USDA Answers Questions on Expanded BSE Testing

Information on the BSE surveillance program is available at: www.aphis.usda.gov

NCBA has supported the USDA Animal and Plant Health Inspection Service (APHIS) BSE surveillance program since its implementation in 1990 as one of the important firewalls to protect against BSE.  USDA now has initiated an expanded 12-18 month BSE testing program designed to determine the presence of BSE in the U.S. and, if it exists, the prevalence of the disease. NCBA believes that effective implementation of this program is important and supports USDA’s efforts.

However, there are aspects of the expanded testing program that NCBA feels USDA did not sufficiently explain when the program was announced. In this regard, NCBA sent a letter on May 25 to Dr. Ron DeHaven, administrator of APHIS, and Dr. Barbara Masters, acting administrator  of USDA’s Food Safety and Inspection Service (FSIS), with questions and concerns that needed to be addressed regarding the expanded BSE testing program. 

NCBA received a response from APHIS and FSIS and a summary of updated information on the USDA expanded testing program is provided  below. However, NCBA feels there are important issues that remain unclear and some questions that remain unanswered.  It is vital to the beef industry that these issues be thoroughly discussed and addressed in order for this program to be effective.     

While the letter of response from APHIS and FSIS clarified many of the issues raised by NCBA, there remain a few areas that require additional information and clarification.

1.   Protection of producers - USDA has established a toll-free number for producers to report high-risk cattle to be part of the surveillance program.  However, USDA has not addressed confidentiality issues to protect a producer who does report an animal, no matter the final result of the BSE test.  There is concern that it will become known when a producer reports an animal and create a risk-averse reaction among potential buyers that will make it difficult or impossible for the producer to market other animals from that herd. 

2.   Indemnity - APHIS’s response to NCBA noted that the area veterinarian in charge and the APHIS Marketing and Regulatory Programs Business Services personnel are responsible for final decisions regarding compensation to owners of animals sampled.  NCBA would like to know the guidelines for making decisions about compensation.  Although each state may have different circumstances, producers must be made aware of the guidelines and compensation details or they are unlikely to be comfortable participating in the program.

3.   Handling of inconclusive test results - The USDA announcement on June 25 of an inconclusive test result illustrated the process USDA will employ in the event other inconclusive results are identified.  NCBA continues to feel the term “inconclusive” may be confusing and is not a true description of the results from these tests because the term includes samples that are found to be “false positives” as well as those that accurately identify a case of BSE as confirmed by immunohistochemistry.

NCBA will be seeking a meeting with USDA to discuss these points.  NCBA encourages state partners and producer leaders to review the information provided by USDA and contact NCBA with any additional concerns about the expanded BSE testing program.

On-Farm Surveillance Issues

Two fact sheets on the surveillance program are now available at the APHIS Web site listed above.

While USDA has not placed specific requirements on the final number of samples each state must take, the agency did request that each state develop a local plan for sampling. Each state, as part of that plan, estimated the number of samples it could obtain. USDA posted examples of what could be considered target geographic distributions of sample collections to the APHIS Web site.

• The top ten states are: California, Idaho, Minnesota, Missouri, Nebraska, New York, Oklahoma, Pennsylvania, Texas and Wisconsin.

• USDA says it expects to obtain a vast majority of samples from rendering, dead stock and salvage slaughter facilities (dead, down, disabled slaughter establishments). It expects these samplings to exceed 80 percent of all samples in some geographic areas.

• USDA established a toll-free number for reporting high-risk cattle. That number is 866-536-7593.

• The APHIS area veterinarian in charge (AVIC) will serve as the primary contact for each state. A state-by-state listing of AVICs can be found at the APHIS Web site listed above.

• Final decisions regarding compensation must be made by each APHIS area veterinarian in charge. Individuals wanting to redeem costs should contact their area office. APHIS has provided each AVIC with general guidelines and appropriate payment instructions.

Sample collection procedures

• USDA published specific sampling processes to its APHIS Web site.

• USDA expected to begin sampling 20,000 apparently normal, but older, animals in late June or early July.

Release of information

• USDA posts a weekly total of tests performed to its APHIS Web site, listed above. The number of inconclusive results, if any, will be reported daily on the same site.

• Any samples that test positive in the initial rapid test will be classified as inconclusive and will be submitted to the USDA’s National Veterinary Services Laboratory (NVSL) in Ames, IA, for confirmatory testing.

• If an inconclusive result occurs, USDA will report after the markets close on the day the result is received that a test has yielded an inconclusive result and that the sample has been submitted to the NVSL for confirmatory testing. Information contained in this report will confirm that samples have been sent to NVSL, when confirmatory test results are expected and confirmation that the animal did not enter the food or feed chain. As necessary, USDA will hold a technical briefing for the media regarding the inconclusive result. USDA will not release information such as the type of animal tested, where the animal was from or which lab did the testing.

• USDA continues to refine the communication plan for dealing with potential inconclusive or positive test results. As part of the planning process, they say they will consider responses to many different potential testing scenarios.

Harvest Issues

Antemortem condemned animals

• All cattle euthanized following antemortem condemnation will be sampled-with two exceptions:

– Veal calves condemned by a trained FSIS public health veterinarian, but not exhibiting signs of CNS disorder, will not be sampled

– Cattle condemned on antemortem inspection, but which the establishment elects to treat, will not be sampled, but must presented for normal inspection at a later date (once they’ve received treatment for a condition that may have caused clinical signs resulting in condemnation upon first antemortem inspection). See http://www.fsis.usda.gov/OPPDE/rdad/FSISNotices/28-04.htm for additional information.

The reason for each condemnation will be recorded in the Animal Disposition and Reporting System Database (ADRS). The reason for condemnation also will be recorded in the APHIS BSE surveillance database. The ADRS database is open to the public and can be accessed electronically at http://www.fsis.usda.gov/Frame/FrameRedirect.asp?main=/ophs/ophswho.htm. The database also contains a list of diseases for which cattle are routinely condemned.

• Sample submission forms will also include the reason for condemnation.

• Condemnation decisions of FSIS public health veterinarians are final; however, plants may appeal the decisions.

Approval for alternative procedures for collecting brain samples

• USDA provided instructions to firms interested in establishing alternate procedures to those suggested by USDA for BSE surveillance sampling in FSIS Notice 29-04 (see the following link: http://www.fsis.usda.gov/OPPDE/rdad/FSISNotices/20-04.htm). The notice outlines six points of explanation the requesting firm must provide before it can receive approval to conduct alternate sampling procedures, including removal of the carcass to another location. Thus far, about 17 requests for alternative procedures have been submitted by slaughter establishments, and reviewed by FSIS district managers.