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Lack of Systematic Sampling of Cow Brains for BSE

Secretary Ann M. Veneman
U.S. Department of Agriculture
14th & Independence Ave., SW
Washington, DC 20250

Dear Secretary Veneman: 

As you know, Americans are understandably concerned about the possibility of mad cow disease or bovine spongiform encephalopathy (BSE) occurring in this country.  Having witnessed the public health, social and economic devastation wrought by the disease in Europe, they are anxious not to see similar scenarios occur here.  While there have been no cases of either BSE or its human equivalent, variant Creutzfeldt-Jakob disease (vCJD), in this country, over 100 people, primarily in Europe, have been diagnosed with vCJD and most of them have already died.  

One line of defense is surveillance: systematic sampling by the USDA of cow brains from around the country.  In the accompanying report, Public Citizen and the Government Accountability Project examine the current U.S. surveillance system for BSE.  Our premise was that, because there is no reason to expect BSE to be significantly more likely to appear in one part of the country or another, testing rates should be approximately equal in all states.  

We used data from the USDA to compare the bovine testing rates between states for the period August 1997-December 2000. There was a 400- to 2,000-fold difference between the states with the highest and lowest testing rates. Attempts to adjust for the age of the cattle slaughtered or their feed do not account for the massive variations in testing rates between states.  

Based on these findings, the report made five recommendations:

  1. Increase the transparency of the testing
  2. Develop clear criteria for the selection of animals for testing
  3. Randomly select slaughterhouses for testing of downer cattle
  4. Monitor state testing rates to identify states with low rates
  5. Conduct unannounced inspections to monitor compliance with the testing requirements  

Please review the attached report and indicate whether and how you plan to order compliance with our recommendations.  We are willing to meet with you to discuss them further.  

Yours sincerely,  

Peter Lurie, M.D., M.P.H.
Deputy Director
Public Citizen’s Health Research Group  

Felicia Nestor
Food Safety Project Director
Government Accountability Project

Patricia Lovera
Public Citizen’s Critical Mass Energy and Environment Program 

Sidney M. Wolfe, M.D.
Director Public Citizen’s Health Research Group 

Wenonah Hauter
Public Citizen’s Critical Mass Energy and Environment Program