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Packers Struggle To Implement
New BSE Regs; Questions Abound  

By Colleen Schreiber           

            WASHINGTON — Fed and non-fed cattle slaughtering facilities were scrambling this week to implement the changes imposed by Secretary of Agriculture Anne Veneman in late December as a result of the Washington state BSE case. The changes deal with process controls for advanced meat recovery, “specified risk” material, product holding and stunning.

            Because most scientific evidence indicates that BSE affects older cattle, typically those over 30 months of age, the new regulations continue to target this age classification as well as non-ambulatory animals, which are also considered to be higher risk animals because their symptoms may reflect BSE infection.

            The U.S. Department of Agriculture’s Food Safety and Inspection Service released the rules late last week, and the three rules and one notice were published in the Federal Register on Monday. The changes became effective immediately upon publication, though there is a 90-day comment period. Monday was the first day that plants were to begin compliance, and that process started with an “awareness” meeting with government officials.

            The new rules are as follows:

            — An interim final rule declaring that the Specified Risk Materials; the skull, brain, trigeminal ganglia, eyes, vertebral column, spinal cord and dorsal root ganglia of cattle 30 months of age or older; and the small intestine of all cattle are prohibited in the food supply. (Tonsils were already excluded).

            — An interim final rule expanding on the prohibition of central nervous system tissues in advanced meat recovery products. AMR technology removes muscle tissue from the bone of beef carcasses under high pressure without incorporating bone material.

            — A final rule to prohibit air injection stunning.

            — A notice announcing that FSIS inspectors will not mark ambulatory cattle that have been targeted for BSE surveillance testing as “inspected and passed” until negative test results are obtained.

            Documentation clearly identifying the age of the animal must now accompany all cattle destined for slaughter. Documentation deemed acceptable, for example, is a “birth certificate” or “cattle passport.”

            If the Veterinarian Medical Officer examines the records and finds significant reasons for questioning their validity, he is to verify the age of the cattle through dental examination. The VMO is to consider cattle to be 30 months and older when the examination of the dentition of the animal shows that at least one of the second sets of permanent incisors has erupted.

            The rule further states, “FSIS recognizes that the permanent incisors of cattle erupt from 24 through 30 months of age, but the Agency has determined that the described dentition procedure will be most protective of public health.”

            This particular issue was one of the big topics of discussion during a Texas Cattle Feeders Association board meeting this week.

            “At this point there’s more questions than anything else,” says TCFA communication director Burt Rutherford. “We don’t know how many cattle this is going to affect; we don’t know what the discounts are going to be. I think by next week we’ll have a better idea of what the real market is going to be on these animals and how the packers are going to handle this.”

            There were all kinds of stories in the rumor mill late last week and early this week with respect to the dentition issue. One story was that Excel, which typically tries to avoid older cattle, was finding one to two percent in the 30-month age category.

            “The research indicates that even with the second pair of incisors, you’re still under 30 months of age,” Rutherford says. “But that’s the rule that the Canadians live under, and if we’re to match our regulation to theirs, then we have to follow.”

            “The talk is that the packer will mouth everything on the kill floor,” says Fort Worth rancher Jim Link. “If it’s older than 30 months they’re required to pull all the SRM and the carcass would be treated like a hard bone carcass.”

            Link says he doesn’t see how packers could enforce this on cash cattle.

            “Once the cattle walk off that scale, they belong to the packer.”

            There was also talk, however, that some feeders on the South Plains had to sign off on some cattle before they ever left the yard.

            Link, like many in the industry, is concerned with the accuracy of dentition, particularly with early maturing breeds like Angus.

            “An Angus can mouth at two when she’s barely over 1.5 years,” he points out.

            On the other hand, Link notes, ossification isn’t all that scientifically valid, either.

            “I know this because of personal experience,” Link says. “I’ve fed calf crops before, and I had one that I knew the date of birth on that was pulled out and classified as a hard bone even though it fell well within that ‘A’ maturity classification.”

            While beef processors generally support the new regulations, there are still many unanswered questions about the implementation process and even more questions about what kind of impact these changes will have on the economics of the beef industry. Others question whether these new proposed changes will encourage export markets to reopen in a timely fashion.

            “It is understandable and prudent for USDA to review our nation's regulatory firewalls that protect against BSE,” says American Meat Institute president and CEO J. Patrick Boyle.

“The new measures are very aggressive and indeed extraordinary measures that go well beyond international standards in an effort to protect cattle herds and to bolster consumer confidence in beef safety. In the wake of these announcements, our trading partners must consider an immediate reestablishment of beef trade with the United States ,” Boyle says.

            “We support the Secretary, and we applaud her for her quick and decisive action,” adds Southwest Meat Association executive director Joe Harris. “We hope that we didn’t go too far on some things, and I think time will tell if we did.

            “Will these steps be enough for our export customers? That’s the question now, but I am optimistic that once the rules are in place and being implemented that they will help open up the borders.”

            The Office of International Epizootics, the international animal health governing body, as of last Friday recognized the United States as what they call "provisionally free" of BSE as opposed to being considered as having BSE. Experts believe this will help in reopening trade with foreign countries.

            While USDA has said from the beginning that the BSE testing and surveillance program in the United States is more than sufficient, officials say the new measures are being implemented, in part, to further allay consumer concerns as well as the concerns of various trading partners.

            There is a belief, however, among some in the cattle industry that USDA has gone beyond the necessary level.

            “It’s somewhat frustrating to many producers that in this climate we have to implement practices that are more inclined to improve the perception with minimal improvement in the safety,” says San Antonio rancher Jim McAdams.

            But National Cattlemen’s Beef Association president Eric Davis insists that the facts and science will continue to guide the government and the industry.

            “There isn’t anything wrong with the systems in place,” Davis insists. “As an industry and as a country, we should be lauded for the triple firewall that we have had in place with regard to BSE. Nevertheless, we have had a positive in this country, and we’ll go where the facts and the investigation leads us. We’ll go with the science as best we know it. And if we need to go to a quadruple or quintuplet firewall, then that’s where will go in order to provide a safe and wholesome food product.”

            On December 30, Veneman also implemented a change with respect to “downer” animals. Specifically, USDA has banned all downer cattle from entering the human food chain. Downer animals include all seriously crippled animals and non-ambulatory disabled livestock. Non-ambulatory livestock are defined as those that cannot rise from a recumbent position or that cannot walk, including but not limited to those with broken appendages, severed tendons or ligaments, nerve paralysis, fractured vertebral column, or metabolic conditions.

            While generally supported by the beef industry, this change has raised several questions, and industry organizations are seeking clarification. The questions include, for example, whether an animal that can walk despite a broken bone can be processed and whether a non-ambulatory animal can be processed for the owner’s personal consumption.

            “We certainly applaud the Secretary on implementing these new changes,” says Texas and Southwestern Cattle Raisers executive director Matt Brockman. “That said, there are questions that need to be answered relative to such things as the definition of non-ambulatory animals, for example.

“We’re going to stay after USDA until we get those answers,” he insists. “The other important aspect of all of this is that we maintain an effective and practical — and I underscore practical — surveillance system. It has to be those two things.”

            The U.S. has had an active BSE surveillance program in place for 13 years. Many question how the surveillance program will be carried out now that downer animals will no longer be accepted at packing houses and thus will not enter the testing stream.

            The OIE has established guidelines for the number of samples that should be tested each year. For the United States , OIE recommends a surveillance level of 433 samples per year. However, the rate of surveillance in the United States for each of the last five years has been at least double the amount recommended by the OIE. Last year, testing reached an all-time high with more than 47 times the number of cattle recommended by the OIE being evaluated. The U.S. system is designed to detect BSE even if it were occurring in less than one in a million cattle.

            Some European countries, as well as Japan , have instituted extreme testing programs because their countries face a BSE epidemic. Unlike the United States , those countries did not put preventive measures in place and did not begin formal BSE surveillance until late in 2000.       

            In the European Union, all cattle for human consumption older than 30 months, all dead-on-farm cattle and emergency slaughtered cattle over 24 months, and all suspect animals independent of their age are tested for BSE.

            During the first three months of 2003, a total of 2.5 million BSE tests were carried out in the EU, 387 of which were positive. Most of these cases were found in the so-called “risk” animals (mainly fallen stock and emergency slaughter).

            Japan tests all cattle for BSE. They slaughter approximately 1.3 million animals per year.

            Finalizing a strategy for surveillance that takes into account the new regulatory changes is a work in progress, but Texas Animal Health Commission executive director Bob Hillman says he’s confident that the U.S. can have an effective surveillance system without slaughter plant testing. Rendering facilities, for example, have agreed to pull samples for testing. There has also been talk about collecting samples on farms and ranches. Most likely, that would occur with the help of state veterinarians.

            “We’re going to have to convince producers that this is something they should participate in,” Hillman remarks. “I expect after watching the media frenzy over the farm in Washington that some will be reluctant, and you can’t blame them.

            “We don’t know yet at this point how much TAHC will be involved with that process. We are in discussions with USDA,” he continues. “It’s going to depend on a number of factors — how are we going to do it, where are we going to do it, how many people will be involved, and how much money is it going to cost?

            “If we can get the resources, both fiscal and human, to do that, we think it’s a role we ought to be playing. We’re between legislative sessions, so we’re not blessed with excess dollars, and to add a big burden to our workforce would require some dollars.”

            In addition to the other changes, another key announcement made by Veneman on December 30 was the immediate implementation of a verifiable system of national animal identification. The development of such a system has been underway for more than a year and a half.

The primary objective of the proposed U.S. Animal Identification Plan is to enhance existing animal disease surveillance and monitoring systems, and to facilitate tracking animals in the event of a reportable animal health incident.

            TSCRA and many other industry organizations also have questions with regard to the animal identification program.

            “What does expedited implementation really mean?” TSCRA’s Matt Brockman asks. “Many of us who have been involved in the USAIP process acknowledge that from a national perspective, the timelines established were too aggressive, but the consensus was that we needed something on paper that would allow some states to move forward at least on premise ID.     

            “At our last meeting in Denver with the cattle species groups, there were several unanswered questions relative to the implementation of the plan,” he continues. “Those questions are still out there but there is a heightened sense of urgency now to get them answered and move forward.

            “There are some things that change because of what’s happened, but the unanswered questions haven’t changed and the issue of cost hasn’t changed either,” Brockman insists. “Our state animal health commission does not have the funds to put into place a premise ID system. Our association and other associations are going to have to be very assertive in going to USDA to get funding, not only for a premise system but for the other components of that system as well.

“That’s not to say that producers may not have to bear some costs, but it doesn’t change the fact that the government has got to step up to the plate. To date they haven’t made that commitment.”

            NCBA CEO Terry Stokes agrees that the cost for such a system needs to be equally shared by producers and state and federal governments.

            “NCBA has been an active participant in the Department's task force on animal ID, and we welcome the accelerated timeframe, but funding needs to be in place for this to happen,” Stokes says.

            Participants agree that for such a plan to work effectively, it must be carried out as a government/industry partnership. It hasn’t been clearly defined whether the program will be mandatory or voluntary.

            The original timeline called for the plan to be phased in over the next three years. There is some concern that stepping up the implementation process might lead to an ineffective system.

            “We have a plan that’s been long in development,” Hillman points out. “It’s a good plan. We need to implement that plan. If we can step up the implementation of that plan, then fine, but let’s don’t shortcut it and make rash decisions relative to ID outside the parameters of the plan that we’ve worked so hard to develop over the last several years.”

     


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