released Monday by the Government Accountability Office (GAO) criticizes the Food and Drug Administration (FDA) for it's monitoring of the feed ban - implemented in 1997 - and other safety measures.
The report, requested by Senators Tom Harkin, D-Iowa, and Richard Durbin, D-Ill., comes on the heels of increased attention on the effectiveness of such feed bans, both in Canada and the United States. Shortly after Canada's discovery of two BSE cases in January, questions arose about findings of animal proteins in ruminant feed supplies. USDA later determined Canada's feed ban was sufficient, but it tainted the U.S. view of Canada's firewalls.
Report doesn't address risk assessment
The GAO report released Monday found FDAâ€™s claim of 99% compliance misleading because it is based on inspecting only a fraction of feed plants and does not count actual violations of the feed rules if the plants involved are later found in compliance. The GAO also noted that because feed plants are not required to register with FDA, not all plants that make animal feed and are subject to FDA inspection have even been identified, or inspected.
The release comes at a time when tensions are mounting in the cattle industry as a trade resumption timeline with Japan remains unknown. Gary Weber, National Cattlemen's Beef Association executive director of regulatory affairs, says the report should not have an impact on ongoing negotiations with Asian markets.
The GAO report states that the 99% compliance level isn't accurate, that the FDA didn't test enough feed samples and more tests weren't done at sites that switched from low to high-risk facilities. "None of that really matters in a risk assessment," Weber says. And the discussions with Japan are based solely on a risk assessment.
Weber says one cannot look just at compliance and judge whether we're doing a good job of eradicating the disease from compliance figures alone. He explains that the GAO report isn't saying what level of compliance is sufficient to prevent the disease from spreading and eradicating it if it's present. "Harvard says it doesn't have to be 99%, especially when all the evidence points to the fact that the BSE risk in North America is very low," he says.
"One has to look at the whole package which includes all of our surveillance data," he says. "That's the most powerful argument we have that the risk of BSE is very low." In less than a year the United States has conducted nearly 270,000 BSE tests, with no additional cases found. Because the feed ban has been in place for nearly eight year, and so many high risk animals have tested negative for the disease, it can be assumed that the risk in the United States is even lower than extremely low, he adds.
Senators call for FDA to use new technology
In addition to raising questions about the validity of FDAâ€™s compliance reports, the GAO cited a number of other shortcomings in FDAâ€™s enforcement of the ruminant-to-ruminant feed ban. Specifically, the report noted that FDA fails to set consistent standards for cleaning machinery and transport vehicles that handle both prohibited and allowed feed materials and fails to conduct timely inspections in all known plants.
Harkin says that, "Common sense tells us the best way to measure compliance is to sample feed to make sure it does not contain ruminant byproducts. Despite what FDA asserts, technology is available for testing feed to detect ruminant byproducts. FDA should use this technology."
Associate Dean and Director of University of California-Davis' Veterinarian Medicine, Teaching and Research Center Jim Cullor's research lab developed a quick test that uses DNA forensic techniques to detect the presence in livestock feed of prohibited materials from cows, sheep, goats and deer.
Cullor says that the test, which takes between one to five hours, can detect 0.05% of contamination. This is equivalent to about one pound per ton of feed. And with further research Cullor says in the near future the test should be able to essentially pick up what level of contaminated feed it would take in a single dairy cow feed serving to spread the harmful BSE prions, or 0.01%. With the quick test, inspectors collect feed samples, send them into a state lab, tests are run and either state or national officials would report back to the site within 24-48 hours.
Cullor says FDA is faced with a daunting task of examining every livestock meal given each day. But that's what the FDA is forced to do, with few resources and long tests. "This test takes a couple of steps in the right direction of being able to accomplish that task," he says.