New Proposed FDA Regulations Fail to Protect the Public from Mad Cow Disease - Again.

The U.S. Food and Drug Administration (FDA) announced new proposed rules in October to address the spread of mad cow disease in the United States. Unfortunately, these new rules continue to put the public at risk. The new rule would only require the exclusion of the brains and spinal cords of cattle 30 months of age and over from use in animal feed. This would still allow younger cattle, blood and blood products, some cattle fat, plate waste and poultry litter contaminated with cattle meat and bone meal, to be fed to cattle. Despite the knowledge that mad cow (or BSE) is spread through animal feed contaminated with such materials, FDA still refuses to take the only step known to stop the spread of mad cow disease – a complete ban on feeding mammalian materials to food animals.

The second confirmed case of a BSE infected cow in the U.S. should have been a call to action for the U.S. to finally put meaningful protections in place. Instead, FDA seems more concerned about protecting industry than citizens. Take action now and tell FDA their refusal to close these dangerous loopholes is unacceptable.

Though the government has investigated three possible cases of Bovine Spongiform Encephalopathy (BSE), commonly known as mad cow disease, in the U.S. – two of which were found to be positive for the fatal brain-wasting disease, they continue to leave the American public vulnerable. Scientists have concluded that exposure to the BSE agent causes a variant form of Creutzfeldt-Jakob disease (nvCJD) in humans. The common characteristics of mad cow disease and nvCJD are that they are both invariably fatal.

In January 2004, the FDA announced they would close the loopholes in the feed ban to address the spread of mad cow. Now, nearly two years later, they have proposed yet another woefully inadequate regulation.

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Sample Letter for Campaign

Dear [ Decision Maker ] ,

I am writing in regard to FDA Docket # 2002N-0273 - proposed rules on food / feed ban to address the spread of mad cow disease in the United States.

While I appreciate FDA's acknowledgement that the current feed rules are in need of strengthening, I find the rules as currently proposed woefully inadequate. Given the severity of the threat mad cow poses both to American cattle and public health, nothing short of 100% protection is acceptable. The only step known to prevent the spread of mad cow disease is a complete ban on feeding mammalian materials to food animals.

The UK took several halfway steps like those currently proposed by FDA, but only when they stopped feeding all mammal materials to any food animals, were they successful in lowering the number of cases to less than ten a year. While the U.S. has found two cases of mad cow, five cases have been confirmed in Canada, where we have recently re-opened the border for Canadian beef and live animals under 30 months of age. Two of the twenty cases of mad cow disease identified in Japan came from cows younger than 30 months.

Given our limited testing program in the U.S. - only one percent of cows are tested at slaughter, and new scientific research showing mad cow disease to be much more contagious than previously thought, FDA needs to take immediate, meaningful action to protect the American public:

- Institute a complete ban on the feeding of all mammalian materials to any food animals, including the use of blood and blood products, plate waste, and gelatin products and proteins from horses and pigs.

- Ban the use of poultry litter, including bedding, waste and spilled feed, as cattle feed. The use of such feed can allow materials not permitted for ruminants to be fed back to cattle as part of feed created from poultry litter.

- Ban the use of salvaged pet foods in ruminant feed. Pet food destined for the retail market can make its way back to the cattle feed market as distressed or salvaged pet foods.

- Ban the use of possible "silent carriers" of mad cow like diseases, such as pigs and chickens, in cattle feed.

- Require companies that process both feed for food animals and pet foods to use separate facilities to prevent any contamination of feed destined for food animals.

- Require detailed records be kept throughout the feed chain for a minimum of 10 years.

As an American consumer, I am deeply concerned about the safety of the meat I purchase. I depend on the FDA to put stringent regulations in place to protect public health, and I find these current shortcomings disappointing and worrisome. I urge you to take immediate action to address this important issue and restore my confidence in U.S. beef and the agency.

Thank you for taking my comments into consideration.

Sincerely,

Campaign Launched:
November 14, 2005