R-CALF USA today, along with 75 other organizations that represent tens of millions of Americans, sent formal correspondence to the U.S. Department of Agriculture (USDA) to request that the agency immediately strengthen protections against Canada's ongoing problems with bovine spongiform encephalopathy (BSE), also known as mad cow disease.

The groups' letter is in response to the disclosure this month of Canada's 18th case of BSE in a Canadian-born animal, which also is the 11th case of BSE in a Canadian cow that met USDA's age requirements to enter the United States. USDA's relaxed import standards are putting not only U.S. beef consumers at risk, but also the U.S. cattle herd and the livelihoods of independent U.S. cattle producers.
 
"Mr. Secretary, above all other considerations, the health and safety of the people of the United States and United States' livestock must come first - first before trade and first before international relations," the letter states. "Your agency's current BSE policies and regulations compromise directly this health and safety priority and we, the undersigned, urge you to take immediate action to, at the very least, restore for the United States the protections against the introduction and spread of BSE that were in place before USDA began to systematically dismantle its BSE-related border restrictions. We respectfully implore you to, as a first step, immediately overturn the OTM Rule."
 
USDA first relaxed U.S. safeguards against BSE in 2005, and then further relaxed those safeguards in 2007 with its OTM (over-30-month) Rule, which facilitates the importation of Canadian cattle born after March, 1, 1999, and beef from Canadian cattle of any age. At that time, Canada had detected only three BSE-positive animals born after March 1, 1999, but as of March 10, 2010, Canada has detected 11 BSE-positive animals born after that date - all of which met USDA's age requirement for export to the United States.
 
"We are asking the Administration to immediately reverse this reckless and unscientific approach to the dangers of BSE by withdrawing the OTM Rule that basically eliminated the United States' only defense against the introduction of BSE into the United States - its import restrictions that prohibited the importation of cattle old enough to have been exposed to the disease," said R-CALF USA CEO Bill Bullard.
 
While USDA allows the importation of cattle old enough to be exposed to BSE in Canada, the letter explains USDA also allows Canadian cattle to be subject to far less stringent risk mitigation measures than what is required in the European Union and Japan, "thus assuring that U.S. consumer are less protected against the introduction of BSE into their food supply than are consumers in those countries."
 
"USDA's dismissal of the epidemiological significance of Canada's high rate of BSE detection is simply inexplicable," Bullard said. "USDA can no longer ignore the empirical facts that show Canada's ongoing BSE problem is far more serious than the agency predicted."
 
Also in the letter, the groups indicate they wholeheartedly disagree with USDA's chief assumption that slaughter controls alone prevent the recycling of BSE infectivity into human food and cattle feed, including the prohibition against the use of tissues from downer cattle in the human food supply and the removal of specified risk materials (SRMs) from human food and animal feed, as well as feed manufacturing controls to prevent the recycling of BSE into cattle feed.
 
"Unfortunately, USDA, it seems, has decided that measures other than border restrictions are adequate to protect against this always fatal disease, yet we cite page after page after page of various violations over the past several years - in both U.S. slaughter facilities and U.S. feed production facilities - that continue to put the general public at risk and our U.S. cattle herd at risk," Bullard pointed out.
 
The following evidence is what has occurred in only the past few years and involves more than 144.5 million pounds of beef. This evidence further undercuts USDA's assumption that BSE risk pathways to humans have been effectively alleviated:
 
·Jan. 15, 2010: New York recall of a beef carcass that may not have had the spinal column removed.
 
·Oct. 17, 2009: Wisconsin recall of about 5,522 pounds of beef tongues that may not have had the tonsils completely removed.
 
·Oct. 16, 2009: California recall of approximately 11,500 pounds of assorted meat and poultry products (including beef) that were produced without the benefit of federal inspection.
 
·Oct. 15, 2009: Nebraska recall of approximately 33,000 pounds of beef tongues that may not have had the tonsils completely removed. 
 
·May 29, 2009: Idaho recall of approximately 14,560 pounds of beef primal and subprimal products that were imported from Canada and not presented for re-inspection upon entry into the United States.
 
·Apr. 29, 2009: New York recall of approximately 16,213 pounds of seasoning products, which contained cattle by-products that were ineligible for import into the United States.
·                     Apr. 26, 2009: Michigan recall of an undetermined amount (estimated at 30,973 pounds) of frozen meat and poultry pasta products (including beef) that were prepared without the benefit of federal inspection.
 
·Mar. 28, 2009: South Carolina recall of approximately 2,925 pounds of beef and other meat products that were mislabeled and possibly produced without the benefit of federal inspection.
 
·Aug. 7, 2008: Texas recall of approximately 941,271 pounds of cattle heads with tonsils not completely removed.
 
·Jun. 26, 2008: Missouri-based recall of approximately 120 pounds of fresh cattle heads with tonsils not completely removed.
 
·Jun. 26, 2008: Texas recall of approximately 2,850 pounds of fresh cattle heads which may have contained SRMs.
 
·April 4, 2008: Kansas recall of approximately 406,000 pounds of frozen cattle heads with tonsils not completely removed.
 
·Feb. 17, 2008: California recall of 143,383,823 pounds of raw and frozen beef products, which were produced without the cattle receiving complete and proper inspection, including requisite inspections of non-ambulatory cattle that were supposed to be removed from the food supply.
 
·A feed manufacturing firm was cited this year by the FDA for manufacturing and distributing adulterated animal feed to nine states: Idaho, Nevada, Utah, Wyoming, Colorado, Montana, Washington, California, and Oregon; yet nowhere was specified exactly how long this manufacturer had been distributing the adulterated feed.
 
·In October 2006, the FDA issued a warning letter to an animal feed protein supplement manufacturing facility in Alabama for producing adulterated feed by failing to implement measures to prevent commingling or cross-contamination of prohibited proteins, as well as for subsequently misbranding animal feeds for more than 15-months.
 
·In 2006, the FDA issued a Louisiana rendering plant a warning letter for violating U.S. BSE-related feed manufacturing controls, again by failing to prevent commingling or cross-contamination with prohibited protein and for misbranding feed.
 
·In 2005, FDA inspectors found that a Minnesota rendering plant was in violation of requirements to prohibit certain proteins in ruminant feed and revealed the rendering plant failed to use proper clean-out procedures to prevent cross-contamination and failed to properly label feed to prevent its consumption by ruminant animals.
 
"These were just the incidents that were caught and likely represent only a fraction of the cattle that were processed without complying fully with required BSE mitigation measures. Thus, there likely are hundreds of thousands of U.S. consumers who have purchased beef that likely was not subject to U.S. mitigation measures," the letter states.
 
"This ongoing, potential human exposure to BSE is unnecessary and can and should immediately be avoided by prohibiting the introduction of cattle and beef from Canada where the BSE agent is known to have recycled in that country's feed system through at least all or part of 2004, and where it likely continued to recycle at least until Canada implemented its upgraded feed ban in mid-2007," the group wrote.
 
"We are hopeful that Secretary Vilsack will respond favorably to the tens of millions of Americans represented by the groups joined in the letter by immediately restoring our border restrictions to prevent the introduction of BSE from Canada," Bullard concluded.