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>

Back to maddeer.org