Group raises serious concerns about credibility of government surveillance program
YONKERS, NY (July 26)–Consumers Union is raising serious questions about the credibility of the U.S. Department of Agriculture’s (USDA) expanded voluntary mad-cow surveillance program and is asking the agency to release details on the more than 400,000 cattle tested. In a letter sent to Agriculture Secretary Mike Johanns today, the group cited serious deficiencies uncovered by the Office of Inspector General in the earlier years of the program.
Consumers Union specifically requested data on:
- The geographic location of sampled cattle (including the state where the cow was born, raised, and slaughtered)
- The age of the cattle tested (CU currently supports testing of all cattle above 20 months)
- The disease/high-risk status of the cattle (for example, did they show symptoms of central nervous system disease, which are common symptoms of mad cow.
“The government keeps telling Americans that they can trust that their beef is safe from mad cow, even going so far as to say that finding BSE is like searching for a needle in a haystack. Yet, since the agency has so far failed to publicly disclose any information whatsoever about the details of the program, it makes us wonder how meaningful their search for the disease is at all,” says Dr. Michael Hansen, PhD, a Senior Scientist with Consumers Union.
“We want to know exactly which cattle were tested and whether or not they really represent the most valid scientific sampling of the highest-risk animals from across the country. If the USDA wants to truly reassure the American people, they should answer our questions. Their failure to do so would make us wonder what the agency is hiding,” adds Hansen.
Consumers Union’s letter comes after the USDA’s announcement last month that a cow originally pronounced last November to be negative for mad cow disease turned out upon re-testing to be positive.
A copy of the letter follows:
July 25, 2005
Hon. Mike Johanns
Secretary of Agriculture
US Department of Agriculture
1400 Independence Avenue, SW
Washington, DC 20250
Dear Secretary Johanns:
We are writing to you because we are concerned about the meaningfulness, credibility and lack of transparency of the expanded BSE Surveillance Program (hereafter referred to as the “Program”) that has been carried out by the U.S. Department of Agriculture’s Animal Plant Health Inspection Service (APHIS) beginning June 1, 2004. The Office of Inspector General’s (OIG’s) Audit Report on the first phase of the BSE Surveillance Program (e.g. 1990-2004) raises serious questions about the quality of the data gathered under the Surveillance program.
We are concerned that there are potentially serious methodological problems and/or flawed assumptions involved with the expanded BSE Surveillance Program. These methodological problems are that sampled brains may not be a proper geographical sample of the high-risk population, and that the highest risk brains may not be included.
The failure of the USDA to release any data whatsoever about the details of the Program, such as location of sampled cattle (state where born, raised, slaughtered), age, and disease/high-risk status (e.g. did it show symptoms of central nervous system [CNS] disease) heightens concerns about whether the sampling is being conducted in a valid matter.
We are concerned about whether adequate geographic distribution is being achieved in the Program. A basic problem is that participation in the Program is voluntary. The stated goal of the USDA’s expanded BSE surveillance program is “to collect samples from as many adult cattle from the high-risk population as possible in 12-18 months while ensuring that there is a statistically appropriate geographical representation of the adult cattle population in the United States”. For this sampling program to be statistically valid, the cattle chosen for testing must be a random geographical sample of the high-risk population. To ensure a random sample, the Program should be mandatory. The OIG’s Audit Report on the first phase of the Program (e.g. 1990-2004), found that prior to the start of the expanded surveillance program (e.g. June 1, 2004), sample collection was not geographically random, but rather was “concentrated in a few slaughter establishments and renderers in a few States.” In addition the OIG noted that “APHIS has no contingency plans if geographical targets are not obtained” . Thus, we ask USDA to release information on the geographical location of all the cattle that are sampled as part of the Expanded BSE Surveillance Program.
The age of sampled animals is also important. Although BSE is thought typically to infect animals at a very young age, the disease can have a long incubation period and is usually detected in older animals (detection is more difficult in young animals incubating the disease). Although animals as young as 20 months (United Kingdom ) or 21 months (Japan ) have been found to test positive for BSE, the detected disease prevalence is higher for older animals. The Texas cow confirmed with BSE last month was about 12 years old. Dairy cattle are at higher risk for BSE compared to beef cattle, because, being productive for a number of years, they are usually slaughtered at an older age than beef cattle. Dairy cattle are also more likely to receive protein supplements in their feed (to support their milk production) than beef cattle. Some 80% of the BSE cases in the UK occurred in dairy cattle . Thus, we feel that all elderly dairy cattle should be sampled for BSE. Consequently, we ask what are the ages of all the cattle that have been sampled for BSE?
Another potentially serious methodological problem with the expanded Program is whether it includes the highest risk animals. According to USDA’s 2004 Expanded Surveillance Plan, the high-risk population to be tested should include “adult cattle showing clinical signs involving the central nervous system (CNS), and dead and non-ambulatory cattle where the clinical signs cannot be adequately evaluated” . But not all animals in this high-risk population are equally high risk. The highest risk animals are those exhibiting symptoms consistent with BSE, such as rabies-suspect animals that test negative for rabies, and animals exhibiting symptoms of CNS disease. In fact, when the USDA first began the surveillance program in 1989/1990, there were only two categories of cattle in the high-risk category: rabies-suspect but rabies-negative cattle and cattle exhibiting CNS symptoms. It wasn’t until 1993 that USDA added downer (e.g. non-ambulatory) cows to the list of high-risk cattle that were to be sampled for BSE testing.
All aggressive animals are tested for rabies. If the test is negative, then some other condition, possibly BSE, is responsible for the aggressive behavior. Thus, rabies-negative cattle are perhaps the highest risk cattle of all. USDA states that all rabies-suspect cattle that test negative for rabies should be tested for BSE . However, the OIG’s Audit Report on the first phase of the Program (e.g. 1990-2004), points out that only a small percentage of rabies-suspect, rabies-negative cattle were actually tested for BSE. The OIG report surveyed five state laboratories and found that only 16% of the rabies-negative samples (94 of 586) from those states were sent for BSE testing . The OIG noted that there was neither a requirement for rabies-negative cattle to be tested nor a formal mechanism in place to routinely submit such samples for testing. The OIG noted that, of 175 rabies-negative cattle tested for rabies at a laboratory in Iowa—in the same state as USDA’s National Veterinary Services Laboratory (NVSL)—during FY 02-03, only two were sent to NVSL for testing for BSE. Indeed, the OIG noted that as of 2004 officials from South Dakota were not even aware that rabies-negative cattle could be sent for BSE testing! Finally, the OIG noted that “As of June 1, 2004, APHIS has not provided us with any detailed plans on how samples for this targeted high-risk group will be obtained” . Since this is perhaps the highest risk group for BSE, we must ask how many rabies-negative cattle occurred in the U.S. from June 1, 2004 to July 1, 2005 and how many of these rabies-negative cattle were actually tested for BSE? If not all rabies-negative cattle, considered to be the highest-risk cattle, are sampled, then we question how useful the data are on the rest of the animals.
Cattle with CNS symptoms
Cattle that are condemned at slaughter for CNS symptoms are also considered to be among the highest-risk cattle for BSE. According to the OIG’s report, USDA’s Food Safety Inspection Service (FSIS) condemned 680 cattle for CNS symptoms between fiscal year 2002 and 2004. Of these 680 cattle 357, or 52%, were classified as adults. Using APHIS records, OIG found that only 162 cattle condemned for CNS symptoms were tested for BSE in this period; this represents 45% of the adult cows (162 of 357) or 24% of all cattle (162 of 680) condemned for CNS symptoms. In April, 2004, a cow condemned for CNS symptoms at a slaughter plant (Lone Star Beef) in San Angelo, TX was not tested for BSE, even though the FSIS officials at the plant had asked that the animal be tested for BSE . Apparently, an APHIS official in Austin, Texas had overruled the FSIS officials at the plant. As a result of this incident, APHIS and FSIS issued a joint notice in May 2004 (FSIS Notice 28-04) which stated that henceforth all animals condemned for CNS symptoms would be tested for BSE, regardless of the age of the animal. We thus ask how many cattle were condemned for CNS symptoms between June 1, 2004 and July1, 2005? How many of these cattle were actually tested for BSE?
Cattle that died on the farm
As the OIG report stated,
“Identifying truly high-risk cattle that die on the farm may be complicated by the reluctance of producers to submit them and the motivation [of others] to mischaracterize low risk carcasses as “high risk” since only the latter may qualify for reimbursement. These inherent problems can lead to an understatement of the projected maximum BSE prevalence rates for truly high-risk cattle and a reduced chance of detecting BSE, if it exists” (OIG, 2004: pg. 16).
According to USDA’s 2004 Expanded Surveillance Plan, the high-risk animals that die on the farm make up the largest component of USDA’s targeted high-risk population. According to the USDA’s Expanded Surveillance Plan, 56% of the 446,000 adult cattle in the “high risk” group will be “adult cattle that die on farm each year due to unknown reasons or reasons that could be consistent with BSE-related clinical signs” . In the General Accounting Office (GAO) audit report on the FDA and USDA actions on BSE, GAO pointed out that USDA didn’t sample many animals that died on the farm and also didn’t separately track brains from such animals; such animals were counted in the downer cow category . The OIG report noted that “we could not determine if samples from this targeted group [cows that died on the farm] have been obtained in the past” italics added. We note that the November, 2004 cow that ultimately tested positive has now been found to be a “dead” cow—it showed up dead at the slaughter plant and was redirected to the Champion Pet food plant in Waco, Texas . Thus we ask How many cattle died on the farm in the U.S. between June 1, 2004 and July 1, 2005? How many dead cattle were actually tested for BSE?
These very important basic facts about the USDA’s Expanded Surveillance Program are essential to an assessment of the validity of the Program. The American public, and America’s trading partners, have had their faith shaken in USDA’s Surveillance Program by the disclosure of severe shortcomings in its confirmation procedures. These shortcomings led USDA to announce on November 22, 2004 that a cow was a confirmed negative when seven months later proper testing showed it was, in fact, positive for BSE. In order to maintain trust in its Surveillance Program, USDA should immediately answer our questions and disclose to the public the details of the Program.
Michael Hansen, Ph.D., Senior Scientist
Jean Halloran, Director, Food Policy Initiatives
Contacts: Michael Hansen, 914-378-2452; Jen Shecter, 914-378-2402