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June 05, 2007

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Hilzoy, it is posts like this that make you my favorite left-of-center blogger.

Thanks for clarifying, hilzoy.

So would the government be in favor of requiring testing on all cattle more than, say, four years old that are entering the food chain?

I am confused. If the test would deliver *too many false negatives,* does that mean that (contrary to all reports, I mean, protests) there IS mad cow disease in US cattle stocks?

And I still don't understand why, if a small company wanted to participate in a "marketing gimmick," it shouldn't be allowed to.

And if, as the USDA ruling says, there is no live-animal test for the disease, that means okay, no testing for young animals prior to slaughter? How about, that means it's time to do more research?

That might be the Ag Department's argument, but the argument doesn't make sense. If a producer wants to go to the expense of running the test, why should he or she not be permitted to, regardless of whether or not the test is worthwhile? If the gov't wants to argue that the advertising the fact that the test does not show what it purports to show--that is, that the animals are free of BSE--and hence would be false advertising, that's one thing. But the gov't doesn't seem to have done that.

"If the test would deliver *too many false negatives,* does that mean that (contrary to all reports, I mean, protests) there IS mad cow disease in US cattle stocks?"

If there is BSE, this test won't tell you.

Let them run the lab procedure if you like - but they shouldn't be allowed to falsely advertise that they've tested the meat. "Test" suggests to the consumer doing something useful.

Ah. I didn't get into that part. The Virus-Serum-Toxin Act says this:

"It shall be unlawful for any person, firm, or corporation to prepare, sell, barter, or exchange in the District of Columbia, or in the Territories, or in any place under the jurisdiction of the United States, or to ship or deliver for shipment in or from the United States, the District of Columbia, any territory of the United States, or any place under the jurisdiction of the United States, any worthless, contaminated, dangerous, or harmful virus, serum, toxin, or analogous product intended for use in the treatment of domestic animals, and no person, firm, or corporation shall prepare, sell, barter, exchange, or ship as aforesaid any virus, serum, toxin, or analogous product manufactured within the United States and intended for use in the treatment of domestic animals, unless and until the said virus, serum, toxin, or analogous product shall have been prepared, under and in compliance with regulations prescribed by the Secretary of Agriculture, at an establishment holding an unsuspended and unrevoked license issued by the Secretary of Agriculture as hereinafter authorized."

That basically (so the argument goes) gives the USDA authority to regulate, among other things, the BSE test. (Lots of arguments about whether the test is indeed an "analogous product", and whether a diagnostic test is used in "treatment"; they turn on features of the history of agricultural regulations which I cannot begin to assess. As I understand it, the USDA's position is: this act gives them the power to regulate biologics used on animals.)

The USDA's argument is that the use of the BSE test "in a non-targeted manner on slaughter-aged cattle" is "worthless", because virtually all BSE is not detectable at that age.

"'Test' suggests to the consumer doing something useful."

So you're saying that if I stick a cow really hard with my finger, and then look at my finger, and announce that I've found no BSE -- a true statement -- that you'd interfere with my freedom of speech to proclaim my truth?!?!

What kinda linguistic fascist prescriptivist are you?

Come see the repression inherent in the system!

"What kinda linguistic fascist prescriptivist are you?"

Poetic license available for inspection on request.


I do wonder how this is consistent with advertising for (untested) herbal remedies, but whatever.

"I do wonder how this is consistent with advertising for (untested) herbal remedies, but whatever."

Congress specifically passed a law giving relative carte blanche on claims about herbs a few years ago; I thought it was scandalous, myself, but the vast herbal-medicine-buying population sure didn't.

But, then, my own fascist impulses run towards wishing there were a law making it illegal to take or earn money, or benefit in any way, from claiming you can communicate with the dead. I'd like to see practitioners convicted of fraud, with 5-10 years served for each guilty count.

That doesn't mean I'd actually advocate this as serious policy. But I'd like to.

Obviously the solution for the company in question is to feed their cattle herbs that supposedly protect them from BSE and advertise that fact.

rilkefan: then those herbal supplements would fall under the VSTA, and would be regulated. It's only when they're for use by mere humans, as opposed to domestic animals, that all is permitted.

"Obviously the solution for the company in question is to feed their cattle herbs that supposedly protect them from BSE and advertise that fact."

It might work.

Alternatively, if the advertising quoted someone who simply said that this was what their spirit guide told them from the Other World, that wouldn't be a violation, would it?

"It's only when they're for use by mere humans, as opposed to domestic animals, that all is permitted."

Because that makes ever so much sense.

"then those herbal supplements would fall under the VSTA, and would be regulated. It's only when they're for use by mere humans, as opposed to domestic animals, that all is permitted."

Infuriating. Where do I sign up to become a libertarian?

Herbal medicine companies are just lucky that humans rarely enter the food chain...

I think something is being overlooked here.

Creekstone wanted to do the testing because Japan made it a requirement for exporting beef there. Now, it may be that the test is not useful for diagnosing BSE, but the USDA says, more fully (from the link):

However, no live animal tests exist for BSE and the currently available postmortem tests, although useful for disease surveillance (i.e., in determining the rate of disease in the cattle population), are not appropriate as food safety indicators.

Maybe the Japanese think 1% testing for surveillance is inadequate. Maybe they are just responding to public pressure in Japan. But even if the proposed test has value only for marketing purposes, that does not mean that the meat will be falsely advertised in the US as "BSE tested" or the like. It just means Creekstone will be allowed to sell beef in Japan.


"Infuriating. Where do I sign up to become a libertarian?"

I don't think you'll find libertarians unanimously voting to authorize the FDA to ban advertising claims.

What you want is the Animal Libertarian Front. The group whose purpose is to gain libertarian rights, including the right to use or not use whatever dietary supplements they like, for animals.

"I don't think you'll find libertarians unanimously voting to authorize the FDA to ban advertising claims."

I.e., I was making a joke about consistency.

Maybe the USDA (or an enterprising bio-sciences company, like the one that makes the current test) should start developing a test that might spot BSE in young-enough-to-eat cattle.

Or if the USDA did not ban the testing - the company manufacturing these tests would have the profit margins to invest R&D to improve their test for younger animals and be certain there was a market for the test. As it stands, rational minds have been chased away from the field by statist controls.

Jon -- the USDA doesn't ban the testing; it just regulates it pretty heavily. I don't know of any reason why they wouldn't allow more extensive testing given a test that would actually accomplish something when used on younger animals.

The inability of the current test to spot BSE in cattle at the normal age at which they are slaughtered doesn't mean that BSE is not prsent or that it can't be transmitted up the food chain.

It means the current commercially available test is incapable of evaluating the spread of BSE across the population of beef animals that form part of the human food chain - including those animals used as food by intermediate animals in the chain. (What about other animals known to be prone to prion "infection", like sheep and chickens?)

It suggests that govt claims of "no" BSE are unsubstantiated and given false support by a test that doesn't seem capable of evaluating what it purports to evaluate.

That's Bad News. Is the govt satisfied by a test with this limited utility? If so, why? Obviously, we need tests that can detect the presence of BSE earlier. What's being done to develop them?

Damn. And this had been such a fine, fine example of regulatory capture. One for the textbooks.

It sounds to me like the obvious solution is to test all the animals that are old enough that the test might work. (Recent infections in older animals wouldn't be caught any more than recent infections in young animals.)

And label all the young beef as untested.

I think from that point the political process would tend toward getting the right results, apart from retribution against the people who did this.

It sounds to me like the obvious solution is to test all the animals that are old enough that the test might work. (Recent infections in older animals wouldn't be caught any more than recent infections in young animals.)

IANAF, but I'm pretty sure they don't slaughter older animals for human consumption. They use the females for milk production, but AFAIK, you can't catch 'mad cow' from dairy products. It probably would be a good idea to test the older animals before putting them into the animal food chain, tho, if we insist on being stupid enough to add animal protein to herbivore food. Better yet, just stop doing that.

And label all the young beef as untested.

This suggestion seems to carry the concept of warning labels a bit far, as we have no idea what the risk level is. Not issuing reckless propaganda that U.S. herds are free of mad cow disease would accomplish the same basic result cheaper & stress me out less when I'm shopping.

Is the govt satisfied by a test with this limited utility? If so, why? Obviously, we need tests that can detect the presence of BSE earlier.

Despite all the hoopla, my guess is that the government doesn't much care about mad cow because very few people have ever died from it and if it ever becomes a significant problem, we can slaughter all our cows and start over, as with hoof-and-mouth disease culling. This seems shortsighted to me, but even I wouldn't call this issue a huge priority, compared to, say, global warming, bee die-off, bird flu, West Nile, etc. I'm sure somebody in private industry must be trying to develop a better test, tho, because there's obviously a market for it.

BTW, I read a book a year or two ago that speculated that many cases diagnosed as Alzheimers are actually a form of mad cow, but the science and the reasoning looked awfully sloppy, so I didn't take it seriously. Anybody know any more about it?

I read with the interest that the Bush administration it will fight to keep meatpackers from testing all their animals for mad cow disease.... I think, the actions of the USDA administration are correct and save- compared with the Europe- "squandermania"... See my opinion in Iowa Farmer Today (October 5, 2006) http://iowafarmertoday.com/articles/2006/10/09/livestock/47bse_ap.txt . Also, recent experiments on mice indicated that mad cow disease in cattle was not contagious (May, 2007). The research group, headed by Tetsutaro Sata, chief of the Department of Pathology at the National Institute of Infectious Diseases (Japan), is now compiling a detailed academic paper based on the findings. So, if the infection cannot be confirmed through the experiments between mice, then it would be difficult to verify the infectiousness (of BSE) http://www.asahi.com/english/Herald-asahi/TKY200705100081.html).
So, where is a central role of infectious proteins (from meat and bone meal- „MBM“) in BSE? For example; why we found BSE positive animals – three or more years after a ban on using MBM in dairy rations? (see examples from Europe, Canada, Japan)? So, there is the evidence that MBM is not „an origin about the BSE“, beef is safe in the all world…
I described an alternative “BSE ammonia-magnesium” theory (http://www.agriworld.nl/feedmix/headlines.asp?issue=3). This theory is based on the chronic Mg-deficiency- potentiated by hyperammonemia (high protein intake…). These mechanisms have a strong influence on CNS, especially in ruminants and carnivora animals ( www.bse-expert.cz). Also according to the recent research; BSE can be “not infectious disease”. Why? At first, authors in „Journal of Pathology“ (March, 2006) found that prion proteins implicated in the development of transmissible spongiform encephalopathies, such as vCJD, may be markers for disease rather than the infectious agents. So, under laboratory circumstances prion-protein can be absorbed across the gut, it also shows that this is unlikely to occur in real life (http://www3.interscience.wiley.com/cgi-bin/abstract/112568745/ABSTRACT).
And what is about the possibility of sporadic mutations- transmission of the disease gene? There is the explanation from Dr.Murphy (President of the International Committee on the Taxonomy of Viruses), he says;
„Recent research has shown that the scrapie PrP protein differs from the BSE PrP protein at only seven amino acid loci, whereas the BSE PrP protein differs from the human CJD PrP at more than 30 loci. These differences explain the concept of strains and help explain why prions from one species might jump more easily into another species than another. It is difficult to find the terms to discuss prions — for example, can we talk about mutants when there is no DNA? What would Watson and Crick think of all this? There is a familial form of CJD, accounting for about 10% of cases. In the familial disease there is are mutations in the gene encoding the normal protein such that the protein tends to fold in the abnormal way and tends to pile up into aggregates in brain cells with lethal consequences….. The prion protein in familial cases is the same in each family member that has it, and different in all other families. Sometimes the difference is as small as one amino acid, but these differences can be used to determine the pedigree of the prion. I’m sure such analyses are being applied to the 10 cases just reported in the UK“ (http://www.accessexcellence.org/WN/NM/madcow96.html).
Other authors in „Journal Biol. Chem.“ (November, 2006) found that small amounts of detergent-insoluble PrP aggregates are present in uninfected human brains, so insoluble aggregates and protease-resistant conformers of prion protein in uninfected human brains (http://www.jbc.org/cgi/content/abstract/281/46/34848). More recently (February, 2007); Authors in “Neuron” wrote; “Early functional impairments precede neuronal loss in prion disease…they occur before extensive PrPSc deposits accumulate…supporting the concept that they are caused by a transient neurotoxic species, distinct from aggregated PrPSc“ . (http://www.neuron.org/content/article/abstract?uid=PIIS0896627307000086).
The prion protein infection from transmissible BSE is then thought to travel to the brain via peripheral nerves, perhaps with assistance from the lymphoreticular system. In 2004, a study of 13,000 appendix and tonsil samples revealed that thousands of people may be unknowingly harbouring vCJD (http://news.bbc.co.uk/2/hi/health/6334215.stm). However, recently scientists find connection between nerve cells and immune system. They have made visible an astounding number of contacts between immune and nerve cells. These include some of the most important immune cell types, such as B-lymphocytes, T-lymphocytes and dendric cells - all of which form connections to the nerves (http://www.news-medical.net/?id=21792).
The new findings, offer significant insights into normal folding mechanisms as well as those that lead to abnormal amyloid fibril conversion (http://www.sciencedaily.com/releases/2007/02/070212182836.htm). Until about five or six years ago, everyone assumed that the large amyloid plaques, or neurofibrillary tangles, that were found in the brains of Alzheimer’s victims were the cause of the disease. However, recent scientific discoveries indicate that these large, insoluble aggregates might merely be markers of the disease—they do not cause the disease (http://www.sciencedaily.com/releases/2007/02/070215110558.htm).
According to the article „Should we still be worried?“ (January 10, 2007) (http://www.guardian.co.uk/g2/story/0,,1986657,00.html), there is an agreement about the „BSE no infectiosity“ – see following text from this article; „ But despite billions spent on efforts to save Britain’s beef industry and protect its citizens, all the major questions remain unanswered. The origin of the disease? A mystery. The number of people infected with vCJD? A mystery. The risk that those harbouring the disease will infect others? Again, a mystery…. The politicians didn’t know what to do and the scientists didn’t know what to do. We didn’t know where it came from, what caused it, how bad it might be. We didn’t know anything…. „The danger now is not from cattle, it’s from other human beings,” says another expert in vCJD …“.
This can be in connection that the story of BSE in Britain is a consequence of „intensive farming“ (metabolic disease disease and „neurotoxicity“) and belongs in the „Organic Research“ (http://organicresearcher.wordpress.com/2007/01/06/bse-an-alternative-theory/). My alternative “BSE ecological view” can be well documented concerning the example “Chronic Wasting Disease” (CWD) http://organicresearcher.wordpress.com/bse-the-work-of-josef-hlasny/. See also one Chapter in my website ( www.bse-expert.cz).
More recently (April 2007) was found that; Alzheimer's disease, Parkinson's disease, type II diabetes, the human version of mad cow disease and other degenerative diseases are more closely related at the molecular level. An international team of chemists and molecular biologists reported; „A mystery on which the new Nature paper sheds light is what causes different strains of prions (infectious proteins) in which the protein sequence is identical. Our research gives a strong hypothesis that the origin of prion strains is encoded in the packing of the molecules in the fibrils which we are seeing in the crystals…“ (http://www.sciencedaily.com/releases/2007/04/070430102021.htm). See also my “opinion- article”(September 2006); about the link between BSE and Alzheimer´s disease (http://www.medicalnewstoday.com/youropinions.php?opinionid=11677). In addition, in neurodegenerative diseases (Alzheimer´s disease…) the hyperfunction was found and in schizophrenia – the hypofunction of glutamatergic (NMDA receptor) neurons was found (http://www.medicalnewstoday.com/youropinions.php?opinionid=17968).

"BTW, I read a book a year or two ago that speculated that many cases diagnosed as Alzheimers are actually a form of mad cow, but the science and the reasoning looked awfully sloppy, so I didn't take it seriously. Anybody know any more about it?"

It's what Denny Crane has.

It seems to be time for the weekly reminder in how to link to URLs: Here is a handy guide to HTML tags.

You can use "find" to go to "link something."

Here's how you link (you can copy this and paste it as necessary, if you can't remember): <A HREF="URL"> </A>

Put words as necessary between > <

Put the actual URL to link to where it says "URL."

You're done.

"And label all the young beef as untested."

This suggestion seems to carry the concept of warning labels a bit far, as we have no idea what the risk level is. Not issuing reckless propaganda that U.S. herds are free of mad cow disease would accomplish the same basic result cheaper & stress me out less when I'm shopping.

If the federal government were to follow my proposal there would be a strong incentive to come up with a workable solution.

As it is, there's a strong incentive to fake a solution and persuade the public to ignore it.

So, if the infection cannot be confirmed through the experiments between mice, then it would be difficult to verify the infectiousness (of BSE)

It's encouraging to see one published result that did not detect BSE in mice. But it would be extremely reckless to depend too much on this study given the stakes. Still, it's good that these mice didn't develop symptoms in 500+ days after one exposure to a small dose, when they develop symptoms in 200+ days after one exposure to a large dose.

For example; why we found BSE positive animals – three or more years after a ban on using MBM in dairy rations? (see examples from Europe, Canada, Japan)? So, there is the evidence that MBM is not „an origin about the BSE“, beef is safe in the all world…

There are other origins, but MBM can amplify the results. It's like, individual people start chain letters, but the post office lets chain letters spread fast.

Your observation that BSE shows up occasionally for other reasons argues the opposite of your conclusion -- it does not at all imply that beef is "safe" anywhere. But we can do things to lower the risk of eating beef.

Other authors in „Journal Biol. Chem.“ (November, 2006) found that small amounts of detergent-insoluble PrP aggregates are present in uninfected human brains, so insoluble aggregates and protease-resistant conformers of prion protein in uninfected human brains

That was a scary article. They did nothing to show that the brains were uninfected. Just, they didn't yet have symptoms and tested negative on all the tests -- none of which would detect infection at that level.

According to the article „Should we still be worried?“ (January 10, 2007) (http://www.guardian.co.uk/g2/story/0,,1986657,00.html), there is an agreement about the „BSE no infectiosity“ –

I strongly encourage everybody to read this article. It's clearly written without excessive technical language. And "I do not think this means what you think it means.". They think there are tens of thousands of human cases in britain that have not yet shown symptoms, and these can infect others through blood transfusions etc. Since britain has officially broken the re-infection cycle of cattle (but may not have broken the human-to-human infection cycle) the big threat there is now human-to-human. There is nothing in the article to imply that BSE is not infectious. Less than half a gram of brain tissue infected scrapie-resistant sheep. Less than a gram infected cattle. Nobody knows how much it takes to infect people, or to what extent the doses are cumulative.

If a small dose will infect you but you won't develop symptoms until you're 120 years old, how many small doses does it take to bring the onset down to 60 years? or 40? This is all unknown at this point, and it would be hard to find out without careful epidemiological studies or (more effectively) with longterm human testing.

The AP article accurately reflects the USDA's fear, despite what they say. They are not fearful of false negative results on cattle that would never be tested in the first place under existing regulations, why would they?.

Their concern is that testing every cattle brings with it the risk of a false positive. Japan tests every cattle and their data suggest a false positive occurs in 1 out of every 30,000 tests. The test most frequently used is a screening test called the Bio-Rad TeSeE ELISA test.

When a false positive test result occurs, it will require further testing to truly identify whether the sample is positive or negative, and a positive result from the screening test is inconclusive.

The US has now gone back to testing only 40,000 cattle that go to market per year, from the 35 million that are slaughtered.

When a positive test result comes out, it is then tested using the immunohistochemistry staining (the international “gold standard” test for detecting prions) and a western blot technique.

Until the result comes out, the market gets nervous if news of the positive result gets out.

This is clearly the only reason for the USDA's concern about more testing by a private farm who simply wants to increase his market share in Japan.

The US consumer has bought into the myth that BSE is not a problem in the US, and anything that could suggest otherwise is a threat. More testing being done will mean more false positives, and most likely, as in the case of every country who has expanded testing to a significant degree, more confirmed cases, and poof goes the myth that we do not have BSE in our beef. If you don't test for it, you don't have it, wink, wink.

"Here's how you link (you can copy this and paste it as necessary, if you can't remember)"

By using a Terminator?

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