February 2001 - Tech Topics

The Certainty of Uncertainty in the European Union: A Profile of North America

By Don A. Franco, D.V.M., M.P.H.
Vice President, Scientific Services, National Renderers Association

Even the world’s most renowned pessimists hate uncertainty because it tends to aggravate their psyche and enhance their anxieties. The beginning of a new year is also not the time to examine the reasons or consequences of uncertainty. Each new year is an opportunity to embrace the positive and plan for constructive change. It is a period for planned progression. In essence, uncertainty is anathema and negative, yet aspects of it will continue to challenge the rendering industry (particularly in Europe) for the foreseeable future. Comparatively, however, many sectors of the world (including North America) have an excellent historical record of produc-ing safe feed ingredients for animal agriculture, pets, and aquaculture.

Globalization has its attribution, however, it comes with a price. The world, having become an electronic village, creates the impression that incidents anywhere have implications everywhere, at least in the industrialized countries. The current crisis in Europe with the tightening controls on animal feed, concurrent with the beef scare due to the increased incidence of bovine spongiform encephalopathy (BSE), exemplifies every symptom of uncertainty and fear. The fear is in context with the variant Creutzfeldt-Jakob disease, the human counterpart of BSE, and the anticipation of an expected increase in incidence, especially in the United Kingdom (UK) and likely France. Unfortunately, other countries in Europe are at risk in varying degrees, and are not exempt from a potential increased incidence of both diseases. Uncertainty, therefore, remains a constant.

The concerns, however, go much deeper than the spongiform encephalopathies, especially in Europe, where the diseases exist. The reactions are totally acute. The infrastructure of government has become suspect. The public suspicion and dissatisfaction that they were denied access to important information that permits people to make adequate choices in matters that deeply affected them, their health, and their families’ well being were central to the criticism of government. And, indeed, hardly a day goes by without the subject of BSE being referred to in the media as epitomizing mal-administration.

The underlying problem that stymied government initially, and throughout the early stages of the outbreak, was that nobody knew whether BSE was a hazard or not. The confirmation of risk was longitudinal and complicated the policy issues. The cumulative uncertainties over the years are symptomatic of the current crisis that is evident throughout the European Union (EU) today. Ultimately, only time will indicate whether or not we have made progress, thus contributing to the “certainty of uncertainty.”

The logical challenge for the United States and Canada is how to work with and eliminate the forces of uncertainty and provide an infrastructure for a rationalistic approach. In retrospect, both countries are fortunate that their governments instituted responsible proactive measures immediately after BSE was diagnosed. This turned out to be most fortunate. I am reminded of the wisdom of a Russian proverb that appears applicable to the United States and Canada governments’ response to the happenings in Europe: “The wise learn from others’ mistakes; the fools learn from their own.”

It does no good to recapitulate the past critically, except to learn from it. Realistically, any charlatan can say I told you so after the fact. The problem facing countries and governments without evidence of the disease in the early phase was what to do to institute preventive controls that would exclude the potential for transmission and spread of the infectious agent of BSE. The science was frightfully uncertain, the description of risks was left to the imagination of the media, and politics intervened in the midst of tentative science and media disinformation. Stephen Strauss of the Globe and Mail summarized the early sentiments succinctly: “Scientific arguments foundered on the shoals of human irrationality. People are not reasoning machines, they are fearing machines, and when there’s a scare, politicians and scientists better tremble.” How very profound!

In a summary reflection of the past, including the current debates and crisis that are presently taking place throughout Europe, it is most appropriate to provide a “nucleus” of the measures taken by the U.S. Department of Agriculture (USDA) and the Food and Drug Administration (FDA) in spite of no evidence of disease (BSE) in the country. Canada has regulations that parallel the United States. A highlight of the prevention and control policies of the United States is for expediency, since I have been aware of them from the inception in 1986.

1. BSE has not been detected in the United States and has been a legally reported disease since November 1986 under Title 9, Code of Federal Regulations (CFR) Parts 161 and 71.

2. Tissues from BSE suspect cases must be submitted for a laboratory diagnosis in the United States under the same titles as above. These include: (a) field cases of cattle exhibiting signs of neurological disease; (b) cattle condemned at slaughter for neurological reasons; (c) rabies-negative cattle submitted to public health laboratories; (d) neurological cases submitted to veterinary diagnostic laboratories and teaching hospitals; and (e) random sampling of aged dairy cattle which are non-ambulatory at slaughter, i.e., fallen stock.

3. 1988 – The establishment of a BSE Working Group as a standing committee to regularly review the currently available science and suggest appropriate regulatory measures.

4. 1989 – Bans the importation of all ruminants, bovine semen, embryos, and meat and bone meal from the UK, where BSE has been officially diagnosed.

5. 1990 – Begins a BSE educational outreach program, educating veterinary practitioners, veterinary laboratory diagnosticians, industry, and producers about the pathology and clinical manifestations of BSE.

6. 1990 – Initiates an active BSE surveillance program, including histopathological examination of brain tissue of high-risk cattle.

7. 1990 – Initiates traceback of cattle imported from the UK.

8. 1991 – Conducts BSE risk analysis.

9. 1991 – Enacts formal regulations to prohibit the importation of most ruminant products from any country known to have BSE.

10. 1993 – Expands BSE surveillance program to include the examination of brain tissue from “downer” cows (fallen stock).

11. 1993 – Updates the 1991 BSE risk analysis.

12. 1994 – Expands diagnostic testing to include supplemental tests for abnormal prion proteins that are indicative of BSE.

13. 1996 – Updates the 1991 BSE risk analysis.

14. 1997 – Prohibits importation of live ruminants and most ruminant products from Europe.

15. 1997 – FDA regulation prohibiting the use of most mammalian proteins in the manufacture of animal feeds to ruminants: Title 21, CFR Part 589, effective August 4, 1997.

16. 1998 – USDA enters into cooperative agreement with Harvard University to analyze and evaluate the effectiveness of the department’s BSE prevention strategies.

17. 1999-2000 – Continued surveillance of “downer” cows increased. The overall level of U.S. surveillance is five times the recommended criterion of the International Organization of Epizootics standards.

You may serve as judge and jury. The government(s) reacted with extensive policies and regulations in a country(ies) in which the disease (BSE) was never diagnosed in the cattle population. Some of the policies were in the same year that the disease was first diagnosed in the UK (1986). We continue to monitor the global situation, especially the activities in Europe, and make sure that the EU takes the necessary precautions to preclude hazards and eliminate the potential for dissemination of the infectious agents to other countries. Our actions were responsible. I can only hope that we enjoy the benefits of accountability.