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Guest Blog: The FDA on BSE

Hi again, everyone,

So, by virtue of my university affiliation, was able to attend a seminar last week given by none other than Lester Crawford (DVM, PhD), the acting commissioner of the FDA. The title of the seminar was “BSE AND BEYOND -- HOW THE U.S. GOVERNMENT IS TACKLING SOME OF TODAY'S BIGGEST HEALTH THREATS.”

I should state that though he had intended to talk about bioterrorism as well, due to copious pointed questions during his BSE (bovine spongeiform encephalopathy) section, he ran out of time… actually, ran over by about 15 minutes. This, should tell you, before I even get started, that he wasn’t very good at adequately answering questions. If you don’t want to read any farther in this post, the take-home message is that I am in no way reassured about the state of beef in this country after this seminar, and am possibly even more worried by Dr. Crawford’s apparent inability to give straight answers to a group of 40 or so scientists.

For those reading who don’t know, I gave up eating beef shortly after the first American mad cow was identified back in December 2003. What follows is the story of the seminar.

I was excited. I had just found out that there would be a seminar on BSE, and I could find out what the government was really doing about it, straight from the horse's mouth, as opposed to weirdly filtered through the news. Possibly, even, have some of my fears allayed and actually go back to a steak house eventually. Mmm... steak. I even made myself a list of "tough questions" to ask in case it was a mostly friendly audience and I was the only person who was really demanding information.

Thinking that this was a pretty hot topic, and knowing that the advertisement for the talk went out to the whole medical center community, and knowing that it was at very reasonable 10AM, I thought I'd better get there early. I guess it was a little disappointing that the 200-person hall was less than a quarter full by the time Dr. Crawford started.

Lester Crawford is an amiable southerner who decided to forgo using slides because of a slide snafu during his talk at the National Medical Association the previous day. A talented storyteller, he started his talk with some feel-good facts about the FDA, and some information about what the organization does. The FDA and the USDA are jointly responsible for regulating the response to BSE. (No, not the CDC. Mind you, this isn't actually considered a human disease yet, which is preposterous, but I digress.)

Crawford took his audience back through the beginnings of BSE. From the first case, discovered in England in the mid-1980's, to the 1988 meeting between the Brits and American scientists. At this meeting, the U.K. told the U.S. that this disease a) was transmitted via cattle proteins (nice euphemism) in cattle feed, b) it could only be diagnosed by histopathology of the brain and c) it was "very likely" transmissible to humans. Armed with this information, we did... well, not a lot to protect our own herd. Grinding up cows and feeding them to other cows had become standard practice both in the U.K. and here. Banning this practice was proposed in 1988... but was not enacted. We also decided to evaluate animals showing signs of neurological disease, under the faulty assumption that this was reasonable, or helpful in detecting BSE cows. I guess we started testing our animals too. At a rate of 12,000 per year. 15 million cows are slaughtered every year (admitted Crawford, in response to a much later question). So that's a 0.08% testing rate. (It's my understanding, also, that our testing has always preferentially tested 'downer cattle,' too sick or hurt to walk into slaughterhouses. Crawford freely offered that this is not the way to hunt BSE. All you find when you look at downers is broken legs, and other physical lesions and illnesses.)

The first Canadian-born BSE case is discovered in Canada in 1993. We did not ban cattle imports from Canada. Japan cuts off US beef imports, though later after some "agreements" starts importing from us again. Canada blames feed obtained from the US. (When I asked later, Crawford contended that we had banned cattle protein in cattle feed at this point, so their claims were ludicrous... however, he told a different story first -- see next paragraph.)

In 1996, 10 years after the first cow diagnosis, the U.K. diagnosed its first human case, (the human version is variant Creutszfeld-Jacob Disease, or vCJD) we finally enacted the regulation about feeding cows to other cows at home. (Mind you, cows can still be fed to chickens, sheep, and pigs, and these animals can be fed back to cows.)

In 2003, the "cow that stole Christmas" as they called her at the FDA became the first cow in the U.S. positively identified as having BSE. (Incidentally, she was not a downer.) Deciding the cow was Canadian, we enforced a ban on Canadian cows. We also banned downers from entering the food supply. Yep, we were eating 'em before. Banning cow protein in any animal feed is suggested, but not enacted.

Okay, now here's where the story gets good. Apparently, the U.S. commissioned some international committee, after we found that cow with BSE, to examine our situation and practices, and make recommendations. Dr. Crawford was, well, derisive, to put it mildly, of the international committee's conclusions and recommendations. He went on at length about how wrong they were and unreasonable and completely off-base. Then, finally, when he brought it up again, someone in the audience asked him "What, exactly, did the international committee recommend? Because you keep saying how unreasonable they were but you haven't told us why."

Apparently, the international committee believed that the U.S. has potentially hundreds of thousands of BSE cases (says Crawford, 'they didn't cite any evidence or references,' and I am skeptical that the number is that high, but still). Among their major recommendations: 1.) we ban the practice of feeding any livestock animals to other livestock, and 2.) we need to worry about animals as young as 12 months of age (no cases have been found yet in animals younger than 30 months).

Our response to the committee's conclusions has been to, uh, test more, but not all of our cattle. There is a program to test 250,000 cattle over the next 18 months for BSE. Wow, you say, that's like 10 times as many as we were testing before! Yeah, now we're up to a whole 250,000/22,500,000 = 1% of our nation's slaughtered herd. Now factor in that this quarter of a million to be tested includes younger animals, downers (which are, let's review, not expected to be infected), and dairy cattle (which aren't even part of the 15 million/yr slaughtered).

In addition, Dr. Crawford was asked if the animals were to be chosen randomly or if they would be tested on a voluntary basis. He said that the question got into the "seamy underbelly" of the situation, then he hedged, then he said that yes, they'd be chosen randomly. Which I interpret to mean 'not really.'

Crawford claimed a 95% confidence that they'd find out if even 10 animals had BSE in all of the U.S. using this screen. But that's not the right statistic -- we're talking about 15 million animals/year here -- 95% is not all that confident.

As for the stricter ban on livestock feed, well, the jury's still out on that. Really. They're actually taking public comments about what to do, until August 13th. As for the testing of younger animals, I wouldn't hold my breath.

Someone actually did ask specifically about the Creekstone Farms incident, wherein a smallish, specialty farm wants to test all their beef so they can export to Japan (who tests all their beef and who banned U.S. imports in December), but the U.S. government won't let them. The questioner wasn't sure if it was the FDA or the USDA who made that call, but asked Crawford what possible justification there could be. Dr. Crawford laughed, and then said "That wasn't us --- we'd never do anything that stupid." He then proceeded to say that the USDA's reasoning went something like this: If this farm tests all their beef and doesn't find any BSE, then they'll say their beef is 100% safe, which they can't say because the tests have a false negative rate and it would be misleading.

Right. Unlike all other beef companies who say their beef is 100% safe without any testing at all. Nor is it unforeseeable just mandate certain kinds of labeling -- a common practice already in the food industry.

Crawford hemmed and hawed about this for a few minutes before mumbling something about "lowering consumer confidence,"' which I interpret to mean: "We're really worried about what lowered consumer confidence will do to the economy, Big Beef, and the status quo, so we've concocted this rather flimsy story about the BSE tests' false negative rate.

What would have been the best question for Crawford is "Are YOU still eating beef?"

Further fun facts to come out of the seminar: * Britain just confirmed their first case of vCJD that came from a blood transfusion, proving that the disease is transmissible to humans. (Previously, naysayers said it could have been genetic.) * China's ban of U.S. cosmetics reminds us that, oh yeah, cosmetics and lotions and stuff (dietary supplements) often contain cow ingredients * Until July 1st, 2004, idiots in the U.S. could actually buy English cow brains over the internet... to help with memory.



So, ewww.

But seriously, not that I want to eat beef that's been fed, well, beef. However, has there been any actual evidence that eating mad cow beef causes humans to contract the human form of mad cow disease? Maybe my info is out of date, but I didn't think so.

Joy suggests these links:

In short (from the first link, the Q&A):

Is there evidence directly linking this newly recognized variant of CJD to BSE exposure?

There is strong epidemiologic and laboratory evidence for a causal association between variant CJD and BSE. The absence of confirmed cases of variant CJD in other geographic areas free of BSE supports a causal association.

I stand corrected.

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