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Comment From Terry ...

Notice: Environmental Impact Statements; Availability, etc.: Animal Carcass Management


  • Greetings APHIS et al, and thank you kindly for allowing me to comment on Environmental Impact Statements; Availability, etc.: Animal Carcass Management [Docket No. APHIS-2013-0044]. I don’t believe I saw the BSE TSE prion aka mad cow type listed in this, but I thought I should list my concerns there from anyway, with relations to this Environmental Impact Statements; Availability, etc.: Animal Carcass Management [Docket No. APHIS-2013-0044]. I well remember what was said long ago ; In Confidence - Perceptions of unconventional slow virus diseases of animals in the USA - APRIL-MAY 1989 - G A H Wells 3. Prof. A. Robertson gave a brief account of BSE. The US approach was to accord it a very low profile indeed. Dr. A Thiermann showed the picture in the ''Independent'' with cattle being incinerated and thought this was a fanatical incident to be avoided in the US at all costs. ... with the recent mass bovine deaths from the floods, the drought, the recent snow storm, and the known fact that mad cow disease of the c-BSE, atypical h,g-BSE, atypical h-BSE, and the atypical l-type BASE BSE, two strains of CWD in cervids, and the deaths there from in the cervid populations from cwd, and ehd, all this proves the USA is, and has been, far from being prepared for any type of major animal disease outbreak, foreign or domestic. also, with all the mass cattle deaths of late, it would have been a perfect time to test for mad cow type disease, if anyone would have attempted such a task, but we know how mad cow TSE testing goes by the USDA et al, that would have just made too much sense to test a mass cattle death for mad cow disease, and of course difficult, with such short time available when turning in and testing samples for a TSE prion disease, but still, a perfect opportunity gone by and missed. I have long been concerned with the Transmissible Spongiform Encephalopathy TSE prion disease, and all it’s strains in the many different species in North America, and the ramifications there from when considering carcass disposal, and I recent put together the following, about soil contamination from the TSE prion, along with other recent science on the potential update of prions to plants. Chronic Wasting Disease CWD, and other TSE prion disease, these TSE prions aka mad cow type disease know no borders. these TSE prions know no age restrictions. The TSE prion disease survives ashing to 600 degrees celsius, that’s around 1112 degrees farenheit. you cannot cook the TSE prion disease out of meat. you can take the ash and mix it with saline and inject that ash into a mouse, and the mouse will go down with TSE. Prion Infected Meat-and-Bone Meal Is Still Infectious after Biodiesel Production as well. the TSE prion agent also survives Simulated Wastewater Treatment Processes. IN fact, you should also know that the TSE Prion agent will survive in the environment for years, if not decades. you can bury it and it will not go away. The TSE agent is capable of infected your water table i.e. Detection of protease-resistant cervid prion protein in water from a CWD-endemic area. it’s not your ordinary pathogen you can just cook it out and be done with. that’s what’s so worrisome about Iatrogenic mode of transmission, a simple autoclave will not kill this TSE prion agent. I wish to submit the following recent and old TSE prion science, some from PRION2013, PRION2012, PRION 2011, data on mass livestock mortality death disposal methods such as Alkaline hydrolysis, composting, burial, rendering, incineration, and some data from the BSE Inquiry submissions going back to 1989, some of which I hope you may find useful. the BSE Inquiry submissions will be at the bottom of my submission here. First, the latest science on the TSE prion disease and reports there from, then what do other countries think of the USA and it’s capability of carcass disposal, and types of methods to dispose of large animal mortality events, and last, the old science from the BSE INQUIRY and what they thought on carcass disposal and the TSE PRION. ‘’There are many disposal options for dead livestock currently in use throughout the world; however, the knowledge that TSEs and some pathogens may not be completely destroyed may limit their utility in the wake of changing legislation (e.g. the amended EU Animal By-Products Regulation (1069/2009) which comes into effect in March 2011). On-farm disposal methods are favoured by the farming community due to the perceived environmental, practical, economical and biosecurity benefits, therefore processes such as composting and anaerobic digestion have found favour in countries such as the USA and Canada. Under the ABPR in the EU, these options are not deemed safe’’ snip... see my full text submission with source references in attachment...TSS

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SUB TYPE Public Comment
Status Posted
Received Date November 03 2013, at 12.00 AM EST
Date Posted November 21 2013, at 12.00 AM EST
Tracking Number 1jx-88ja-ui7z
Comment Start Date October 25 2013, at 12.00 AM EST
Comment Due Date November 25 2013, at 11.59 PM EST
Object ID 090000648146e8c2
First Name Terry
Page Count 0