in Article 3.2.13.1. points 3) and 4); or"



APPENDIX C
International Animal Health Code
Special Edition 1997
Chapter 3.2.13.
Bovine Spongiform Encephalopathy
(BSE)


Article 3.2.13.1.
Bovine spongiform encephalopathy (BSE) is a progressive nervous disease of adult cattle. BSE has a long incubation period measured in years, and arose from feeding contaminated ruminant protein.
The BSE status of a country can only be determined by continuous surveillance and monitoring. The minimum requirements for effective surveillance are:


1) compulsory notification and clinical investigation of suspect cases;
2) a risk assessment identifying the potential hazards for BSE occurrence:

a) risk arising by:

i) importation of animals or embryos/ova which are potentially infected with a transmissible spongiform encephalopathy (TSE);

ii) importation and feeding of potentially contaminated animal feedstuff to cattle;

b) indigenous risks:

i) consumption, by cattle, of contaminated, animal-derived proteins arising from transmissible spongiform encephalopathy-infected animals and rendering processes which do not inactivate the agent;

ii) potential vertical transmission of BSE from cows originating from infected countries;


3) a continuous BSE surveillance and monitoring system with emphasis on risks identified in point 2) above; and

4) examination in an approved laboratory of brain material from cattle older than 20 months displaying signs of progressive neurologic disease in accordance with the diagnostic techniques set out in the Manual. A sufficient number of investigations as indicated in Table I of the Guidelines for Continuous Surveillance and Monitoring of BSE (Appendix VIII of document 65 SG/12/CS.) should be carried out annually;

in countries where progressive neurologic disease incidence is low, surveillance should be targeted at cattle older than four years of age displaying other progressive disease conditions;

5) records of the number and results of investigations should be maintained for at least seven years.

Each confirmed case should be reported as a separate outbreak.


Article 3.2.13.2.
Countries may be considered free of BSE if:

1) they have implemented a risk management strategy to address any risk, as identified in Article 3.2.13.1. point 2); and

2) The feeding of meat-and-bone meal to cattle derived from ruminants originating from animal TSE infected countries, or countries which do not have an effective and continuous surveillance and monitoring system as described in Article 3.2.13.1 points 3) and 4), has been banned and is effectively enforced;

AND

3) a) there has been no clinical case of BSE, the disease is notifiable, and an effective and continuous surveillance and monitoring system is practised, as described in Article 3.2.13.1. point 3) and 4); or



b)all cases of BSE have been clearly demonstrated to originate directly from importation of live cattle originating from BSE infected countries, provided that the disease is made notifiable and suspect animals are slaughtered, investigated and, if disease is confirmed, completely destroyed and an effective and continuous surveillance and monitoring system is practised, as described in Article 3.2.13.1. points 3) and 4); or


c) BSE has been eradicated (under study).


Article 3.2.13.3.

Veterinary Administrations can authorise without restriction the import or transit through their territory, directly or indirectly, of milk, milk products, tallow, hides and skins originating from healthy animals from countries where BSE has been reported. There is also no scientific evidence of a risk associated with the trade in semen from healthy animals. By-products, such as gelatin and collagen, are considered to be safe if produced by processes (under study) which inactivate any residual BSE infectivity.


Article 3.2.13.4.




When importing from countries with low incidence of BSE, Veterinary Administrations should require:



for cattle



the presentation of an international animal health certificate attesting that:



1) the disease is compulsorily notifiable;



2) affected cattle are slaughtered and completely destroyed;



3) suspect heifers or cows close to calving are isolated;



4) an effective and continuous surveillance and monitoring system is practised in accordance with Article 3.2.13.1.;



5) the feeding of meat-and-bone meal derived from ruminants to ruminants has been banned and effectively enforced;



6) cattle selected for export:



a) are identified by a permanent mark enabling them to be traced back to the dam and herd of origin;



b) are not the calves of BSE suspect or confirmed females.



Article 3.2.13.5.



When importing from countries with a high incidence of BSE, Veterinary Administrations should require:



for cattle



the presentation of an international animal health certificate attesting, in addition to the requirements set forth in Article 3.2.13.4. that animals for export:



1) either were born after the date on which an effective ban on the use of ruminant meat-and-bone meal in feed for ruminants has been effectively enforced; or



2) were born, raised and had remained in a herd in which no case of BSE had ever been confirmed, and which contains only cattle born on the farm or coming from a herd of equal status; and



3) have never been fed ruminant meat-and-bone meal.



Article 3.2.13.6.



When importing from countries with a low incidence of BSE, Veterinary Administrations should require:

for fresh meat (bone-in or deboned) and meat products from cattle



the presentation of an international sanitary certificate attesting that:



1) the disease is compulsorily notifiable;



2) affected cattle are slaughtered and completely destroyed;



3) ante mortem inspection is carried out on all bovines;



4) an effective and continuous surveillance and monitoring system is practised in accordance with Article 3.2.13.1.;



5) the meat products do not contain brain, eyes, spinal cord or distal ileum from cattle over six months of age which were born before the date on which the feed ban referred to in paragraph 5) of Article 3.2.13.4. was effectively enforced.



Article 3.2.13.7.



When importing from countries with high incidence of BSE, Veterinary Administration should require:



for fresh bone-in meat from cattle



the presentation of an international sanitary certificate attesting, in addition to the requirements set forth in Article 3.2.13.6., that:



1) the tissues listed in Article 3.2.13.12. are removed from all cattle at slaughter and destroyed;



2) the cattle from which the meat originates:



a) were born after the date on which a ban on the use of ruminant meat-and-bone meal in feed for ruminants has been effectively enforced; or



b) were born and had only been kept in herds in which no case of BSE had been recorded; and



c) have never been fed ruminant meat-and-bone meal.



Article 3.2.13.8.



When importing from countries with a high incidence of BSE, Veterinary Administrations should require:



for fresh deboned meat and meat products from cattle



the presentation of an international sanitary certificate attesting that the conditions in Article 3.2.13.7. apply or alternatively that:

1) the disease is compulsorily notifiable;



2) affected cattle are slaughtered and completely destroyed;



3) ante mortem inspection is carried out on all bovines;



4) an effective and continuous surveillance and monitoring system is practised in accordance with Article 3.2.13.1.;



5) the tissues listed in Article 3.2.13.12. are removed from all cattle at slaughter and destroyed;



6) nervous and lymphatic tissues exposed during the cutting process have been removed and destroyed.



Article 3.2.13.9.



When importing from countries with a low incidence of BSE, Veterinary Administrations should require:



for bovine embryos/ova



the presentation of an international animal health certificate attesting that:



1) the disease is compulsorily notifiable;



2) affected cattle are slaughtered and completely destroyed;



3) suspect heifers or cows close to calving are isolated;



4) an effective and continuous surveillance and monitoring system is practised in accordance with Article 3.2.13.1.;



5) the feeding of meat-and-bone meal derived from ruminants to ruminants has been banned and effectively enforced;



6) embryos/ova for export are derived from females which:



a) are not affected with BSE;



b) are not the daughters of BSE affected females; and



c) were not suspected of being so affected at the time of embryo collection.



Article 3.2.13.10.



When importing from countries with a high incidence of BSE, Veterinary Administrations should require:



for bovine embryos/ova



the presentation of an international animal health certificate attesting that embryos/ova for export are derived from females which comply with the conditions in Article 3.2.13.5. and paragraph 6) of Article 3.2.13.9.



Article 3.2.13.11.



Meat-and-bone meal containing any ruminant protein which originates from countries with a high incidence of BSE, should not be traded between countries.



Meat-and-bone meal containing any ruminant protein which originates from countries with a low incidence of BSE, should not be traded between countries for use in ruminant feed. For other uses, it should have been processed in plants which are approved and regularly controlled by the Veterinary Administration following validation that each plant can achieve the processing parameters described in Appendix 4.3.3.1.



Article 3.2.13.12.



Bovine brains, eyes, spinal cord, tonsils, thymus, spleen and distal ileum (tissues under study) and protein products derived from them from cattle over six months of age originating from countries with a high incidence of BSE should not be traded between countries.



Bovine brains, eyes, spinal cord and distal ileum (tissues under study) and protein products derived from them from cattle over six months of age which originate from countries with a low incidence of BSE and were born before the date on which the feed ban referred to in point 5) of Article 3.2.13.4. was effectively enforced, should not be traded between countries, unless they comply with the provisions of Article 3.2.13.11.



Article 3.2.13.13.



Careful selection of source materials is the best way to ensure maximum safety of ingredients or reagents of bovine origin used in the manufacture of medicinal products.



Countries wishing to import bovine materials for such purposes should therefore consider the following factors:



1) the BSE status of the country and herd(s) where the animals have been kept, as determined under the provisions of Article 3.2.13.1. and Article 3.2.13.2.;



2) the age of the donor animals;



3) the tissues required and whether or not they will be pooled samples or derived from a single animal.



Additional factors may be considered in assessing the risk from BSE, i.e.:



1) precautions to avoid contamination during collection of tissues;



2) the process to which the material will be subjected during manufacture;

3) the amount of material to be administered;



4) the route of administration.

1Shrieber, R. 1997. Presentation to the FDA Transmissible Spongiform Encephalopathy Advisory Committee, April 23, 1997. Transcript is available in hard copy or on disk from Freedom of Information, HFI-35, Food and Drug Administration, Rockville, MD 20857.

2Office International des Epizooties. 1997. International Animal Health Code, Special Edition, Chapter 3.2.13. pp. 267-274, Paris.


* * * * * * * * * * * *



Reprinted by permission from the Office International des Epizooties.

[rsomer]

Yes, the United States is attempting to regain BSE free status by claiming the Washington Holstein was imported from Canada. If they are successful in doing this American exports of beef will resume, according to OIE rules. Buts lets look at some facts.

In late 1993 Canada kept its BSE status because in this instance Canada's sole case was discovered in a British born Salers cow on a Red Deer, Alta. ranch. Agriculture Canada ordered the slaughter of the entire herd. In addition, and this is an important point, all animals imported from Great Britain since 1982, eleven years prior, were traced and eliminated and the carcasses incinerated. In total 363 animals were killed and burned in special incinerators. See: http://131.104.232.9/fsnet/1996/3-1996/fs-03-27-96-01.txt

Lets compare that to the situation that exists today in the United States. In the last eleven years the United States has imported 40,011 purebred live cattle as listed below. These cattle would have become part of the U.S. cow herd and many of these cows and their calves would still be alive today.

U.S. Imports of Canadian Live Purebred Cattle
1991 2,074
1992 2,549
1993 1,601
1994 990
1995 754
1996 956
1997 971
1998 2,926
1999 5,979
2000 5,629
2001 8,388
2002 7,194

During this same period 1991-2002 the United States total imports from Canada amounted to 14,663,408 live cattle as listed:

Total U.S. Imports of Live Canadian Cattle
1991 904079
1992 1272638
1993 1202289
1994 1010299
1995 1132685
1996 1509158
1997 1376790
1998 1313437
1999 985247
2000 964265
2001 1306155
2002 1686366

Source: http://www1.agric.gov.ab.ca/$department/deptdocs.nsf/all/sdd7799/$FILE/table5.pdf

The U.S appears to be focusing its efforts on the 81 head of Holsteins imported August 28, 2001, ignoring the other 14,663,246 Canadian live cattle imported during the period of interest.

If the world buys into the story that the U.S. is somehow free of BSE if this Holstein is shown to have come from Canada and at the same time Canadian beef is not safe to eat and should be banned from importation then you really can fool all of the people all of the time.
When you consider the level of live cattle trade between Canada and the U.S. it is incredible to think that the U.S. has banned any Canadian product since May 20 while saying their herd is free of BSE and the Canadian herd is not.
And the restrictions of Canadian imports looks like it will continue into the forseeable future unless there is some fair play and commonsense shown by our U.S. trading partners and the world community.

[pandiana]

Apparently the US has already made a presentation to Japan regarding opening the ban on US cattle citing that the BSE affected cow is of Canadian origin.

This info from another forum, but will look for the link if anyone is interested.

[kato]

I personally don't think the Japanese could care less where the cow came from. I bet they are totally aware of how many cattle cross the border, and have made that clear to the US government. If they are having trouble finding the 81, then how do they find 14 million?

[cowman]

Actually who cares if they open the border to live stuff right now? At least the young slaughter cattle? With the crash of their market(around 30 cents in one day) and the rise in the loonie, I doubt many cattle could make a buck?
I think Alberta fats dropped off 22% at a recent satelite sale to 68 cents.
We'll get this garbage sorted out. If the US does manage to weasel their way out of this one, then our government and industry leaders need to quit kissing their butt and start to play hardball! How? Test everything and start taking out full page ads in every paper in the USA and Japan. Pour money into a domestic infrastructure and agressively market our certified BSE free meat. If countries still refuse to accept it then take them to the WTO and sue their butts off.

[rsomer]

U.S. CME Live cattle futures on Friday traded for between 69 and 73 cents. That is in line with longer term average prices for fats.
I think it is reasonable to assume that 50% of the purebred cattle that entered the U.S. in the last 11 years are still in the herd and a small portion of the other live cattle would not have been slaughtered but would have become part of the U.S. cow herd as well. To pull a number out of the air, as many as 75,000 Canadian cows could be assumed to be in the U.S. cow herd on December 9, 2003; the day the Washington Holstein was slaughtered. That suggests the possibility that 1 in 75,000 Canadian cows may be infected with BSE, much more than suggested previously and well above the 1 in 1 million level that would have been acceptable even under the proposed changes to the BSE rules.
If that is true, then we would expect to see a similar infection rate in the 5.8 million Canadian cow herd or potentially 77 BSE positives waiting to be detected. Since it would be assumed that the infected cows were born before the 1997 ban on ruminant protein, those cows are coming 7 years old and will be slaughtered in the coming four years at an average of 1.6 cows per month that presumably will be detected if all slaughtered cows are tested for BSE. This is the potential magnitude of the BSE problem in Canada.
Presently Canada is removing SRM’s from all animals over thirty months of age (OTM). The science says this eliminates the possibility of the food supply being infected with BSE prions. Unless Canada institutes a mandatory cull of cows over 6 ½ years of age so that these animals are eliminated from the herd immediately, 100% BSE testing of OTM cows will ensure that the BSE problem is in the news monthly for the next four years.
Will our food supply be any safer, no because it is already safe due to the removal of SRM’s, there is presently no possibility of transmission of BSE from Canadian cattle. The required health protocols are in place. And the experience in Europe suggests that a mandatory cull does not foster public confidence in our product, on the contrary it would destroy confidence and the good will that our industry has enjoyed from the Canadian public.
Some would say that 100% testing of OTM cattle would open borders. But the facts are that the borders are closed to Canadian beef not for food safety concerns rather the issues are political and protectionist. I see no justification for the United States to close the borders to our beef but we will see what happens January 5 which was to be the last day for the U.S. rule making process. There is some reason for hope due to U.S. concerns that they may have a BSE positive before the OIE rules can be rationalized.
One thing is for certain, our industry and the U.S. industry have harmonized their response to BSE since before 1997. Canada will not test 100% of OTM cattle unless the U.S. does too and that is not going to happen, plain and simple. Calls from Canadian producers for 100% testing are just going to undermine consumer confidence in our product without improving food safety one bit. For certain no animal tested for BSE should enter the food chain until the test is returned negative, but that is already being done in Canada.

[pandiana]

I am not sure I follow you rsomer. If the US cow originates from Canada and was infected in Canada, this would make 2 out of 5.8 million (your figure) or .34 incidents per million head. If you could say that for every detected case of BSE, maybe 10 are now going undetected that would be 3.4 incidents per million head (or 20 cases per 5.8 million). A percentage of these 20 cases would have already slipped untested through the system before symptoms appeared or experiences triple S. Again, assuming that we have had 100% compliance with the feed ban, this number would decline each year as the aged cattle left the system. The average age of Holsteins is quoted as 3.5 lactations and I think beef cattle average 6 calves, so the age distribution of all cattle over 6 years would drop off dramatically. On the other hand, if the distribution of infected animals can be shown to come from a single source of feed, then the distribution would be skewed towards cattle with access to this feed.

It would seem to me that, for our own sake, the only way we can get a handle on just how big this problem is would be to test as many cattle as possible, especially the older ones. Once we have a more accurate assessment of the infection rate, and once we are 100% sure of compliance in feed regulations, it will be very simple to target the high risk cattle and expedite their removal from the system. Nobody wants to find another one, but if the second case of BSE is ours we can no longer ignore the fact that the probability is that there are others. Without a doubt, the risk to human health is still infinitesimally small, but as we have said, this is politics not health.

I think what we and the Canadian government have to ask ourselves is whether we are serious about cleaning up a problem or would we rather bat it around for a while longer to see if we can score political points. The US must ask the same questions.

[cowman]

rsomer: I'm afraid you just don't get it! The consumer will make his choice to buy any product he wants. Now we can quote science all we want but that just doesn't matter. Especially when the "science" isn't very reliable? How many times can we say "The science says this...maybe?" and expect the consumer to buy it?
You seem to have this attitude that a few cases of Mad Cow are okay. And I presume that a few human deaths are okay? And please don't quote how much worse SARS is or salmonella or something. If I'm dead from Mad Cow I don't really care about all the other bad things that might have got me.
Do you really want to raise a product that might kill some person? When you could have raised a safe product for the cost of a cheap test? Quite frankly I'm starting to consider not buying any more beef until I'm sure it is safe. And I think I will look into buying some of the test kits from the outfit in Colorado before I sell anymore cattle! I'm just not into killing people.

[rsomer]

Cowman: Our beef is safe without a test.
If you trust the people who say their tests work then why would you not trust the people who say that removing Specified Risk Materials or SRM’s eliminates the possibility that BSE prions are present in the food product. They are the same scientists.
I tend to think the only useful purpose of a test is to measure the incidence of BSE within a given population of cattle, not to provide assurances of food safety. Our assurance of food safety is accomplished by removing the SRMs from every single animal over 30 months of age.
I frankly am suspicious that the link between BSE and nvCJD even exists but to be better safe than sorry I agree that the steps we are taking such as removing SRMs represent an abundance of caution. Even the worst case scenarios suggest the incidence of BSE is very low in Canada.
You are thinking of the very, very unfortunate situation in Britain where BSE was widespread in the British cow herd yet no one took any preventative measures whatsoever and then you are drawing incorrect conclusions about the Canadian situation.
Our incidence of BSE is still very low yet we are taking all the correct measures to ensure the safety of our food product. The Canadian consumer seems to be educated about our product and internationally consumers would accept our product if they had the opportunity.
I tend to think there is more chance of your cow killing someone out in the field at calving time then there would be when she is on the plate. Are you willing to erect a 6 foot high solid fence around your fields to ensure that no one can enter and get trampled by a cow?

[cowman]

rsomer: The fact of the matter is we don't know how safe our cow herd is. And we never will unless we test? How do we know how many cows ate infected feed? To not test is just another version of Shoot, Shovel and Shutup. No tests...no BSE...problem solved? Perhaps. At least until people start showing up with vCJD? Then we have a nightmare that no amount of BS will solve?
If the science says removing SRMs makes the product totally safe then why the problem with the older animals? If the scientists and the politicians are so sure of this then why aren't the borders open? I do understand it is about trade and politics but how is the consumer to see all this? On the one hand we say it is safe but on the other hand we say it isn't? Is this supposed to make the beef consumer have confidence in the safety of the product? What would make the consumer totally confident?

[rsomer]

You are absolutely right that the United State’s two faced approach to BSE is undermining consumer confidence. On the one hand the U.S. says the Washington Holstein that the USDA allowed to enter the food chain does not pose a food safety risk because the SRM’s were removed. On the other hand the U.S. continues to block imports of Canadian cows because of BSE fears. They can’t play it both ways. The consumer would be more confident if governments had a more consistent response to BSE.

Cowman: you will be interested to read these links that detail the BSE testing done in Canada since 1992. I long have been very uncomfortable with the level of testing done. While on one hand Canada was saying we were free of BSE, Canadian officials really did not act as if they wanted to find a BSE positive. The same situation exists in the U.S.
I do think our food is safe. I do think removing SRM’s is more effective at safeguarding our food supply than testing would be. That the U.S. is blocking our product is not backed up by the science.
Canada and the United States will be increasing their testing in the future. On the one hand we as Canadian producers acknowledge we are in a North American industry yet on the other hand we hear that we to have go our own way and establish Canadian protocols and standards. However, if we wish to remain part of a North American industry we will be harmonizing our response to BSE with the U.S. response. This is what we have done since BSE was first recognized as a threat. Canadian and U.S. government officials will determine an appropriate level of testing for BSE and we will proceed on that basis. I do not see the U.S. testing all their cows, therefore I do not see Canada doing it either. This said, I often dispair that we are not really part of a North American industry, every time the going gets rough Canadians are on their own.

The links are:
http://www.inspection.gc.ca/english/sci/ahra/bseris/bserisb1e.shtml#Btab1
http://www.inspection.gc.ca/english/sci/ahra/bseris/table1e.shtml

Since Canada began testing for BSE in 1992 we have tested a total of 13,291 animals to June 2003. I really agree with more testing, how much I am not sure. I think we need to get more rational OIE rules in place first before we test all cows. That needs to be done quickly.

[cowman]

rsomer: Public perception is our main problem. As long as the Canadian and American consumer percieve beef is safe things can be worked out. Safeguards are slowly being put into place that should solve the problem.
If the Canadian and American governments are being truthful when they say they will test more animals then we should expect more BSE animals? How will they handle this? How will they convince the consumer the product is safe? Will the consumer start to demand that all cows over a certain age be tested? Or will the governments continue to stonewall and let the consumer desert the beef industry? Or will it be a sophisticated Shoot, shovel, and shutup? Pour the money into advertizing the safety rather than actually practising safety?
Are they playing games while you and me go broke? If so then why? Who benifits?

[pandiana]

Some good points cowman.

[pandiana]

"Our incidence of BSE is still very low yet we are taking all the correct measures to ensure the safety of our food product." "Since Canada began testing for BSE in 1992 we have tested a total of 13,291 animals to June 2003. I really agree with more testing, how much I am not sure."

rsomer, this is the problem, alright. Even if we had 20 or 77 infected cattle that are out there, the risk of a human case of vCJD is still extremely small. Therefore you could assume our food is safe (certainly more safe than the risk associated with meat and vegetables contaminated with pathogenic strains of E coli and Salmonella. But what if, like UK, this is the tip of the iceberg? How do we know if we have BSE or, more importantly, don't have BSE if we don't 'seriously'look for it?

[cakadu]

Seems to me if you go looking for trouble - you'll find it. As was pointed out in another thread - are we willing to do WHATEVER it takes in order to ensure what you are asking for?

I want my food as safe as possible, but I think that based on what I have read and heard that there are far greater risks than BSE will ever be to me. Part of the reason for my confidence is that I have never eaten any of the SRM and don't ever intend to.

Risk is an individual thing and is different for all of us.

I agree cowman, don't lie to the consumer, because that shakes confidence more than you know. The consumer may be fickle with all the choices out there, but they have long memories and are not willing to forgive what they perceive is anything less than the truth.