DeLauro Questions Testing That May Allow Injured Cattle Back into Food Supply
DeLauro Questions Testing That May Allow Injured Cattle Back into Food Supply
-- Calls for Agriculture Department to Institute National Animal Identification System --
WASHINGTON, D.C. - In a letter to Secretary Johanns today, Ranking Member of the Appropriations Agriculture Subcommittee Congresswoman Rosa L. DeLauro (Conn.-3) questioned the Agriculture Department testing that may allow injured cattle back into the food supply. Last week, Secretary Johanns said the department is considering lifting the ban on injured cattle, put in place 15 months ago after the first case of "mad cow" disease in the country. Johanns suggested it was now safe due to an agriculture study. Previous cases have shown that a cow's injury can be a sign of "mad cow."
"APHIS never tells the reader how it will overcome the major flaws identified by the IG such as the fact that its sampling program is voluntary, that it is not geographically viable, and that a significant number of cattle, such as downers that would be expected to be tested in a European study, are not being presented to be tested at all," DeLauro wrote in the letter. "In fact, the APHIS study certainly contrasts unfavorably with testing protocols in the United Kingdom where all cattle over thirty months of age, and all fallen or downer cattle are tested for BSE."
The full text of the letter follows.
April 22, 2005
The Honorable Mike Johanns
Secretary, U.S. Department of Agriculture
Jamie Whitten Building
1400 Jefferson Drive SW
Washington, DC 20250
Dear Secretary Johanns:
I am writing to express my concern about recent reports that you are considering allowing some injured cattle to enter the human food supply based on the "increased surveillance" program run by the Animal and Plant Health Inspection Service (APHIS). This action, in my opinion, is questionable based upon the August 2004 report of the Inspector General of USDA, as well as the contradictory follow up issued by APHIS itself the following month.
During your testimony before the Appropriations Subcommittee on Agriculture, you and I discussed meeting to discuss food safety, and the management of the Bovine Spongiform Encephalopathy (BSE) issue in particular. I hope we will have the opportunity to discuss these proposed changes soon.
In August of 2004, the Inspector General's Office of USDA found several troubling issues surrounding the expanded testing program that inhibit APHIS reaching its stated goal - to determine if " BSE is actually present in the population and if so, at what level." At that time the IG raised several important issues about the surveillance program and plan. They pointed out that:
· Sampling is not truly random because participation in the program is voluntary (the IG asserts that while APHIS has authority to collect samples it chose not to exercise this authority except in federally inspected slaughter facilities.)
· As the plan was then designed APHIS could not obtain a statistically appropriate geographical representation of the U.S. cattle population. This is true both because the program is voluntary and the universe of high risk cattle is difficult to identify, obtain and test.
· APHIS' plan assumes BSE is confined to high-risk cattle - something that has been refuted in other countries.
Following those and other findings, the IG asked APHIS to fully disclose the assumptions that it made in designing its sampling plan and clarify the limitations that exist in the data it collects. APHIS did publish its " USDA BSE Surveillance Plan: Background On Assumptions and Statistical Inferences" in September 2004. However, this document does little to clarify the current surveillance plan underway in the U.S. or to enhance its credibility.
APHIS does admit in the statement that their study of the condition of cattle presented for possible testing - as measured between May 2003 and May 2004 has resulted in the probability that: "those animals that had neurological deficits sufficient to lead to injuries - are now being condemned ante-mortem or not being presented for slaughter." Therefore, by APHIS' own report animals that should be examined because they qualify as "downers" are not being tested. Their effort to have these animals presented for testing voluntarily is also not working.
In its statement APHIS indicates that it is not conducting a study of prevalence, but rather is attempting to detect BSE in the U.S. cattle population at or above a specified prevalence with a specified degree of confidence. But by making the admission that the universe is low of "high risk" animals that should be tested in order for APHIS to detect BSE it seems to contradict possible achievement of this goal. And again later in the statement APHIS declares that the testing protocol will help to determine parameters around probable prevalence level of BSE in the United States. Which is it - detection or probable prevalence? Can either be accomplished by this particular study?
APHIS never tells the reader how it will overcome the major flaws identified by the IG such as the fact that its sampling program is voluntary, that it is not geographically viable, and that a significant number of cattle, such as downers that would be expected to be tested in a European study, are not being presented to be tested at all. In fact, the APHIS study certainly contrasts unfavorably with testing protocols in the United Kingdom where all cattle over thirty months of age, and all fallen or downer cattle are tested for BSE.
In the context of excusing itself from not using randomized sampling in the targeted population, APHIS uses the fact that it has not implemented a National Animal Identification System and therefore it is not feasible to "compare the tested group characteristics to the targeted population using criteria such as age, breed, and geographical location." The lack of comparability is undoubtedly true, again putting into question the study itself.
These are only a few of the flaws in the APHIS testing, which is less a plan or a program, than it is a sampling program without a statistically planned model for the use of such samples.
Mr. Secretary, before you alter what animals can enter the human food supply, I strongly suggest that you move forward on a real National Animal Identification System, and that a team of statisticians and risk assessors evaluate the so-called BSE Surveillance Plan in a thorough and scientific manner.
Having lost, by USDA's own estimates, approximately $2 billion last year in beef exports due in part to lack of credibility in the USDA's BSE management program it is critical for us to institute excellent and internationally accepted management programs for BSE. We need new and aggressive leadership at USDA for the good of producers as well as processors, and to ensure we are adequately protecting the health of our citizens in the short and long term.
I look forward to discussing these issues with you in the near future. Please have your staff contact Nancy Mulry at (202) 225 3661 to find a convenient time to meet.
Sincerely,
Rosa L. DeLauro
Ranking Member
Appropriations Subcommittee on Agriculture, Rural Development, Food and Drug Administration and Related Agencies
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http://www.house.gov/delauro/press/2005/April/downer_cows_04_22_05.html