Saturday, April 18, 2009

FDA Plans to Break Food Safety Promise to America

Op-Ed by R-CALF USA CEO, Bill Bullard

Washington, D.C.  - The U.S. Food and Drug Administration (FDA) plans to break its promise to American consumers to timely upgrade the animal feed ban designed to protect U.S. consumers and the U.S.  cattle herd against the heightened risk of bovine spongiform encephalopathy (BSE, or mad cow disease). 

For folks that don't know, the feed ban keeps animal parts out of animal feed because cows eating cows is linked to Mad Cow Disease.  

For folks who don't know, the FDA is supposed to protect the public.

For the FDA which don't know, the FDA is supposed to protect the public.

Now correct me, but isn't this the same FDA pushing a host of "food safety" bills in Congress right now?  And don't those same bills contain NAIS which is supposed to be about tracing animal disease ... so as to protect the public?  

If the government wouldn't make the disease from scratch (or feed), so to speak, wouldn't they not have to trace it and wouldn't that save things from going in a circle?

Will Rogers is needed just about now. 

He'd probably be partial to their calling the feed with the animal parts in it, "enhanced." 

Scientific studies have linked BSE to cases of variant Creutzfeldt-Jakob Disease (vCJD) in humans, an invariably fatal disease that most likely results from human consumption of infectious material from cattle with BSE. There have been 212 human deaths in 11 countries caused by vCJD, including the United Kingdom, and there are five known living humans with the disease.    

On April 9, FDA published a special filing in the Federal Register giving the public only seven days to comment on the agency's plans to delay the scheduled April 27, 2009, implementation of its upgraded BSE feed ban.

FDA sure seems in a big hurry to get that Mad Cow feed ban lifted.   Guess when one is breaking a promise and risking food safety, it's best to get it over with quick.  Then again, without it, they can tell the public they're in more danger so we need the "food safety" bills.

The U.S. faces a heightened risk from mad cow disease because it continues to import millions of live cattle from Canada, where the disease prevalence is between three cases per million cattle to eight cases per million cattle. The U.S. Centers for Disease Control and Prevention (CDC) states this prevalence in Canadian cattle is 18-fold to 48-fold higher than the prevalence in the United States.

Now, that's the USDA.  Letting sick animals into the country.  

FDA cooks up the diseases and the USDA gets right in on the game, and goes and finds it and brings it to us.  Then they want NAIS to trace animal disease. 

That's our government at work.  

You gotta have a problem first, don't you?  Else it would make no sense to use tax money to "fix" it.  So, we got the FDA cooking up diseases and the USDA inviting cows with it to "come on down."  

And NAIS is just perfect because it won't fix a thing so the problem won't go away and so millions more are needed.  

So, the USDA needs farmers signed on to show NAIS can work but farmers are a whole lot less than excited about NAIS.

But that USDA is just as clever about bringing farmers to NAIS as they are about bringing disease to the country.  It's the "come on down" plan, only to get farmers on, they add a little extra touches - paying 4-H kids to sign up their parents and neighbors without their knowing, and for a reward; sending out notices saying it was mandatory until R-CALF sued to stop them; making vets sign on folks against their will when they come in with sick animals; making folks have to sign up to show at fairs, ...  So many ways, so much imagination. 

They're just doing their job.  

Good to know those "food safety" bills would put the USDA together with the FDA to watch over our food, like they are watching over the cow's feed and diseases.  

FDA was johnny on the spot about cherries.  Saved us all from even learning grandmoters were right all along about cherries.   Cherries are better for pain than aspirin, tylenol ...  And safer.

But the FDA protected those drugs like they had a personal stake in them.  

The World Organization for Animal Health (OIE) and scientists the world over stated that Canada's heightened BSE risk cannot be effectively mitigated with the basic ruminant-to-ruminant feed ban implemented in both Canada and the U.S. in 1997. Following the detection of multiple cases of mad cow disease in cattle born years after Canada's original feed ban, Canada finally relented to scientists' urgings and upgraded its basic feed ban in July 2007. The new feed ban protects Canadian consumers against known BSE transmission routes: cross-contamination and inadvertent feeding of contaminated cattle parts. Unfortunately, 10 of Canada's 16 native mad cow disease cases were found in animals born after the implementation of Canada's original feed ban.

One year ago, the FDA issued a news release touting its promise to upgrade the U.S. feed ban by stating, "FDA Strengthens Safeguards for Consumers of Beef," and informing consumers that the new feed ban would become effective on April 27, 2009,  after allowing time for the industry to adapt its practices to the new requirements.

A government promise, friends.  Those words don't sit too well next to each other.  Isn't the government saying the "food safety" bills won't hurt farmers?  Didn't they say NAIS would be voluntary?

But even before that, in late 2007, the U.S. Department of Agriculture (USDA) issued regulations that now allow even higher-risk Canadian cattle into the U.S. – cattle over 30 months (OTM) of age.

Well, what good is it to trace disease if you ain't got none?  Gotta bring some in.

USDA's base-case risk model predicts that the importation of OTM cattle will result in the introduction of 19 BSE-infected cattle into the U.S. causing the subsequent infection of two U.S. cattle over the next 20 years. Human exposure to BSE also was predicted to increase by more than 15 percent compared the earlier base-case modeling conducted in 2003 by Harvard University.

The unconscionable irony ...

Now that's where Will is missing out and sorely missed.

... is that the U.S. is importing millions of higher-risk Canadian cattle – allowing them to commingle with the U.S. cattle herd and to freely enter the U.S. human food supply and animal feed supply – without affording U.S. consumers and the U.S. cattle herd the benefit of the scientific safeguards implemented by Canada to protect its citizens and its cattle herd from the BSE infectivity known to be circulating in its cattle herd. In short, the U.S. is accepting Canada's higher BSE risk without the protections necessary to mitigate that higher risk.  

So, let's see.  The USDA is mixing Canada's BSE cattle with ours just at the same time the FDA is saying let's have animal feed with Canada's BSE animal parts?  I can see why folks in government want these two agencies to work together for "food safety."  They are of a like mind.  We won't say what kind of mind, but they're definitely kin in how they think.

Hard not to notice that we get the diseases and Canada gets the safeguards.  Guess they aren't blessed with an FDA and USDA to make things interesting there.

The thousands of U.S. cattle producer-members of R-CALF USA recognize that we have an absolute obligation to protect our U.S. consumers from mad cow disease.

Where we come from, that almost sounds like real food safety.  

Together, the USDA and FDA are undermining our efforts.

Yeah, but they got bills they "call" food safety, so that must make it so.

Under no circumstances should FDA delay implementation of the new feed ban, which already has been found necessary to mitigate Canada's heightened BSE risk, while the U.S. continues to import Canada's higher-risk cattle.  

Either USDA must immediately eliminate the source of this heightened BSE risk by prohibiting the importation of OTM Canadian cattle, or, FDA must immediately implement the new feed ban to mitigate this heightened risk.  There are no responsible alternatives.

Now, R-CALF, you're taking all the fun out "tracing" diseases.  They got nothing to trace now since our system has worked so well.  How are they going to say they need all that expensive equipment and global tracking tags and regulations out the whazoo for keeping tabs, if farmers have been handling things with common sense and good feed and plain old ear tags and that works?  

What's the sense of common sense when it stops millions for electronic chips from going to those in need at those big electronic tag companies?  What's the sense of  good sense when it takes all the fun out of looking for diseases by having none?

The FDA has an absolute duty to protect U.S. citizens from the foreign health threat of BSE and must not kowtow to the very industry trade associations – the National Cattlemen's Beef Association and the American Farm Bureau Foundation – that are fighting to expose U.S. consumers to Canada's BSE risk before Canada can demonstrate that it has eradicated this deadly disease from its cattle herd.    

Almost sounds like R-CALF cares more about food safety and animal diseases than the government.  But the government has got the big new programs with some new fancy promises about tracing diseases and they are talking up a big "food safety" agency.  

What's R-CALF got to show?  Common sense and no diseases.  Ain't no money in either.  No big programs needed.  

The FDA is making animal diseases, the USDA is even seeking them out, together they are worried sick about food safety and animal diseases and ready to give prison terms to farmers who kept us safe.  Getting rid of those farmers is to make us all "food safer."  

For those who'd like to express themselves about "food safety" and NAIS, feel free:

"We reject all forms of food dictatorship. We oppose all deceptive attempts
to industrialize the food supply under the guise of "food safety." Current bills
before Congress such as HR875, S425, HR759, etc., lack any producer protective
language patterned after Fair Labor Standards Act, 29 USCsec 203(s)(2)and DSHEA
protective language of the 2007 FDA act, Section 1011.
They are therefore unacceptable to the members of a free society and must be

Urgent 3-Part Action Item:
Step 1: Click here to email the President NOW

Step 2: Call the White House switchboard at 202-456-1414 and the comment center 202-456-1111. Let's keep those phones ringing!

Step 3: Click here to tell Congress "NO!" to all of the fake food "safety" bills. They provide neither real, wholesome food nor safety:

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