HAZARDS OF DOWNED CATTLE

Dockets Management Branch
U.S. Food and Drug Administration
5640 Fishers Lane, Room 1061
Rockville, MD 20852

Re: Docket # 98P-0151/CP1

S.T.O.P. - Safe Tables Our Priority is a non-profit, grassroots organization consisting of victims of foodborne illness, family, friends and concerned individuals who recognize the threat pathogens pose in the U.S. food supply. S.T.O.P.'s mission is to prevent unnecessary illness and death from foodborne microbial contamination. We count among our members victims of E. coli 0157:H7 contaminated meat, lettuce and apple juice; Hepatitis A contaminated strawberries, Vibrio vulnificus in oysters, Salmonella contaminated poultry and eggs, and Campylobacter contaminated poultry. In all of these cases, the dangers of potentially contaminated products were known to government. In all of these cases, industry practices and inadequate governmental regulations and enforcement failed to protect consumers from life-threatening pathogens.

We appreciate the opportunity to comment on Docket #98P-0151/CP1.

To protect the health and safety of the American public, S.T.O.P. urges the FDA to immediately ban the use of "downed" animals for use in all food. USDA regulation 9 C.F.R. section 301.2(y) defines downed animals as diseased. The current USDA ban on the use of meat from downed animals in federal institutions such as schools and employee cafeterias does not reach nearly wide enough in protecting all populations and should be expanded to include all meat designated for human consumption. Furthermore, the public deserves to be protected from the use of diseased animals in all foods regardless of whether it falls under USDA or FDA jurisdiction.

The entry of paralyzed and downed animals into the public food supply is inherently unsafe. Downed animals demonstrate higher bacterial levels initially and then pick up substantially more filth and pathogens when dragged along the ground, through dirt and fecal matter, after falling (1). The resulting levels of contamination have the potential to overwhelm subsequent HACCP safeguards and any subsequent killsteps. Of concern as well is that these organisms on the exterior of the animal could become aerosolized in the plant and/or colonize the plant (2).

Furthermore, insufficient research has been done to determine why downed animals fall. The animal's inability to stand or walk is a potential indicator of serious, transmissible neurologic disease and may not be considered by the veterinarian at that point. An animal's inability to stand or walk which is currently attributed to a stumble resulting in a fractured limb could well be the warning sign of an early-stage neurological impairment. The very real threat of Bovine Spongiform Encephalopathy (BSE), combined with its long incubation period and its potentially disastrous implications for public health, makes this policy an invitation for disaster.

The members of S.T.O.P. know firsthand the devastating penalty of safeguards that are too lax. We urge you to act immediately to prevent future suffering and deaths from contaminated meat by prohibiting the use of downed and paralyzed livestock as adulterated and unsuitable for any food items.

Sincerely,

Nancy Donley
President

Karen Taylor Mitchell,
Executive Director 

1) Smith, Gary (distinguished professor, Colorado State University) at the American Meat Institute Animal Handling and Stunning Conference, February, 1999, as reported by Grandin, Temple, in "A.M.I. Sponsors Stunning and Handling Conference", Meat & Poultry, March 1999, p.48-49.

2) Keller, Susanne (National Center for Food Safety and Technology, FDA), "Consequences of Poor Apple Quality, Sanitation, and Persistence of E. coli", presentation given at Apple Hill Research Summary: Juice HACCP Final Rule" meeting, High Hill Ranch, Placerville, CA; April 25,2001.