Stauber testimony on CWD 7/22/02
By John C. Stauber
Testimony to Dane County Task Force on CWD
Mount. Horeb Public Library, 7/22/02
My name is John Stauber, I am a resident of Dane
County. My views are
my own and not necessarily those of any other organizations or individuals.
I will keep my comments brief because you have much
work to do, and I
have already provided you with a copy of the 1997 book I co-wrote with
Sheldon Rampton titled Mad Cow USA.
When Sheldon and I were wrapping up our book in
September of 1997 it
came to our attention that Chronic Wasting Disease (CWD) was rampant
in wild
deer in northeastern Colorado, infecting in some areas more than 15%
of the
deer. This was quite stunning because at the height of Britain's
mad cow
epidemic only 1-2 % of cows on infected farms were thought to have
BSE, or
mad cow disease. Since 1997 I have been keeping an eye on CWD
developments
and was not surprised when it showed up in Wisconsin.
I have read the charge of this task force and I
have some observations.
I am not a scientist, but in researching and writing about this issue
I
have had access to some of the top TSE (Transmissible Spongiform
Encephalopathy) researchers in the world. I've found that given
the bizarre
nature of the infectious prion (pree' on) agent sometimes it's easier
for a
non-scientist to grasp the spread of TSE diseases, since they seem
to break
so many rules of science, and are so intricately linked to the past
twenty
years' practice of taking billions of pounds of slaughter house waste
and
turning dead animals into feed supplements for live animals.
Here are my comments:
1.) For more than a decade the federal government
-- the US Department of
Agriculture, the Food and Drug Administration, and the Centers for
Disease
control -- have failed to take the proper steps to monitor and prevent
outbreaks of TSE diseases in both animals and people in the US.
The
mistakes that took place in Britain and Europe in the mishandling of
mad cow
disease are being repeated, not avoided, here in the US with indigenous
TSEs
such as sheep scrapie and CWD. No counties or states
should be expected
to adequately deal with the threat of TSE diseases; this is a
federal
issue, and as long as the federal government fails to recognize and
address
TSE threats, states and counties will be inadequate to the task.
2.) What should the federal government do that it is not doing?
It should
learn from the mad cow crisis and take the same steps that have been
taken
in Europe.
A.) All feeding of mammalian protein to mammals
should be completely
banned and this ban very strictly enforced with severe penalties for
violations.
The 1997 FDA regulations on feeding rendered byproducts
are wholly
inadequate have been widely ignored and poorly enforced. They
simply
require that meat and bone meal from ruminant animals such as cattle,
deer
and sheep be labeled not to be fed to ruminants. At the time
they were
finalized, exactly five years ago, all existing stocks of ruminant
MBM were
allowed to be fed to ruminants, and the General Accounting Office,
the
investigative arm of Congress, this January found serious problems
with
compliance to this regulation.
Even if there were strict compliance, the 1997 regulation
is wholly
inadequate to prevent the spread of TSE agents via animal feed.
For
instance, ruminant blood can be and is fed as a protein source to ruminants,
even though in the laboratory blood can transmit TSE diseases, and
it is for
this reason that Britain no longer uses its own human blood plasma
for
transfusions, since person who have contracted British mad cow disease
have
given blood. But here in the US raw cattle blood plasma is used
as the
protein source for calf starter and milk replacer. The FDA has
known this
for five years, and done nothing.
Rendered ruminant meat and bone meal is fed to pigs
and poultry, and
pigs and poultry are rendered and can be fed to cattle. Pigs
are rendered
and fed to pigs, and even CWD infected deer and scrapie infected sheep
can
be legally rendered and fed to pigs, which can then be fed to cattle.
The FDA was aware of these glaring loopholes in
US feed regulations
before announcing them in 1997, but has done nothing. It is ironic
indeed
that while the state of Wisconsin and Dane County sweat and fret over
how to
safely dispose of more than 25,000 deer carcasses, 500 or more of which
are
probably from CWD infected deer, under US regulations all those deer
could
legally be rendered and used as animal feed for pigs, pets and poultry.
B.) US livestock including cattle, pigs, sheep
and farmed and wild deer
and elk should be extensively tested for TSE agents including BSE (British
mad cow disease), scrapie and CWD. Extensive livestock testing
is now done
in Europe, but the US refuses to do so relying instead on computer
modeling
to declare that the US does not have BSE. The US may or may not
have BSE,
but we do have sheep scrapie and CWD, and since TSE infected sheep
and deer
have been rendered and fed to cattle, pigs and other US livestock,
we may
already have CWD and scrapie strains circulating in US livestock.
In 1995 alone some 26,000 Wisconsin road killed
deer were rendered into
meat and bone meal, and the same rendered product was feed to both
deer and
cattle. There is now growing evidence that byproduct feed given
to deer in
the Eradication Zone was infected with CWD, and we now know that rendered
byproducts have been extensively fed to wild and farmed deer and elk
especially to grow big antlers.
C.) The Centers for Disease Control should
make all types of CJD (TSE
disease in humans) a reportable disease, and maintain and provide regular
statistics on cases of CJD (Creutzfeldt-Jakob Disease). Over
the past few
years there have been growing numbers of young people dying of what
has been
called sporadic or classic CJD, and if CWD is spreading into people
it could
very well appear as classic CJD in younger people. In January
1999 the CDC
refused a petition (from the widow of a young Western hunter who died
of
CJD) requesting that CJD be made reportable, and CDC has been deceptive
in
its handling of this issue, often saying that if CWD were moving into
the
human population it would look exactly like variant CJD (vCJD or British
mad
cow disease in people), when there is no good evidence for that claim.
D.) The US needs to invest billions of dollars
to crank up a crash TSE
identification and prevention program in the US that would emphasize
the
development of new testing procedures to keep TSE infected animals
out of
the food chain. The amount of federal funding for this issue
is abysmal and
unlikely to improve unless states like Wisconsin demand better federal
policies and testing.
3.) The state of Wisconsin has bungled the CWD issue
since at least 1998
when the Thompson administration, in the face of notification that
elk from
CWD infected herds were coming into the state, refused to implement
a DNR
staff recommendation that all live deer and elk imports into the state
be
halted until the day a live test is developed. Instead, the Department
of
Agriculture established an advisory board dominated by owners of deer
and
elk farms, and began managing this issue as a public relations problem
rather than a threat to human and animal safety. While the discovery
of CWD
in Wisconsin has changed that agenda somewhat, the same individuals
are in
charge at the state level and decisions such as the refusal to adequately
test outside the 361 square mile Eradication Zone until the Fall smack
of
political maneuvering to avoid learning the truth about the spread
of CWD
until after the Fall elections. The refusal of the Department
of
Agriculture to require that all deer and elk that die on but don't
leave
game farms be tested provides a loophole for hiding CWD cases on game
farms.
4.) The idea that the Eradication Zone is a unique
hot spot in Wisconsin
or the Upper Midwest is ridiculous, wishful thinking at best, and to
proceed
with current plans based on this assumption is a huge misstep and waste
of
time, resources, and public credibility. The best evidence is
that CWD is
spread in many ways: through animal to animal contact in close
quarters
like feeding plots and game farms; through contamination of the environment;
and, through extensive feeding of rendered byproduct as protein and
mineral
supplements and binders for feed pellets both on game farms and in
the wild.
CWD is a highly invisible disease, and animals appear healthy during
most of
their lives. The DNR has already spent almost a million dollars
killing and
testing deer in the Eradication Zone. Had that money been spent
on testing
statewide, we would have much better data on the extent of the problem
and
how to handle it. Instead, we are likely throwing good money
after bad
pursuing the myth that the practices that spread CWD in the Eradication
Zone
are unique, when these practices are widespread.
5.) The often repeated line that "there is absolutely no evidence
that CWD
could kill people" is false and misleading. In fact, the best
available
scientific evidence is that CWD could infect people, based on the peer
reviewed published work of Dr. Byron Caughey and others at the National
Institutes of Health lab in Montana. This study shows that while
the rate
of transmission might be low, it would probably be equivalent to the
rate of
transmission of mad cow disease, since both CWD and BSE infected prions
were
able to convert normal human prions into being infected in this laboratory
study. Furthermore, the emergence of CJD in a growing number
of young
hunters and venison eaters over the past few years may be the first
cases of
human CWD. There is no proof that CWD is, or is not, spreading
to people,
but the best available scientific evidence indicates it could,
and it is
simply wrong to misrepresent this for the sake of deer management objectives
or to prevent harm to business interests.
6.) Every hunter in Wisconsin should have the opportunity to have
their
deer tested for CWD. Downplaying and denying the human health
risks while
refusing to facilitate hunter testing will backfire. While it
is true that
no CWD test is perfect, making testing available and explaining its
inadequacies will serve the state's interests better. Some state officials
have said that even if CWD kills people, it will be no worse than British
mad cow disease which so far has only killed about 130 people.
This
statement is based on ignorance. The number of cases of British
mad cow
disease in people now seems to be doubling every three years, after
starting with ten
cases in 1996. TSE diseases can incubate invisibly in humans
for decades,
and we do not know yet how many people will die from mad cow disease
in the
decades ahead. Furthermore, if mad cow disease is spread through
surgery
and blood transfusion, the death toll could increase significantly
from
those secondary sources. With CWD there is evidence of its spread
from deer
to deer like a cold or the flu, which is not the case with BSE.
Imagine a
form of CJD that humans can "catch" from each other; that could be
CWD in
people.
7.) We need to take all available precautions or the steps we
do take will
be inadequate and might make matters worse. Since the emergence of
mad cow disease in 1986 in Britain, government agencies and the meat
industry have managed this issue with denial, deceit and public relations
in
an attempt to downplay human health risks and to protect business interests.
While Britain and Europe have learned from their mistakes, the US is
repeating them by ignoring the threats posed by non-BSE strains of
TSE in
the US such as scrapie and CWD. Some say that because scrapie
has been seen
in sheep for 250 years it is not a problem. What that ignores
is that only
for the past couple of decades have billions of pounds of dead animal
waste
been ground up and fed back to animals, creating the feed loops responsible
for the creation, amplification and spread of mad cow disease in Britain
and
probably CWD here in the US. Feeding billions of pounds of rendered
byproduct is still done annually in the US, even though a decade ago
some
inside the USDA wanted it to be stopped.
I hope that Dane County can help to force the regulatory
reforms
necessary for the US to adequately deal with CWD and other TSE threats.
Since byproduct feeding still goes on in the US on a massive scale,
and
since the US is the largest meat producing nation in the world,
a TSE
disaster in the US could make Britain's mad cow crisis pale by comparison.
Unless the proper precautions are taken this scenario could be just
a matter
of time.
Thank you. Please feel free to contact me at
if I can provide any
additional information.
(end)
John Stauber, co-author, Mad Cow USA <www.prwatch.org>
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