![](media/image1.jpeg){width="7.25in" height="1.0638888888888889in"}

> ![](media/image2.jpeg){width="1.2444444444444445in"
> height="8.792361111111111in"}

**Food Safety**

Allowing downers to be processed for human food threatens the safety of
the food supply. Non-ambulatory disabled cattle are understood to be at
heightened risk for BSE. A Swiss study (one of several cited by USDA)
found that downer cattle are 49 to 58 times more likely to have BSE than
cattle identified through passive surveillance (i.e., those reported to
veterinary authorities as BSE-suspect based on clinical
observation).^4,5^ Given the terrible and devastating nature of new
variant Creutzfeldt-Jakob disease (vCJD) in humans, thought to be caused
by eating meat contaminated with the abnormal prions that cause BSE,
keeping downer cattle out of the U.S. food supply makes eminent sense.

Animals unable to stand or walk are not only at a higher risk of
suffering from BSE but also have been shown to have a higher prevalence
of *Escherichia coli*, *Salmonella*, and other dangerous pathogens that
can transmit disease to consumers. In particular *E. coli* O157: H7 is a
significant public health concern because it has been implicated in more
than 70,000 human infections and around 61 human deaths each year in the
U.S.^6,\ 7^ Cattle are the primary reservoir for *E. coli* O157:H7^8^
and a study on the subject found downer cattle were more than 3 times
more likely to have this deadly pathogen than healthy cattle.^9^ Downer
cows can also shed more salmonella.^10^

**Public Support**

When the USDA announced its interim ruling prohibiting the processing of
non-ambulatory disabled cattle for the human food supply, there was an
outpouring of public support. Major retailers, consumer groups and other
nonprofits, and some agricultural organizations and individual ranchers
expressed strong support for the ban as well. In fact, of approximately
22,000 comments submitted to the USDA, more than 99 percent strongly
support the ban. Details on this and more are included in the linked
HSUS report "[**Public Comments on USDA's Downed Animal Ban: Major
Retailers and the Vast Majority of Americans Support No-Downer Policy;
Some Industry Groups Reverse Their Support for the
Ban**](../../../../../../../../F:/BSE/USDA%20comments/2004_06_16_rept_USDA_comments.pdf)".
The massive support for the ban was not only based on food safety
concerns but also humane concerns, and is in line with a 2003 Zogby poll
that showed a majority of Americans oppose the use of downed animals for
human food. According to that poll, more than three-fourths of the U.S.
population feels it is unacceptable to use downed animals for human
consumption (77%). An even larger majority of the U.S. population is
concerned that sending downed animals to slaughterhouses could put human
consumers at risk for mad cow disease (81%).^11^ The FDA should heed
this strong and unwavering support for the prohibition on non-ambulatory
disabled cattle and extend the ban to the human food and cosmetics it
oversees.

In conclusion, we urge the FDA to prohibit the use of non-ambulatory
disabled cattle in the human food and cosmetics under its regulation.
Animals that are unable to stand and walk are suffering and their meat
and meat byproducts should be entirely kept out of the food supply.
Thank you for your time and consideration.

Sincerely,

Wayne Pacelle

President and CEO

References:

1.  LCI Annual Meeting Proceedings. 1996. Website:
    <http://www.animalagriculture.org/Proceedings/1996AMProceedings.asp>

Accessed August 2004

2.  Grandin T. 1998. Handling of Crippled and Nonambulatory Livestock.
    *Animal Welfare Information Center Bulletin*. Volume 9, Number 1/2,
    Fall 1998

3.  Grandin T. 1991. Pro-active activism. *Meat & Poultry.* August 1991

4.  Doherr MG, Heim D, Fatzer R, Cohen CH, Vandevelde M, and A
    Zurbriggen. 2001. Targeted screening of high-risk cattle populations
    for BSE to augment mandatory reporting of clinical suspects. *Prev
    Vet Med. 2001.* 51(1-2):3-16

5.  Food Safety and Inspection Service, USDA. 2004. Prohibition of the
    Use of Specified Risk Materials for Human Food and Requirements for
    the Disposition of Non-Ambulatory Disabled Cattle. *Federal
    Register* 69(7)1862-1874

6.  Byrne CM, Erol I, Call JE, Kaspar CW, Buege DR, Hiemke CJ,
    Fedorka-Cray PJ, Benson AK, Wallace FM, and JB Luchansky. 2003.
    Characterization of Escherichia coli O157:H7 from downer and healthy
    dairy cattle in the upper Midwest region of the United States. *Appl
    Environ Microbiol*. 2003 Aug;69(8):4683-8

7.  Kassenborg HD, Hedberg CW, Hoekstra M, Evans MC, Chin AE, Marcus R,
    Vugia DJ, Smith K, Ahuja SD, Slutsker L, Griffin PM, and Emerging
    Infections Program FoodNet Working Group. 2004. Farm visits and
    undercooked hamburgers as major risk factors for sporadic
    Escherichia coli O157:H7 infection: data from a case-control study
    in 5 FoodNet sites. *Clin Infect Dis*. 2004 Apr 15;38 Suppl 3:S271-8

8.  *Id*

9.  Byrne CM, Erol I, Call JE, Kaspar CW, Buege DR, Hiemke CJ,
    Fedorka-Cray PJ, Benson AK, Wallace FM, and JB Luchansky. 2003.
    Characterization of Escherichia coli O157:H7 from downer and healthy
    dairy cattle in the upper Midwest region of the United States. *Appl
    Environ Microbiol*. 2003 Aug;69(8):4683-8

10. New York State Cattle Health Assurance Program. 2002. Website:
    [http://nyschap.vet.cornell.edu/module/salmonella/section2/SalmonellaRiskAssessment.pdf
    Accessed August
    2004](http://nyschap.vet.cornell.edu/module/salmonella/section2/SalmonellaRiskAssessment.pdf Accessed August 2004)

11. Zogby International. 2003. Results from Zogby America Poll. Zogby,
    New York