SUNDAY, MAY 18, 2008
BSE, CJD, and Baby foods (the great debate 1999 to 2005)
BSE, CJD, and Baby foods (the great debate 1999 to 2005)
Bovine Spongiform Encephalopathy
BSE-L is a discussion forum for scientists who are interested in Bovine Spongiform Encephalopathy (BSE). BSE-L has been created on 20th July, 1994 by Siegfried Schmitt. Impressum: http://www.kaliv.de/impressum.html
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CJD and Baby foods (the great debate 1999)
Subject: Re: Girl, 13, shows CJD symptoms.
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Wed, 24 Nov 1999 11:35:44 -0600 Content-Type: text/plain Parts/Attachments: text/plain (67 lines)
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Heather Paine should be educated on the products she over-sees. These children's health are at risk, and if she does not know what has and has not been going into baby-foods, she does not need to hold that position. The Inquiry was very concerned about baby foods, and at one point said something about; they were no different than the SBO's, in some cases, depending on the ingredients, of that particular kind of baby food. I forget the exact quote and by whom it was said??? I have it somewhere, but my filing system has a lot, _not_ to be desired for..............
Debora MacKenzie wrote:
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GIRL, 13, SHOWS CJD SYMPTOMS November 23, 1999 PA News John von Radowitz, Medical Correspondent, PA News
A 13-year-old girl may, according to this story, be the youngest victim of the human form of mad cow disease. The girl, whose identity and whereabouts are being kept secret, is, the story adds, thought to be displaying symptoms of new variant Creutzfeldt Jakob Disease. The story says that if the case is confirmed it has major implications. It raises the question of whether the girl was infected by baby food, and may shed light on the disease's incubation period. The girl was less than a year old in 1986 when BSE, the cattle disease thought to manifest itself in humans as the new variant form of CJD, was formally identified. Three years later the Government banned parts of the cow most likely to be infected, such as the brain and spinal cord, from human food products. So far the youngest of the 48 people to have died from nvCJD has been 16. David Churchill, chairman of the support group the Human BSE Foundation, was cited as saying he was aware of the case, adding, "I can confirm that the story is true - the girl is showing symptoms of the disease. This case raises a whole new spectre. There's no way anyone can say this child picked up nvCJD prior to knowledge about BSE. Back in 1986 BSE was not only identified but becoming prevalent. It can only have been picked up after the emergence of BSE, and the likelihood is that it was through baby food. ...
The ability to diagnose this illness from its symptoms is improving with each case, and there are some fairly clear diagnostic guidelines now. The chances of a misdiagnosis, or missed diagnosis, are less likely than they used to be." Although the disease could only be confirmed for certain after death, the girl was showing signs and behaviour known to be linked with nvCJD. Heather Paine, spokeswoman for the Infant and Dietetic Foods Association, was cited as saying that as far as she knew no high-risk beef material, such as mechanically recovered meat stripped off the spine, had ever been used in baby products, adding, "To my knowledge no MRM from cattle has ever been put in baby food. Manufacturers are very aware of what mothers want to feed their babies." At one-year-old the girl would probably have been weaned off commercial baby food and eating home-prepared meals which may have included mince and beef cuts, said Ms Paine.
Debora MacKenzie, Europe correspondent, New Scientist. tel: +32-2-245-0412 fax: +32-2-245-0552 email: d.mackenzie@chello.be
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Subject: Re: Girl, 13, shows CJD symptoms. [re-baby food]
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Thu, 25 Nov 1999 11:21:52 -0600 Content-Type: text/plain Parts/Attachments: text/plain (66 lines)
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Hello Robert and All,
I would like to point out in DFA 9
99. Mr. Lawrence wrote a letter to Sir Richard on 6 January 1989 (110) explaining that there were _no_ special regulations with regard to the composition of baby food except in relation to additives, and that there was therefore _nothing_ in the rules that would exclude certain parts of animal being incorporated into baby foods as long as they were fit for human consumption.
152. There is _no_ evidence of written assurances from the manufacturers supplied to either MAFF or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus.
155. The reply also outlined the following actions already taken or to be taken by the Government in response to the Working Party's recommendations. 1) As a precautionary measure the Government would enact secondary legislation to ensure it was illegal to sell Baby Food containing brain, spinal cord, spleen and intestines.
165. On 23 May 1989 Mr. Cockbill prepared draft regulations prohibiting the use of certain _specified offals_ in Baby Foods...
Kind Regards, Terry S. Singeltary Sr., Bacliff, Texas USA
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Subject: Re: Girl, 13, shows CJD symptoms. [re-baby food]
From: J Ralph Blanchfield
Reply-To: Bovine Spongiform Encephalopathy
Date: Thu, 25 Nov 1999 22:30:36 +0000 Content-Type: text/plain Parts/Attachments: text/plain (168 lines)
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Hello Robert, Terry and Everyone,
On Thu, 25 Nov 1999 13:17:45 -0500, Robert LaBudde wrote:
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At 11:21 AM 11/25/99 -0600, Terry wrote: I would like to point out in DFA 9
99. Mr. Lawrence wrote a letter to Sir Richard on 6 January 1989 (110) explaining that there were _no_ special regulations with regard to the composition of baby food except in relation to additives, and that there was therefore _nothing_ in the rules that would exclude certain parts of animal being incorporated into baby foods as long as they were fit for human consumption.
152. There is _no_ evidence of written assurances from the manufacturers supplied to either MAFF or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus.
155. The reply also outlined the following actions already taken or to be taken by the Government in response to the Working Party's recommendations. 1) As a precautionary measure the Government would enact secondary legislation to ensure it was illegal to sell Baby Food containing brain, spinal cord, spleen and intestines.
165. On 23 May 1989 Mr. Cockbill prepared draft regulations prohibiting the use of certain _specified offals_ in Baby Foods...
Thanks for the relevant information, Terry.
I over-generalized based on US experience. There's a thick wad of FDA regulations concerning baby food in this country, and I made the mistake of presuming that this was a similar occurrence in Europe.
If the UK was really this cavalier about baby food, the regulations on 'normal' food must be very weak. It's still hard to believe this is really true.
Perhaps JRalph could help us out with an authoritative comment on this issue.
I'll do my best. You really are keeping me hard at work today here and elsewhere, aren't you, Robert?
_Specific_ Regulations relating to baby foods prohibit added colours, artificial sweeteners and some additives, limit pesticide residues and vitamin A content. There are no "recipe" Regulations affecting them.
Baby foods, and all other foods, are subject to the general provisions that are in the Food Safety Act 1990 and were in its predecessors all the way back to 1872.. Section 7 of the 1990 Act states:
7. Rendering food injurious to health
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
(1) Any person who renders any food injurious to health by means of any of the following operations, namely- (a) adding any article or substance to the food; (b) using any article or substance as an ingredient in the preparation of the food; (c) abstracting any constituent from the food; and (d) subjecting the food to any other process or treatment; with intent that it shall be sold for human consumption, shall be guilty of an offence. (2) In determining for the purposes of this section and section 8(2) below whether any food is injurious to health, regard shall be had- (a) not only to the probable effect of that food on the health of a person consuming it; but (b) also to the probable cumulative effect of food of substantially the same composition on the health of a person consuming it in ordinary quantities. (3) In this Part ‘injury’, in relation to health, includes any impairment, whether permanent or temporary, and ‘injurious to health’ shall be construed accordingly.
Section 8 contains two provisions -- 8(2)(b) and 8(2)(c) -- not in the predecessors of the 1990 Act:
8 Selling food not complying with food safety requirements
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
(1) Any person who-
(a) sells for human consumption, or offers, exposes or advertises for sale for such consumption, or has in his possession for the purpose of such sale or of preparation for such sale; or
(b) deposits with, or consigns to, any other person for the purpose of such sale or of preparation for such sale, any food which fails to comply with food safety requirements shall be guilty of an offence.
(2) For the purposes of this Part food fails to comply with food safety requirements if-
(a) it has been rendered injurious to health by means of any of the operations mentioned in section 7(1) above;
(b) it is unfit for human consumption; or
(c) it is so contaminated (whether by extraneous matter or otherwise) that it would not be reasonable to expect it to be used for human consumption in that state, and references to such requirements or to food complying with such requirements shall be construed accordingly.
(3) Where any food which fails to comply with food safety requirements is part of a batch, lot or consignment of food of the same class or description, it shall be presumed for the purposes of this section and section 9 below, until the contrary is proved, that all of the food in that batch, lot or consignment fails to comply with those requirements.
(4) For the purposes of this Part, any part of, or product derived wholly or partly from, an animal-
(a) which has been slaughtered in a knacker’s yard, or of which the carcase has been brought into a knacker’s yard; or
(b) in Scotland, which has been slaughtered otherwise than in a slaughterhouse, shall be deemed to be unfit for human consumption.
(5) In subsection
(4) above, in its application to Scotland, ‘animal’ means any description of cattle, sheep, goat, swine, horse, ass or mule; and paragraph (b) of that subsection shall not apply where accident, illness or emergency affecting the animal in question required it to be slaughtered as mentioned in that paragraph.
Baby foods, like all foods, are of course also subject to the extensive provisions of the Food Safety (General Food Hygiene) Regulations 1995 (and parallel Hygiene Regulations covering specific food sectors).
It is easy with the 20/20 vision of hindsight to say now that certain animal derivatives should not have been used in baby foods (and indeed we do not know that they were, and Heather Paine is quoted as saying that to her knowledge they were not). Until the investigations of the Southwood Committee, there was anyway no reason to suppose that these materials, from apparently healthy cows, were other than wholesome or had any connection with BSE or indeed vCJD (the existence of which was at that point unknown). As it happens, the food manufacturer for which I worked in the early 1950s, among its many canned, bottled, frozen and dehydrated products, manufactured a range of baby foods including a beef broth, which was made from Argentinian frozen beef -- no offals of any kind.
But each manufacturer decided for itself what ingredients to use, and they were/are in no way controlled or "overseen" by a trade association, which is what the Infant and Dietetic Foods Association was/is. So Terry, your attack on Heather Paine was unwarranted and badly misconceived, and I think you owe her an apology.
I happen to know Heather well in an entirely different connection, and a more honest and conscientious person it would be hard to find.
Finally, if it is vCJD, there is no more reason to suppose that the girl in question acquired the infection from baby food than from infected mince after weaning or from the infected vaccines that we now know were in use.
Regards Ralph
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J Ralph Blanchfield MBE Food Science, Food Technology & Food Law Consultant Chair, IFST External Affairs Web Editor, Institute of Food Science & Technology IFST Web addresse-mail: ICQ# 6254687. ICQ Web page
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Subject: Re: Girl, 13, shows CJD symptoms. [re-baby food]
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Fri, 26 Nov 1999 10:36:34 -0600 Content-Type: text/plain Parts/Attachments: text/plain (210 lines)
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Hello Ralph and All, I think you are correct Ralph, after reading back over my comments, I was a bit hasty, and in a friends eyes, may have even seemed rude. For that I would like to apologize to Heather and You. It still does not change my position on the matter. It would have been better directed, if I would have directed my haste, to the _whole_ industry involved, as opposed to Heather and the Baby Food industry. For obvious reasons, if the DFA's are accurate, and the statements within from the Working Party and the Gov. and the statement from the manufacturers of Baby Foods, where they are stating in DFA 9; "152. There is no evidence of written assurances from the manufacturers supplied to either Maff or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus". Then from past experiences from big industry, I would bet that the ingredients in question were used.
Not to change the subject, but if the people that oversee adult products for consumption, allows manufactures of pills in (nutritional supplements) in 1999, to put "brain, eyeballs, pituitary, and scrotum" in these pills, then pass them off as miracle cures from heaven that will cure everything from aids to the common cold. Then allow them to label it as "100% herbal". And then top it all off, instead of classifying them as pharmaceuticals, they classify them as _food_. If the people that oversees this, has anything to do with what goes in baby foods, after the manufactures comments, I just find it hard to believe, that this did not take place, and to some extent, still is. All this, going into the year 2000, and we are still debating if brain and or other sbo's should be going into the human food chain (and they still are), after knowing for many years about the highly infectivity of the brain, eye and other organs and or tissues. This I do not understand, and this is why I most hastily replied to Heather's comments. Hope this smoothes' things over Ralph.........
Kind Regards, Terry
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Subject: Re: Girl, 13, shows CJD symptoms. [re-baby food]
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Sat, 27 Nov 1999 18:54:39 -0600 Content-Type: text/plain Parts/Attachments: text/plain (397 lines)
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Thanks Ralph,
re-Heather<>
I have learned from the past, about TSE's and information. Being passive, or suttle, and or subdued, and simply saying o.k. to an answer, does not get it. You don't find out much that way. Although since being on this list, I have learned a great deal about being diplomatic, "I thought". Although I guess you could say sometimes, that I am ranting. It is for a good cause, and I probably have a lot more to learn. Speaking through these machines, across oceans, it's easy to do sometimes. I don't believe I have been the only one on this list to rant.
guilt by association, and U.K. laws about nutritional supplements<>the manufactures".
< a2="ind9911&L=" p="R15856&X=" y="flounder9%40verizon.net">Reply-To: Bovine Spongiform EncephalopathyDate: Sun, 28 Nov 1999 11:46:07 +0000 Content-Type: text/plain Parts/Attachments: text/plain (119 lines)
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Hello Terry and Everyone,
On Sat, 27 Nov 1999 18:54:39 -0600, Terry wrote:
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I have one question for you Ralph; from the statement made by the manufactures to the Gov. "152. There is no evidence of written assurances from the manufacturers supplied to either Maff or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus". If in fact, the manufactures could not supply this information to the Gov., confirming that baby food did not or has not contained bovine brain, spinal cord, spleen intestines and thymus;
What would you understand this to mean?
Firstly, the DFA paragraph 152 does _not_ say "the manufactures could not supply this information to the Gov". It says that there is no written evidence that they did -- not the same thing at all.
I do _not_ understand the DFA paragraph 152 to mean "the statement made by the manufacturers to the Gov." and nor should you. Paragraph 152 refers to the _absence_ of written evidence of a statement by the baby food manufacturers. You should not find it difficult to perceive the difference between what paragraph 152 actually says and what you say it says.
I have no first-hand knowledge of what was contained in babyfoods on sale in the UK at that time, and neither do you; but from my much earlier first-hand experience of babyfood manufacture, and Rachel's first-hand experience too, I regard it prima facie as most unlikely that SBOs were ever used in babyfoods.
Nor do I personally (or you) have any knowledge of _why_ there was "no evidence of written assurances from the manufacturers supplied to either Maff or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus".
Fortunately, in answer to my requests for her comments on your previous posts, I have now received two e-mail messages from Heather Paine which give clear answers on these matters, and which I regard as setting the record straight,.
Dear Ralph
Further to our telephone conversation yesterday here is a brief summary of my discussion with the journalist John Radowitz re BSE and babyfoods.
The journalist was mainly interested in MRM and asked me if the baby food industry used MRM to 'bulk out' baby foods!
I said no and that to my knowledge the UK baby food industry had never used MRM. I also told him that when the SBO offal ban came into being this had no effect on baby food industry practice because we didn't use these materials either.
Commercial baby food manufacturers work to very strict specifications and only use ingredients that meet their tough specifications. Mothers expect baby food manufacturers to use the best cuts of meat and so the meat used is similar to that used in preparing baby foods at home. Baby food manufacturers, therefore, do not use MRM from the carcases of cattle, sheep (lamb) or pig.
I also questioned his assumption that at one year old the child would have been fed only commercial baby foods. At that age it was just as likely that the child would be eating home made foods/family meals.
Hope this helps
Heather
Dear Ralph
Just read your latest e-mail. Nice to see the apology which I accept, but I do not accept his accusations that we are still guilty.
Just because MAFF have no written assurance about SBOs not being used in baby foods doesn't mean that we used these materials. In fact, MAFF were fully aware in 1989 that the baby food industry did not use SBOs. The trouble was that there is no written record.
When the Southwood Report was being put together, MAFF contacted IDFA at quite a late stage (and it was me in those days) to ask whether the baby food industry used these materials. We said 'no' (both IDFA and individual companies were contacted) but it was all by telephone, (MAFF wanted a quick response so they could advise the Southwood Committee) - so unfortunately there is nothing on record (at least IDFA records)! - Except, after the Southwood Report was published IDFA complained to the then Minister about their handling of the issue which implied a change in baby food industry practice.
Of course when the consultation on the Regulations took place IDFA did not comment as we did not use SBOs and so we had no objections. Again no written record! But the fact is UK baby food manufacturers did not use these materials in their products.
The moral of the story is of course always place your comments on record - even when you have 'no objections'. Hindsight is a wonderful thing!
All the best
Heather
Regards Ralph
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J Ralph Blanchfield MBE Food Science, Food Technology & Food Law Consultant Chair, IFST External Affairs Web Editor, Institute of Food Science & Technology IFST Web addresse-mail: ICQ# 6254687. ICQ Web page
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Subject: Baby Food * June 23, 1999 BSE Inquiry
From: "Terry S. Singeltary Sr."Reply-To: Bovine Spongiform Encephalopathy
Date: Tue, 30 Nov 1999 11:16:54 -0600 Content-Type: text/plain Parts/Attachments: text/plain (125 lines)
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Terry S. Singeltary Sr., Bacliff, Texas USA
> Greetings everyone, I thought these comments were interesting. Thought
> some of you might find some interest in them...
>
> 2 MR LAWRENCE: Yes.
> 3 MR WALKER: I think you thank Mr Cockbill later for help on
> 4 the idiosyncracies of the meat products regulations. Is
> 5 that what he helped on?
> 6 MR LAWRENCE: I think that is right. But I think in
> 7 conjunction with what I was being asked to do, I think
> 8 Charles Cockbill was considering, am I right, the
> 9 possible regulations in relation to baby food?
> 10 MR WALKER: Yes.
> 11 MR LAWRENCE: So he was also making an assessment of those
> 12 tissues which might contain infective agent for that
> 13 piece of legislation.
> 14 MR WALKER: Yes. He was head of Food Standards Division,
> 15 reporting to Mrs Attridge.
> 16 MR LAWRENCE: Yes.
> 17 MR WALKER: And I think we have seen documents which
> 18 suggest he was in correspondence with Dr Pickles at the
> 19 Department of Health in relation to the baby food
> 20 regulations.
> 21 MR LAWRENCE: I think I have seen some of those, yes.
> 22 MR WALKER: Can you recall whether he was helping you on
> 23 the tissues, then, that might be infective?
> 24 MR LAWRENCE: It may well be. I cannot quite recall.
> 25 I mean there were a lot of documents at the time. But
> 1 obviously I gleaned information from various different
> 2 sources because, you know, I did produce a draft,
> 3 I think of 27th April. So whether I took on board some
> 4 of the information that I had seen from Charles or not,
> 5 I do not know. It may well have been, yes.
> _______________________________________________________
>
> 15 Could you just help us on the manuscript that we
> 16 see here? Is this from Mr Meldrum to you dated 14th
> 17 May?
> 18 MR LAWRENCE: Yes, I think that is.
> 19 MR WALKER: And he said:
> 20 "Thank you for a chance to comment. I think there
> 21 is some danger of Don fusing the proposed legislation on
> 22 baby foods and a wider ban on brains, spinal cord et
> 23 cetera. I am a little uneasy about some of the
> 24 assumptions made because I am advised that some bovine
> 25 brains are used for human consumption."
>
> 1 Have I deciphered that correctly?
> 2 MR LAWRENCE: Yes, I think that is right.
> 3 MR WALKER: We see on the left, against that reference to
> 4 some bovine brains being used for human consumption:
> 5 "But not in meat products".
> 6 MR LAWRENCE: I think that is my writing.
>
> 4 MR WALKER: That is very helpful. Thank you very much.
> 5 That comment, is that something that, from your point of
> 6 view, you simply took at face value?
> 7 MR LAWRENCE: Well, yes. I mean, as a non-scientist I was
> 8 really relying on their expertise to advise me, you
> 9 know, in what I should be putting up to the Minister in
> 10 the way of advice, yes.
> 11 MR WALKER: Did you see it as your role to seek to identify
> 12 what the level was in animals suffering from the disease
> 13 and how much lower the level was in these sub-clinically
> 14 infected animals?
> 15 MR LAWRENCE: No.
> 16 MR WALKER: From your point of view, that was a matter for
> 17 the expert advisers?
> 18 MR LAWRENCE: Yes. I mean, I think I have said in perhaps
> 19 a rather simplistic way I simply wanted to know from
> 20 these blokes which tissues they felt should be banned
> 21 from human consumption. And it did not concern me, you
> 22 know, about titre levels or anything else. It was
> 23 really yes or no.
> 24 MR WALKER: Yes, thank you.
> _____________________________________________________
>
> 1 MR WALKER: Why was it you were saying to UKASTA that the
> 2 SBO ban was simply to maintain public confidence?
> 3 MR LAWRENCE: Well, can I again read out what I intend to
> 4 say in...
> 5 MR WALKER: Yes.
> 6 MR LAWRENCE: I am saying in response to what you are
> 7 asking me I think the answer to that is that it was. As
> 8 I have already stated, the risks from BSE were regarded
> 9 as remote so the SBO ban was a measure of additional
> 10 reassurance against that remote risk. The determination
> 11 of which tissues to proscribe was a scientific
> 12 assessment based on the scrapie analogy of those offals
> 13 which might contain the agent in cattle with
> 14 pre-clinical disease.
> 15 My minute, again, may be a bit of shorthand
> 16 because I wanted to refer, and I will do when I send the
> 17 supplementary note, to another document I sent out on
> 18 that very same day; and that was the consultation letter
> 19 in relation to the proposed SBO ban, which is reference
> 20 YB 89/7.26/1.1.
> 21 In that what I am saying, in the letter, amongst
> 22 other things, is that scientific advice, including that
> 23 reflected in Southwood Report, is that in clinically
> 24 diseased animals and those which may be incubating the
> 25 disease, the BSE agent might be present in the brain,
> lawrence
>
> 1 spinal cord, spleen, thymus, tonsils and intestines.
> 2 The Southwood Working Party suggested, merely as a
> 3 precautionary measure, that manufacturers of baby food
> 4 should refrain from using certain offals in their
> 5 products.
> 6 In all the circumstances, Ministers have decided
> 7 that the most effective way of ensuring the protection
> 8 of public health would be to make regulations under the
> 9 Food Act 1984, those regulations being the SBO ban.
> 10 So, yes, you know, my minute in the way it is
> 11 worded -- sorry, the minute you are referring to, yes,
> 12 does look as if it was simply maintaining public
> 13 confidence. But I think in the letter I sent the same
> 14 day, the consultation letter, I am explaining it in more
> 15 detail, you know, the reasoning behind it that there was
> 16 a scientific reason for going a bit further..................
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Subject: Southwood Working Party advice on baby food. >witness statement 184e - Meldrum issued 10/14/99
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Tue, 30 Nov 1999 12:32:34 -0600 Content-Type: text/plain Parts/Attachments: text/plain (872 lines)
######### Bovine Spongiform Encephalopathy#########
Terry S. Singeltary SR., Bacliff, Texas USA
For those of you interested, the following report, helps us look at the big picture, about baby foods. Although you should remember, they were still implying
(or hoping), that BSE could not be transmitted to humans. Unfortunately, they found out different...
___________________________________________________________
Southwood Working Party advice on baby food
5.In my oral evidence (T69, Vol. T7, Tab 9, page 74 to 75) I stated that it was normal practice when an expert working party reported for the recommendations to be accepted as they stood. As regards the Southwood Report, I went on to say that it was not until later when I and my colleagues came to think through the advice on baby food that it became clear that it appeared to lack some logic, "that if particular tissues should be removed from baby food, why should not those same tissues be removed from the food of adolescents or pregnant mothers or adult people? Where do you draw the line? So it was a gradual thinking process in part accelerated by the request from Sir Donald Thompson that he put in about the same time when he asked us to consider the possibility of removing from the human food chain adult cows and adult ewes at the end of their life….".
6.At first sight the advice that baby food manufacturers should avoid the use of ruminant offal and thymus did make sense; (a) the Southwood Working Party had concluded that the risk of transmission of BSE to humans was remote, (b) it was accepted at the time that the young were more susceptible to the TSEs, (c) nevertheless steps had already been taken to ensure that clinically affected cattle should not enter the human food chain, (d) but if the BSE agent were to be present in an animal it was most likely to be in the spleen and lymphatic tissues in the early stages of infection, and in brain and neural tissue as the disease progressed, (e) accordingly consideration had been given to the risks from products containing tissues from sub-clinically infected cattle, and (f) it was believed that the risks as perceived at that time did not justify action beyond that advised for baby food manufacturers. When further pressed on the matter in oral evidence, I reiterated that at the time the Southwood Report was submitted and considered by Ministers, I was quite content with the recommendations as they stood. It was not until shortly thereafter, and arising from discussions with colleagues and representatives from outside organisations, that there appeared to be a certain element of illogicality in the advice (T69, Vol. T7, Tab 9, page 76 to 77), i.e. how do you define a baby, do you draw the line at toddlers and what about adolescents. My view that consideration of the advice for baby food manufacturers was a gradual process is supported by Sir Derek Andrews' oral evidence (T81, Vol. T9, Tab 1, page 117, line 21 to page 118, line 23).
7.It follows that since it was a gradual thinking process, so too the advice to Ministers developed gradually. This advice might not have been formulated to expressly state that the recommendation "made no sense", but rather that certain aspects of it required clarification before steps could be taken to implement it. Also, whilst such advice may have been gradual, Ministers nevertheless did receive advice on (i) the definition of offals as used in the Southwood Report advice on baby food, (ii) whether the definition included liver and kidney, and (iii) why one should distinguish between babies and older humans. Even if it was not me personally who put forward the advice, it was put forward by other MAFF officials and I was aware that the issues were being discussed and Ministers kept informed by virtue of the fact that I was a copy recipient of numerous minutes. If I had felt that I needed to put forward additional separate advice to express my view as CVO I would have done so, as indeed I did later in relation to the draft regulations on baby food (see the section below on "Development of the SBO ban"). Ministers themselves took a very keen interest in BSE and the Southwood Report, asked many questions and put forward their views themselves on the options open to MAFF. They were therefore intimately involved with discussions on the development of the Government’s policy on the disease.
8.Turning to point (i) in paragraph 7 above, the Southwood Report did identify the offals in question, albeit indirectly, and also explained why such offals and thymus caused concern. Paragraph 5.3.5 of the Southwood Report referred to the generic term "offal" and cross-referred by a footnote to those regulations from which the definition of that term had been taken. When asked subsequently (see sub-paragraph 9(a) below), Sir Richard Southwood confirmed that the intention was that the reference was to mean offal as described in the regulations identified within that paragraph of the Southwood Report. As regards the reasons why such offals and thymus should cause concern, this follows from the statement earlier in paragraph 5.3.5 of the Southwood Report (IBD 2, Vol. IBD 1, Tab 2) that if the BSE agent were to be present in an animal it would most likely be in the spleen, lymphatic tissues, brain and neural tissue. Whether or not it was realised at that stage what the specific definition of offals was intended to be, it would be clear that if those were the tissues where the BSE agent might be found, then "offal" (even if defined as just brain and spleen) could be a concern. Similarly, if lymphatic tissue might harbour the agent, then thymus, which is part of the lympho-reticular system, could be a concern.
9.In any event, the definition of offals used in the Southwood Report was clarified in the course of consideration of the advice to baby food manufacturers. As the events set out below show, Ministers were aware of and were advised on this process of clarification, and particularly whether liver and kidney were included in the Southwood Report definition. Some of the key events are as follows: a.13th February, 1989. In Mr Lawrence's minute and brief for Ministers and the Permanent Secretary (copied to me) it was stated in relation to the advice on baby food that thymus was not used in baby foods but on the other hand kidneys and liver, but no other offals were. Manufacturers' agreement would be sought to using non-ruminant liver and kidney as a replacement in baby foods (YB89/2.13/4.1-4.15).
b.15th February, 1989. In a minute to Mr Cruickshank (copied to me), Mrs Attridge pointed out that liver and kidney were the major element of offal likely to be found in baby foods and constituted an important part of a baby's diet. Mrs Attridge said there could be a risk of malnutrition if the rather vague recommendation in the Southwood Report led to the removal of cow and sheep liver from baby food. She suggested referring the matter to the CMO so that further investigations could be made on the risks involved (YB89/2.15/2.1-2.2).
c.20th February, 1989. In a minute to Mr Cruickshank (copied to me), Mrs Attridge raised concerns over parts of the submission and question and answer brief for the Southwood Report that related to baby food. She said that definitive answers were needed so that MAFF would not be accused of spreading uncertainty over products which actually had very considerable nutritional advantages for all sectors of the population (YB89/2.20/1.1).
As well as being copied to me, Mrs Attridge's minute dated 15th ebruary, 1989 (YB89/2.15/2.1-2.2) was copied to the Minister (Mr MacGregor) and the minute dated 20th February, 1989 (YB89/2.20/1.1) was copied to Private Offices (i.e. Ministers and the Permanent Secretary). As such, Ministers received information and advice on the need to clarify the definition of offals used in the outhwood Report.
d.21st February, 1989. In a minute to Mrs Stagg (PS/Minister) (copied to me), Mr Cruickshank stated that the reference to the baby food advice in the paper for MISC138 had been amended to reflect Mrs Attridge's suggestion. The paper stated that the Southwood Working Party had not examined all the scientific evidence relating to offal, particularly liver and kidney in baby food, and the CMO would therefore consider this further and advise on any action required (YB89/2.21/2.1-2.19).
It should be noted that the wording in the paper reflected that suggested by Mrs Attridge as a way of enabling MAFF to assess the risks of any ban on liver and kidney without causing too many presentational difficulties. This minute was copied to Private Offices.
e.23rd February, 1989. A minute from Mr Garnett to Mrs Stagg (PS/Minister) (further copied to me by the original copy recipient Mr Cruickshank) recorded the CMO's clarification with Sir Richard Southwood of what was meant by the reference to "ruminant offal and thymus" in the Southwood Report. Mr Garnett explained that it was intended that the reference would be to offal as described in the Meat Products and Spreadable Fish Products Regulations 1984 (L11 Tab 6). This meant that liver, kidney and heart which might otherwise be regarded as "offal" would not be restricted by the Southwood Working Party's advice. The CMO's advice, cleared with Sir Richard Southwood, would be that they need not be concerned at the inclusion in infant diets of kidney, liver and heart (YB89/2.23/7.1-7.2).
The CMO had passed this information on to the Minister Mr MacGregor) at a meeting on 23rd February, 1989 which was also attended by the Secretary of State for Health. I did not attend this meeting but did receive a copy of the note of the meeting (YB89/2.23/3.1-3.3). As such I was aware of Mr MacGregor's iscussions with the Department of Health on this issue. The note of the meeting records that after the CMO explained the confirmation received from Sir Richard Southwood as to the definition of offals, it was felt appropriate for the Government to take legislative steps to implement the advice on baby foods. If the Minister had felt that he was not clear on the Southwood Working Party's advice or had not received sufficient advice on the issue, I am of the view that he would not have come to the judgement to proceed with legislation.
10.Turning to point (ii) in paragraph 7 above, Mr Garnett's minute of 23rd February, 1989 (YB89/2.23/7.1) indicates that the Southwood Working Party had never intended the reference to offal to include liver and kidney, but rather it had been part of their deliberations prior to submitting the Southwood Report to Ministers that the offals they were concerned about were those described in the Meat Products and Spreadable Fish Products Regulations 1984 (L11 Tab 6) (see also the oral evidence of the Southwood Working Party; T 106, Vol. T11, Tab 6, pages 101 and 102). The question as to whether this was a correct conclusion for the Southwood Working Party to make is, more properly, an issue on which the members of the Southwood Working Party might care to comment rather than me. In addition, the question of the risks to babies from liver and kidney was quite properly identified as a matter for the CMO to follow up with Sir Richard Southwood. I was aware from the minutes and meeting notes (YB89/2.23/3.1-3.3) that were copied to him that this was how it was being pursued, with the full knowledge of the Minister (Mr MacGregor).
11.Finally, turning to point (iii) in paragraph 7 above, whilst it is correct to say that the Southwood Report did not appear to give any explanation why a distinction could be drawn between babies and other groups of people, the contemporaneous documents demonstrate that the reasons for this were known and explained to Ministers. In addition I was aware at the time of the thinking on the susceptibility of the young to which I have already referred in paragraph 6 above (see point (b)). For example:
(a) 24th February, 1989. The Q&A brief circulated to the Prime Minister's office, the Cabinet Secretary and members of MISC 138 included a question n why there should be concern about offal in baby food and not food for adults. The answer was that young animals were more susceptible than adults to orally acquired SEs (YB89/2.24/10.1-10.13).
The version of the Q&A brief circulated to the Minister and Private Offices on 21st February, 1989 (see paragraph 9(d) above) also included this nformation.
(b) 3rd April, 1989. At a meeting between the Parliamentary Secretary and Compassion in World Farming, Mr Lowson referred to the possibility that oung 'animals' might be more susceptible than older ones (YB89/4.05/1.1-1.3).
This view was also expressed by Dr Pickles in a letter to Mr Cockbill (YB89/4.13/2.1-2.3), although I was not involved in Mr Cockbill's discussions with the Department of Health relating to the drafting of the baby food regulations.
Development of the SBO ban
12.As I explained in my oral evidence and as referred to in the sections above on "Assessment of the Southwood Report" and "Southwood Working Party advice on baby food", it was a "gradual thinking process" that led to the decision being made by Mr MacGregor in June 1989 that wider action was needed on offals to meet concerns about some tissues from sub-clinically infected animals and the possibility that cattle affected with BSE were "getting through the net to the market" (YB89/6.7/7.1-7.2). Events preceding the meeting with Mr MacGregor on 6th June, 1989 should be seen as development of the thinking by a number of people on the need to take wider action than that advised by the Southwood Working Party on baby food and earlier agreed by Ministers.
13.Mr Thompson requested advice on 21st March, 1989 as to whether MAFF should consider requiring that cull cows be excluded from human consumption as a precautionary measure as such animals could be culled before they started to display clinical symptoms of BSE (YB89/3.21/5.1). This was one of the factors contributing to the "gradual thinking process". In oral evidence, I referred to this as having in part "accelerated" that process (T69, Vol. T7, Tab 9, page 75). Mr MacGregor's thinking appears in his manuscript note dated 26th February, 1989 querying, amongst other things, whether MAFF should be taking further action on offal in new product preparations and that given that animals are slaughtered the moment they show signs of BSE, whether there were any risks from animals just before that stage (YB89/02.24/14.1). It is not clear whether that note was passed to any particular MAFF official or whether it was for Mr MacGregor's use only. I cannot recall seeing this note. However, my minute of 5th April, 1989 to Mr Lawrence (YB89/04.05/2.1) indicates that he was aware that both Mr MacGregor and Mr Thompson were concerned about the human health implications of consumption of high risk material derived from both cattle and sheep. In that minute I noted that Mr Thompson had asked about the disposal of cull ruminants and the Permanent Secretary (Mr Andrews) was speaking to Mr MacGregor about the use of brain and spinal cord in meat preparations and that a meeting might be called if Mr MacGregor so wished. There was no suggestion by this minute that either Mr Thompson or Mr MacGregor had made a specific proposal for action on sub-clinical cases. At that stage, these were concerns in respect of which advice was requested and provided.
14.In any event, my previous minute to Mr Lawrence dated 30th March, 1989 (YB89/3.30/2.1) appears to indicate that Mr Andrews' concerns stemmed from the adverse publicity being received on the use of brains, etc. in human food generally rather than specifically in relation to risks to human health from BSE, or more particularly from sub-clinically infected cattle (YB89/3.30/2.1). When Mr Thompson told me that the concerns he had expressed about cull cows actually related to the remote risk associated with the consumption of brain and spinal cord derived from cows, bulls, ewes and rams at the end of their working life, this served to clarify the detailed issue on which he required advice (YB89/4.10/2.1). Following consultation with the CVL, advice was put forward by Mr Lawrence on 22nd May, 1989 (YB89/5.22/1.1-1.4). So far as I can recall, prior to May 1989 no other events took place that could amount to a proposal from either Mr Thompson or Mr MacGregor, or indeed any other source, for "action on sub-clinical cases".
15.My minute of 26th May, 1989 (YB89/5.26/5.1-5.2) was put forward to Mr MacGregor after discussion with Mr Andrews, so that I could express my own views in a note to go to Mr MacGregor in parallel with the submission which Mr Andrews would be putting forward. That submission had been prepared by Mr Cockbill (YB89/5.26/4.1-4.12) to seek Ministers' approval for proceeding to public consultation on the draft regulations prohibiting the use of certain specified offals in baby food. As the note had to go from me in parallel with Mr Andrews' submission which was going forward on 26th May, 1989 (YB89/5.26/5.1-5.2), the minute (YB89/5.26/5.1-5.2) was prepared hurriedly and I recognise that the wording of that minute is not as clear as I feel it could have been if I had had more time to draft it. However, any imperfections would have been ironed out at the later meetings with Ministers.
16.As noted in Mr Cockbill's minute to Mr Ryder on the draft regulations, and in paragraph 4 of the submission itself, the list of prohibited offal in the draft regulations had been made wider than the limited list in the Southwood Report for "ease of enforcement and for the sake of consistency with other regulations made under the Food Act" (YB89/5.23/4.6). The draft regulations thus included offal from all mammalian species and covered a number of tissues which, although not likely to be significant in BSE terms, were equally not used in baby foods. This is the context in which the sentence in my minute of 26th May, 1989 (YB89/5.26/5.1-5.2) which reads, "I am becoming increasingly concerned that Ministers are being forced to consider a ban on the use for human consumption of certain offals, such as brain, spinal cord and spleens, derived from both cattle and sheep, even though there is no scientific evidence to support such action", should be read. It should also be noted that the reference to evidence in this part of the minute refers to cattle and sheep and not to one species alone; this is important in the context of later comments in the minute where reference is made to the scientific findings of Professor Hadlow and others. Mr Cockbill's minute to Mr Ryder (YB89/5.5/9.1-9.2) (copied to Mr MacGregor and Mr Andrews) had also noted that the proposals for the regulations as to baby food might stimulate suggestions that the ban should be extended to all meat products. My concerns expressed in his minute related to a large extent to the possibility that the proposals in Mr Cockbill's submission (YB89/5.26/4.1-4.12) might lead to pressure on MAFF to take action on sheep offals when scrapie had been in the UK and other countries for around 250 years without any scientific evidence of it being a human hazard. In addition, the control of scrapie in sheep and goats would have been a virtually impossible task at that time. This point had been made by me in a minute dated 30th March, 1989 to Mr Lawrence (YB89/3.30/2.1). Paragraph 5 of my minute dated 26th May, 1989 (YB89/5.26/5.1) further clarifies where my concerns lay and what action I did support; "it could be argued that the brain, spinal cord and spleen of adult cattle should be removed from the human food chain for the reasons expressed above but to go further and extend this to sheep would reopen the whole of the scrapie issue and would signal that we were concerned about the human health aspects of that disease".
17.My minute of 26th May, 1989 (YB89/5.26/5.1-5.2) went on to note that the argument for prohibiting the use of offals such as brain, spinal cord and spleens derived from adult cattle was more persuasive as we were dealing with a new condition in cattle and could not be certain that the agent could not jump yet another species barrier and affect man. This is clearly an indication of my support for a policy of destruction of potentially infective tissues in the event that Ministers felt that such action was necessary. In my minute, I specifically pointed out that on occasions the BSE agent would be present in the brain of apparently healthy cattle that were in the incubative stage and the BSE agent was also likely to be present on occasion in other materials such as spleen, lymph glands and nerves. This is information that I discussed at the meeting with Dr Kimberlin on 16th May, 1989 (YB89/5.18/5.1; YB89/5.16/1.1-1.3; paragraph 7 of section F of WS 184A).
18.Having received the information I did as a result of the meeting with Dr Kimberlin and Pedigree Petfoods, it is difficult to see how I either could or would oppose or fail to support a policy of destruction of potentially infective material in the event that Ministers decided to pursue such a policy. Once the decision to go further than the Southwood Working Party had advised had been taken, Dr Kimberlin's knowledge was applied to determine what tissues could sensibly be included in any ban. I knew from Dr Kimberlin that it was possible to extrapolate from Professor Hadlow's work in sheep. This was not new scientific evidence, but Dr Kimberlin’s assessment of the risk was new so far as I was concerned. It should also be noted that this was not scientific evidence on the BSE agent, rather it was a scientific comparison based on published data on the distribution of the scrapie agent in clinically affected sheep. In my oral evidence (T69, Vol. T7, Tab 9, pages 87 to 88), I explained that it was clear to me that Dr Kimberlin thought it was a "good idea" to keep those offals with the highest infectivity load out of the human food chain. It is important to note that I used the words "good idea" and that I did not say that such action on offals was either necessary or warranted at that time. A different distinction was made at a later date in the light of further assessments and knowledge.
19.In any event, the issue was discussed in detail with Ministers. In my minute of 26th May (YB89/5.26/5.1-5.2), I advised that Ministers should consult with Sir Richard Southwood, and asked for a meeting with Ministers himself to discuss the issues. The meeting between Mr MacGregor, MAFF officials and Dr Metters took place on 6th June, 1989 (YB89/6.7/7.1-7.2) and the meeting with Sir Richard Southwood took place on 7th June, 1989 (YB89/6.8/4.1-4.2).
20.Finally, I wish to comment on my recollection of the meeting on 16th May, 1989 with Dr Kimberlin. I described this in my previous statement (WS 184A, section F, paragraph 7). At the time I was preparing my previous statement (WS 184A) the only documents which I had available to me were my own handwritten notes of the meeting. Since then a number of additional documents have been found by the MAFF Liaison Unit which are relevant to the meeting. Whilst confirming that the meeting with Dr Kimberlin was on a confidential basis, these documents indicate that it was also attended by Mrs Owen, Mr Garnett and Dr Woolfe. I believe that there were two meetings. The first was attended by MAFF officials, Pedigree Petfoods and Dr Kimberlin (YB89/5.18/5.1) and the second was a more open meeting between Dr Kimberlin and myself. It was at that later meeting that Dr Kimberlin gave me a copy of the Pedigree Petfoods papers, in confidence. As regards the point of clarification over the number of documents which I received from Dr Kimberlin at the meeting, I can confirm that I received the five documents dated 2nd September, 1988 (M49 Tab 6)), January 1989 (M49 Tab 6A), February 1989 (two documents(M69 Tab 6B and 6C) and March 1989 (M69 Tab 6D). I did not recognise the earlier reference to five documents since my set of five documents are bound together as two separate documents.
Approach taken to the Southwood Working Party advice
21.I have been asked to consider whether the approach to be taken to advice from the Southwood Working Party should have been as follows:
"(1) where the Working Party had expressed their view on a scientific question (e.g. whether there was a risk that tissues from sub-clinically infected animals could be infective to humans if eaten or accidentally inoculated, and the best estimate of the extent of that risk in scientific terms) Ministers should not depart from this unless they had scientific advice to cast doubt about it;
(2) where such a body had made a value judgement as to whether any articular risk merited the taking of any particular steps it was for government to assess the costs and benefits of those steps in the light of scientific advice.
22.It is very difficult to draw such a clear cut distinction as between an advisory committee's view on a scientific question and a value judgment as to the merit of taking any particular steps, such a value judgment having been made as a result of a view taken on a scientific issue. To a certain extent it is agreed that an advisory committee's view on a scientific question could and should not be challenged except with further scientific data (see paragraphs 1 to 6 on the section above on "Relationship with the Southwood Working Party" which set out views on the Southwood Working Party and the approach to advisory committees in general; see also paragraph 18 of the section above on "Assessment of the Southwood Report".)
23.Taking, as an example, the Southwood Working Party's view on the scientific question as to the risks to human health from tissues from sub-clinically infected cattle, and their value judgment as to whether those risks as perceived at that time merited particular steps, be it labelling or advice to baby food manufacturers, I did not advise Ministers that they should not depart from or go further than the Southwood Working Party's advice that baby food manufacturers should avoid using ruminant offals and thymus. As explained in the section above on "Development of the SBO ban", my minute of 26th May, 1989 (YB89/5.26/5.1-5.2) did not amount to advice that Ministers should not go further than the Southwood Working Party's value judgment that the risks as perceived did not justify requiring the labelling of food products containing brain and spleen. If I had advised Ministers not to depart from this value judgment, then there may never have been an SBO ban. It was the assessment of the steps suggested by the Southwood Working Party that led to the development of the thinking behind the SBO ban.
24.In the context of this section, I have also been asked to consider the following matters: a.Southwood Report "unnatural practices" recommendation.
I was questioned on the issue of the Southwood Working Party's proposed "unnatural practices" recommendation in my oral evidence. I was asked whether it was my own view that, as stated by Mr Suich in a minute of 10th January, 1989 (YB89/1.10/2.1-2.2) to the Permanent Secretary, "such a controversial recommendation went wider than the Southwood Committee's remit". My answer was: "It would have been the general view at the time, whilst on the other hand accepting that if Government and Ministers decide to appoint an expert working party, it is most unhelpful to then fetter them in the ecommendations that they can make. Therefore this was simply and solely an issue of reporting that this consideration was taking place and to make sure that the Permanent Secretary … was in fact alerted to it" (T69, Vol. T7, Tab 9, page 72). In this respect, I would also comment that there were spurious suggestions in the press at the time that MAFF had influenced and altered the Southwood Report and that the final wording had been cleared with MAFF. As the contemporaneous documents show, this was not the case. Indeed, as far as I can recall, I was never formally consulted on the draft Southwood Report in the way that it appears to have been suggested that I would be (YB89/1.17/9.1). I believe it was quite proper that I should not be invited to comment in this way. When the Permanent Secretary (Mr Andrews) suggested to Sir Richard Southwood that I should attend the final meeting of the Southwood Working Party to discuss rendering practices, this was turned down by Sir Richard Southwood, who made it clear that my input was not equired (YB89/1.31/1.1-1.8; YB89/2.2/2.1). In any event, at the time it was recognised that the Southwood Working Party seemed intent on including the recommendation on "unnatural practices" in its final report. However, it was felt that a paper rom MAFF making the Southwood Working Party aware of what the rendering industry did and its scale of activity, would at least leave room for the Government to examine a number of options apart from a prohibition on the use of recycled animal waste in animal feed (YB89/1.10/2.1-2.2).
b.Southwood Report advice for baby food manufacturers.
It was accepted that the wording of the advice for baby food manufacturers was less than precise and some clarification was subsequently required, but the drafting of the Southwood Report was a matter for the Southwood Working Party and them alone. This has been discussed in more detail in the section above on "Southwood Working Party advice on baby food"
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*** BABY FOODS 2001
Subject: FSA ADMITS ERROR OVER BABY FOOD - BABY FOODS AND MAD COW DISEASE back on table...
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Sat, 20 Oct 2001 10:19:30 -0700 Content-Type: text/plain Parts/Attachments: text/plain (203 lines)
######## Bovine Spongiform Encephalopathy#########
Saturday, 20 October, 2001, 02:24 GMT 03:24 UK
FSA admits error over baby food
Many parents remain concerned over baby food ingredients The Food Standards Agency has admitted its chairman wrongly asserted that British sheep were not used in baby food production.
Sir John Krebs said lamb from the UK was not being used in baby food.
He suggested there was a voluntary agreement by the food industry to use lamb only from countries like New Zealand.
Sir John hoped the assertion would be reassuring for those who feared sheep might harbour BSE.
But a spokesman for the baby food industry, Heather Payne, told the BBC manufacturers are still using British lamb.
"The lamb that baby food manufacturers use comes from a number of different sources. But it includes the UK, New Zealand, France and Germany.
"We had a meeting earlier this year with the Food Standards Agency and we explained all our procedures and all our operations to them.
"They advised us there was no need to change our source of lamb."
Lethal illness
There have been fears that BSE could be present in the national flock, sparking fears of a mass slaughter.
BSE-infected meat is widely believed to be the source of the lethal vCJD illness in humans
The FSA said in August that there was a "theoretical risk" BSE was in sheep, but stressed it was not asking people to stop eating lambs.
There have previously been concerns, fiercely denied by the baby food industry, that mechanically-recovered meat from heavily infected areas of cattle could have been used in the 1980s.
The FSA has joined in the chorus of criticism after it was revealed on Friday that scientists investigating whether BSE was in sheep had actually been examining the brains of cattle.
http://news.bbc.co.uk/hi/english/health/newsid_1609000/1609832.stm
Greetings list members,
we debated this issue in great length on Nov. 25, 1999. i even got a spanken from Ralph for being a bit rude for attacking Heather. But thought since the issue is back in the media and Heather is making comments again, some might be interested in the debate of 1999 on baby foods and BSE. no attack intended on Heather...
with kind regards, Terry S. Singeltary Sr., Bacliff, Texas USA
Re: Girl, 13, shows CJD symptoms. [re-baby food]
Date: Thu, 25 Nov 1999 22:30:36 +0000
J Ralph Blanchfield
snip...
It is easy with the 20/20 vision of hindsight to say now that certain animal derivatives should not have been used in baby foods (and indeed we do not know that they were, and Heather Paine is quoted as saying that to her knowledge they were not). Until the investigations of the Southwood Committee, there was anyway no reason to suppose that these materials, from apparently healthy cows, were other than wholesome or had any connection with BSE or indeed vCJD (the existence of which was at that point unknown). As it happens, the food manufacturer for which I worked in the early 1950s, among its many canned, bottled, frozen and dehydrated products, manufactured a range of baby foods including a beef broth, which was made from Argentinian frozen beef -- no offals of any kind.
But each manufacturer decided for itself what ingredients to use, and they were/are in no way controlled or "overseen" by a trade association, which is what the Infant and Dietetic Foods Association was/is. So Terry, your attack on Heather Paine was unwarranted and badly misconceived, and I think you owe her an apology.
I happen to know Heather well in an entirely different connection, and a more honest and conscientious person it would be hard to find.
snip...
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At 11:35 AM 11/24/99 -0600, Terry wrote:
Heather Paine should be educated on the products she over-sees. These children's health are at risk, and if she does not know what has and has not been going into baby-foods, she does not need to hold that position. The Inquiry was very concerned about baby foods, and at one point said something about;
It is very unlikely that baby food would contain SBO's, since baby food is the most highly regulated and safest of all commercial foods.
So, if baby food is suspected as a vehicle for BSE->ukCJD, then it would be base on its containing normal cuts of meat. Baby foods contain more liver than the general population eats, so perhaps there could be a correlation there.
Babies of all species have more porous intestinal membranes, so uptake of prions would be expected to be more efficient.
snip...
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99. Mr. Lawrence wrote a letter to Sir Richard on 6 January 1989 (110) explaining that there were _no_ special regulations with regard to the composition of baby food except in relation to additives, and that there was therefore _nothing_ in the rules that would exclude certain parts of animal being incorporated into baby foods as long as they were fit for human consumption.
152. There is _no_ evidence of written assurances from the manufacturers supplied to either MAFF or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus.
155. The reply also outlined the following actions already taken or to be taken by the Government in response to the Working Party's recommendations. 1) As a precautionary measure the Government would enact secondary legislation to ensure it was illegal to sell Baby Food containing brain, spinal cord, spleen and intestines.
165. On 23 May 1989 Mr. Cockbill prepared draft regulations prohibiting the use of certain _specified offals_ in Baby Foods...
snip...
========================================
for anyone interested and wanting to search data of this thread, search BSE-L archive NOVEMBER 1999. towards the bottom, #35.
kind regards, Terry S. Singeltary Sr., Bacliff, Texas USA
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Subject: Re: FSA ADMITS ERROR OVER BABY FOOD - BABY FOODS AND MAD COW DISEASE back on table...
From: J Ralph Blanchfield
Reply-To: Bovine Spongiform Encephalopathy
Date: Sat, 20 Oct 2001 19:15:48 +0100 Content-Type: text/plain Parts/Attachments: text/plain (249 lines)
######## Bovine Spongiform Encephalopathy#########
Hello Terry and Everyone,
The question of the sources of lamb used is of course a totally different issue from that of the past allegations about the use of MRM,, as Terry is very well aware, and he deserves another (and severe) spanking for intentionally misrepresenting the two issues as the same issue ("since the issue is back in the media").
Sir John had obviously been badly briefed when in an interview he said that no UK lamb was used in babyfood, when in fact FSA actually knew that it was one of the sources. Moreover, on advice published by FSA there was no reason why it should not have been one of the sources (actually UK lamb "of scrapie-free lineage").
As regards the "lamb brains" paste from the early 1990s that turned out to be cow brains paste, Terry has assumed his usual "conspiracy theory" explanation. Generally speaking, in real life sensible people examine the likelihood of cock-up before jumping to the conclusion of conspiracy I certainly think there was no excuse for the curious timing and obscure method of disclosure (the Jo Moore syndrome?), but as to the wrong material being tested for four years, I think that this was the major cock-up of all time. Fortunately, a separate investigation, at the Weybridge veterinary laboratories has been proceeding in parallel, on 163 scrapie-affected present-day sheep and so far no BSE has been found. And before Terry produces his usual condescending lecture and mantra about "absence of evidence is not evidence of absence", all of those with any sort of scientific background on this list were trained to understand that as a basic principle long before he entered this list and picked up the phrase.
Best wishes Ralph
******************************************************
Prof J Ralph Blanchfield, MBE Food Science, Food Technology and Food Law Consultant Chair, External Affairs, Institute of Food Science and Technology Webmaster / Editor, Institute of Food Science and Technology Vice President, European Food Law Association of the UK Chair, IFT Committee for Global Interests Past Chair, IFT British Section Adjunct Professor, Michigan State University IFST Web addressPersonal Web address
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Subject: Re: FSA ADMITS ERROR OVER BABY FOOD - BABY FOODS AND MAD COW DISEASE back on table...
From: Brian MATTHEWS
Reply-To: Bovine Spongiform Encephalopathy
Date: Mon, 22 Oct 2001 15:33:42 +0100 Content-Type: text/plain Parts/Attachments: text/plain (270 lines)
######## Bovine Spongiform Encephalopathy#########
Ralph,
Regarding the second part of the posting (sheep), would this be the same or a different study to that reported in the last week or so where the wrong animals' brains were examined.
Given the latest display of ineptitude on the part of UK scientists, what faith can be placed in the data?
Regards,
Brian Matthews lt09@dial.pipex.com
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Subject: Re: FSA ADMITS ERROR OVER BABY FOOD - BABY FOODS AND MAD COW DISEASE back on table...
From: J Ralph Blanchfield
Reply-To: Bovine Spongiform Encephalopathy
Date: Mon, 22 Oct 2001 19:00:08 +0100 Content-Type: text/plain Parts/Attachments: text/plain (311 lines)
######## Bovine Spongiform Encephalopathy#########
Hello Brian and Everyone,
I only have access to the same information that you do. I thought it was crystal-clear, and I think I reflected that in the second part of my posting, that there were two separate experiments, namely
1) the experiment at the Institute of Animal Health (the so-called Bostock experiment) supposedly on a paste of scrapie-infected sheep collected in 1990 for a different purpose along with brains from BSE-infected cattle. Because of fears of cross-contamination, DEFRA referred a sample of the sheep-brain paste for testing to the Laboratory of the Government Chemist which has now determined by DNA that the supposed ovine material was in fact wholly bovine. This is the experiment that I described as "the major cock-up of all time". But whose cock-up? Before rushing to blame the IAH scientists, I would want to know exactly what was the provenance of the material provided to them to test.
2) A totally separate experiment on a number (too-small, 163) of present-day scrapie infected sheep brains, carried out by Veterinary Laboratory Agency in Weybridge, which so far has produced no evidence of BSE.
Best wishes Ralph
******************************************************
Prof J Ralph Blanchfield, MBE Food Science, Food Technology and Food Law Consultant Chair, External Affairs, Institute of Food Science and Technology Webmaster / Editor, Institute of Food Science and Technology Vice President, European Food Law Association of the UK Adjunct Professor, Michigan State University IFST Web addressPersonal Web address
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Subject: Re: FSA ADMITS ERROR OVER BABY FOOD - BABY FOODS AND MAD COW DISEASE back on table...
From: Brian MATTHEWS
Reply-To: Bovine Spongiform Encephalopathy
Date: Mon, 22 Oct 2001 19:22:09 +0100 Content-Type: text/plain Parts/Attachments: text/plain (334 lines)
######## Bovine Spongiform Encephalopathy#########
Dear Ralph,
I seems at least possible that the mix up of brain material involved the former MAFF laboratories. This is currently under investigation, of course. Perhaps this information will also be published in a government press release at 22.30!
If the MAFF scientists were involved in the first cock-up, why should their information be seen to be any more reliable for the second experiment unless it is first vetted by independent scientists? After all, the same people did not all come out with glowing testimonials in the BSE Inquiry report.
Another aspect of the cock-up that concerns me is that the work was being undertaken in a laboratory that could not, according to all accounts I have seen, undertake a DNA test to confirm the source of the materials sent to them. It seems surprising that the work should continue for so long without such a basic test of veracity being applied.
Regards,
Brian Matthews lt09@dial.pipex.com
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===================== *** BABY FOOD 2005 *** =====================
===============: BSE 'may have entered baby food in 70s' ===================
LISTS.AEGEE.ORG ( BSE-L: 61 matches (only the first 50 will be shown).. )
Subject: Re: BSE 'may have entered baby food in 70s'
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Fri, 4 Mar 2005 17:09:14 -0600 Content-Type: text/plain Parts/Attachments: text/plain (956 lines)
##################### Bovine Spongiform Encephalopathy #####################
THE BABY FOOD (PROHIBITED OFFAL) REGULATIONS 1989
http://collections.europarchive.org/tna/20080102185118/http://www.bseinquiry.gov.uk/files/yb/1989/05/00002001.pdf
Bovine Spongiform Encephalopathy
BSE-L is a discussion forum for scientists who are interested in Bovine Spongiform Encephalopathy (BSE). BSE-L has been created on 20th July, 1994 by Siegfried Schmitt. Impressum: http://www.kaliv.de/impressum.html
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CJD and Baby foods (the great debate 1999)
Subject: Re: Girl, 13, shows CJD symptoms.
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Wed, 24 Nov 1999 11:35:44 -0600 Content-Type: text/plain Parts/Attachments: text/plain (67 lines)
######### Bovine Spongiform Encephalopathy
Heather Paine should be educated on the products she over-sees. These children's health are at risk, and if she does not know what has and has not been going into baby-foods, she does not need to hold that position. The Inquiry was very concerned about baby foods, and at one point said something about; they were no different than the SBO's, in some cases, depending on the ingredients, of that particular kind of baby food. I forget the exact quote and by whom it was said??? I have it somewhere, but my filing system has a lot, _not_ to be desired for..............
Debora MacKenzie wrote:
######### Bovine Spongiform Encephalopathy
GIRL, 13, SHOWS CJD SYMPTOMS November 23, 1999 PA News John von Radowitz, Medical Correspondent, PA News
A 13-year-old girl may, according to this story, be the youngest victim of the human form of mad cow disease. The girl, whose identity and whereabouts are being kept secret, is, the story adds, thought to be displaying symptoms of new variant Creutzfeldt Jakob Disease. The story says that if the case is confirmed it has major implications. It raises the question of whether the girl was infected by baby food, and may shed light on the disease's incubation period. The girl was less than a year old in 1986 when BSE, the cattle disease thought to manifest itself in humans as the new variant form of CJD, was formally identified. Three years later the Government banned parts of the cow most likely to be infected, such as the brain and spinal cord, from human food products. So far the youngest of the 48 people to have died from nvCJD has been 16. David Churchill, chairman of the support group the Human BSE Foundation, was cited as saying he was aware of the case, adding, "I can confirm that the story is true - the girl is showing symptoms of the disease. This case raises a whole new spectre. There's no way anyone can say this child picked up nvCJD prior to knowledge about BSE. Back in 1986 BSE was not only identified but becoming prevalent. It can only have been picked up after the emergence of BSE, and the likelihood is that it was through baby food. ...
The ability to diagnose this illness from its symptoms is improving with each case, and there are some fairly clear diagnostic guidelines now. The chances of a misdiagnosis, or missed diagnosis, are less likely than they used to be." Although the disease could only be confirmed for certain after death, the girl was showing signs and behaviour known to be linked with nvCJD. Heather Paine, spokeswoman for the Infant and Dietetic Foods Association, was cited as saying that as far as she knew no high-risk beef material, such as mechanically recovered meat stripped off the spine, had ever been used in baby products, adding, "To my knowledge no MRM from cattle has ever been put in baby food. Manufacturers are very aware of what mothers want to feed their babies." At one-year-old the girl would probably have been weaned off commercial baby food and eating home-prepared meals which may have included mince and beef cuts, said Ms Paine.
Debora MacKenzie, Europe correspondent, New Scientist. tel: +32-2-245-0412 fax: +32-2-245-0552 email: d.mackenzie@chello.be
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Subject: Re: Girl, 13, shows CJD symptoms. [re-baby food]
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Thu, 25 Nov 1999 11:21:52 -0600 Content-Type: text/plain Parts/Attachments: text/plain (66 lines)
######### Bovine Spongiform Encephalopathy
Hello Robert and All,
I would like to point out in DFA 9
99. Mr. Lawrence wrote a letter to Sir Richard on 6 January 1989 (110) explaining that there were _no_ special regulations with regard to the composition of baby food except in relation to additives, and that there was therefore _nothing_ in the rules that would exclude certain parts of animal being incorporated into baby foods as long as they were fit for human consumption.
152. There is _no_ evidence of written assurances from the manufacturers supplied to either MAFF or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus.
155. The reply also outlined the following actions already taken or to be taken by the Government in response to the Working Party's recommendations. 1) As a precautionary measure the Government would enact secondary legislation to ensure it was illegal to sell Baby Food containing brain, spinal cord, spleen and intestines.
165. On 23 May 1989 Mr. Cockbill prepared draft regulations prohibiting the use of certain _specified offals_ in Baby Foods...
Kind Regards, Terry S. Singeltary Sr., Bacliff, Texas USA
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Subject: Re: Girl, 13, shows CJD symptoms. [re-baby food]
From: J Ralph Blanchfield
Reply-To: Bovine Spongiform Encephalopathy
Date: Thu, 25 Nov 1999 22:30:36 +0000 Content-Type: text/plain Parts/Attachments: text/plain (168 lines)
######### Bovine Spongiform Encephalopathy
Hello Robert, Terry and Everyone,
On Thu, 25 Nov 1999 13:17:45 -0500, Robert LaBudde wrote:
######### Bovine Spongiform Encephalopathy
At 11:21 AM 11/25/99 -0600, Terry wrote: I would like to point out in DFA 9
99. Mr. Lawrence wrote a letter to Sir Richard on 6 January 1989 (110) explaining that there were _no_ special regulations with regard to the composition of baby food except in relation to additives, and that there was therefore _nothing_ in the rules that would exclude certain parts of animal being incorporated into baby foods as long as they were fit for human consumption.
152. There is _no_ evidence of written assurances from the manufacturers supplied to either MAFF or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus.
155. The reply also outlined the following actions already taken or to be taken by the Government in response to the Working Party's recommendations. 1) As a precautionary measure the Government would enact secondary legislation to ensure it was illegal to sell Baby Food containing brain, spinal cord, spleen and intestines.
165. On 23 May 1989 Mr. Cockbill prepared draft regulations prohibiting the use of certain _specified offals_ in Baby Foods...
Thanks for the relevant information, Terry.
I over-generalized based on US experience. There's a thick wad of FDA regulations concerning baby food in this country, and I made the mistake of presuming that this was a similar occurrence in Europe.
If the UK was really this cavalier about baby food, the regulations on 'normal' food must be very weak. It's still hard to believe this is really true.
Perhaps JRalph could help us out with an authoritative comment on this issue.
I'll do my best. You really are keeping me hard at work today here and elsewhere, aren't you, Robert?
_Specific_ Regulations relating to baby foods prohibit added colours, artificial sweeteners and some additives, limit pesticide residues and vitamin A content. There are no "recipe" Regulations affecting them.
Baby foods, and all other foods, are subject to the general provisions that are in the Food Safety Act 1990 and were in its predecessors all the way back to 1872.. Section 7 of the 1990 Act states:
7. Rendering food injurious to health
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
(1) Any person who renders any food injurious to health by means of any of the following operations, namely- (a) adding any article or substance to the food; (b) using any article or substance as an ingredient in the preparation of the food; (c) abstracting any constituent from the food; and (d) subjecting the food to any other process or treatment; with intent that it shall be sold for human consumption, shall be guilty of an offence. (2) In determining for the purposes of this section and section 8(2) below whether any food is injurious to health, regard shall be had- (a) not only to the probable effect of that food on the health of a person consuming it; but (b) also to the probable cumulative effect of food of substantially the same composition on the health of a person consuming it in ordinary quantities. (3) In this Part ‘injury’, in relation to health, includes any impairment, whether permanent or temporary, and ‘injurious to health’ shall be construed accordingly.
Section 8 contains two provisions -- 8(2)(b) and 8(2)(c) -- not in the predecessors of the 1990 Act:
8 Selling food not complying with food safety requirements
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
(1) Any person who-
(a) sells for human consumption, or offers, exposes or advertises for sale for such consumption, or has in his possession for the purpose of such sale or of preparation for such sale; or
(b) deposits with, or consigns to, any other person for the purpose of such sale or of preparation for such sale, any food which fails to comply with food safety requirements shall be guilty of an offence.
(2) For the purposes of this Part food fails to comply with food safety requirements if-
(a) it has been rendered injurious to health by means of any of the operations mentioned in section 7(1) above;
(b) it is unfit for human consumption; or
(c) it is so contaminated (whether by extraneous matter or otherwise) that it would not be reasonable to expect it to be used for human consumption in that state, and references to such requirements or to food complying with such requirements shall be construed accordingly.
(3) Where any food which fails to comply with food safety requirements is part of a batch, lot or consignment of food of the same class or description, it shall be presumed for the purposes of this section and section 9 below, until the contrary is proved, that all of the food in that batch, lot or consignment fails to comply with those requirements.
(4) For the purposes of this Part, any part of, or product derived wholly or partly from, an animal-
(a) which has been slaughtered in a knacker’s yard, or of which the carcase has been brought into a knacker’s yard; or
(b) in Scotland, which has been slaughtered otherwise than in a slaughterhouse, shall be deemed to be unfit for human consumption.
(5) In subsection
(4) above, in its application to Scotland, ‘animal’ means any description of cattle, sheep, goat, swine, horse, ass or mule; and paragraph (b) of that subsection shall not apply where accident, illness or emergency affecting the animal in question required it to be slaughtered as mentioned in that paragraph.
Baby foods, like all foods, are of course also subject to the extensive provisions of the Food Safety (General Food Hygiene) Regulations 1995 (and parallel Hygiene Regulations covering specific food sectors).
It is easy with the 20/20 vision of hindsight to say now that certain animal derivatives should not have been used in baby foods (and indeed we do not know that they were, and Heather Paine is quoted as saying that to her knowledge they were not). Until the investigations of the Southwood Committee, there was anyway no reason to suppose that these materials, from apparently healthy cows, were other than wholesome or had any connection with BSE or indeed vCJD (the existence of which was at that point unknown). As it happens, the food manufacturer for which I worked in the early 1950s, among its many canned, bottled, frozen and dehydrated products, manufactured a range of baby foods including a beef broth, which was made from Argentinian frozen beef -- no offals of any kind.
But each manufacturer decided for itself what ingredients to use, and they were/are in no way controlled or "overseen" by a trade association, which is what the Infant and Dietetic Foods Association was/is. So Terry, your attack on Heather Paine was unwarranted and badly misconceived, and I think you owe her an apology.
I happen to know Heather well in an entirely different connection, and a more honest and conscientious person it would be hard to find.
Finally, if it is vCJD, there is no more reason to suppose that the girl in question acquired the infection from baby food than from infected mince after weaning or from the infected vaccines that we now know were in use.
Regards Ralph
******************************************************************
J Ralph Blanchfield MBE Food Science, Food Technology & Food Law Consultant Chair, IFST External Affairs Web Editor, Institute of Food Science & Technology IFST Web address
******************************************************************
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Subject: Re: Girl, 13, shows CJD symptoms. [re-baby food]
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Fri, 26 Nov 1999 10:36:34 -0600 Content-Type: text/plain Parts/Attachments: text/plain (210 lines)
######### Bovine Spongiform Encephalopathy
Hello Ralph and All, I think you are correct Ralph, after reading back over my comments, I was a bit hasty, and in a friends eyes, may have even seemed rude. For that I would like to apologize to Heather and You. It still does not change my position on the matter. It would have been better directed, if I would have directed my haste, to the _whole_ industry involved, as opposed to Heather and the Baby Food industry. For obvious reasons, if the DFA's are accurate, and the statements within from the Working Party and the Gov. and the statement from the manufacturers of Baby Foods, where they are stating in DFA 9; "152. There is no evidence of written assurances from the manufacturers supplied to either Maff or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus". Then from past experiences from big industry, I would bet that the ingredients in question were used.
Not to change the subject, but if the people that oversee adult products for consumption, allows manufactures of pills in (nutritional supplements) in 1999, to put "brain, eyeballs, pituitary, and scrotum" in these pills, then pass them off as miracle cures from heaven that will cure everything from aids to the common cold. Then allow them to label it as "100% herbal". And then top it all off, instead of classifying them as pharmaceuticals, they classify them as _food_. If the people that oversees this, has anything to do with what goes in baby foods, after the manufactures comments, I just find it hard to believe, that this did not take place, and to some extent, still is. All this, going into the year 2000, and we are still debating if brain and or other sbo's should be going into the human food chain (and they still are), after knowing for many years about the highly infectivity of the brain, eye and other organs and or tissues. This I do not understand, and this is why I most hastily replied to Heather's comments. Hope this smoothes' things over Ralph.........
Kind Regards, Terry
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Subject: Re: Girl, 13, shows CJD symptoms. [re-baby food]
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Sat, 27 Nov 1999 18:54:39 -0600 Content-Type: text/plain Parts/Attachments: text/plain (397 lines)
######### Bovine Spongiform Encephalopathy
Thanks Ralph,
re-Heather<>
I have learned from the past, about TSE's and information. Being passive, or suttle, and or subdued, and simply saying o.k. to an answer, does not get it. You don't find out much that way. Although since being on this list, I have learned a great deal about being diplomatic, "I thought". Although I guess you could say sometimes, that I am ranting. It is for a good cause, and I probably have a lot more to learn. Speaking through these machines, across oceans, it's easy to do sometimes. I don't believe I have been the only one on this list to rant.
guilt by association, and U.K. laws about nutritional supplements<>the manufactures".
< a2="ind9911&L=" p="R15856&X=" y="flounder9%40verizon.net">Reply-To: Bovine Spongiform Encephalopathy
######### Bovine Spongiform Encephalopathy
Hello Terry and Everyone,
On Sat, 27 Nov 1999 18:54:39 -0600, Terry wrote:
######### Bovine Spongiform Encephalopathy
I have one question for you Ralph; from the statement made by the manufactures to the Gov. "152. There is no evidence of written assurances from the manufacturers supplied to either Maff or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus". If in fact, the manufactures could not supply this information to the Gov., confirming that baby food did not or has not contained bovine brain, spinal cord, spleen intestines and thymus;
What would you understand this to mean?
Firstly, the DFA paragraph 152 does _not_ say "the manufactures could not supply this information to the Gov". It says that there is no written evidence that they did -- not the same thing at all.
I do _not_ understand the DFA paragraph 152 to mean "the statement made by the manufacturers to the Gov." and nor should you. Paragraph 152 refers to the _absence_ of written evidence of a statement by the baby food manufacturers. You should not find it difficult to perceive the difference between what paragraph 152 actually says and what you say it says.
I have no first-hand knowledge of what was contained in babyfoods on sale in the UK at that time, and neither do you; but from my much earlier first-hand experience of babyfood manufacture, and Rachel's first-hand experience too, I regard it prima facie as most unlikely that SBOs were ever used in babyfoods.
Nor do I personally (or you) have any knowledge of _why_ there was "no evidence of written assurances from the manufacturers supplied to either Maff or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus".
Fortunately, in answer to my requests for her comments on your previous posts, I have now received two e-mail messages from Heather Paine which give clear answers on these matters, and which I regard as setting the record straight,.
Dear Ralph
Further to our telephone conversation yesterday here is a brief summary of my discussion with the journalist John Radowitz re BSE and babyfoods.
The journalist was mainly interested in MRM and asked me if the baby food industry used MRM to 'bulk out' baby foods!
I said no and that to my knowledge the UK baby food industry had never used MRM. I also told him that when the SBO offal ban came into being this had no effect on baby food industry practice because we didn't use these materials either.
Commercial baby food manufacturers work to very strict specifications and only use ingredients that meet their tough specifications. Mothers expect baby food manufacturers to use the best cuts of meat and so the meat used is similar to that used in preparing baby foods at home. Baby food manufacturers, therefore, do not use MRM from the carcases of cattle, sheep (lamb) or pig.
I also questioned his assumption that at one year old the child would have been fed only commercial baby foods. At that age it was just as likely that the child would be eating home made foods/family meals.
Hope this helps
Heather
Dear Ralph
Just read your latest e-mail. Nice to see the apology which I accept, but I do not accept his accusations that we are still guilty.
Just because MAFF have no written assurance about SBOs not being used in baby foods doesn't mean that we used these materials. In fact, MAFF were fully aware in 1989 that the baby food industry did not use SBOs. The trouble was that there is no written record.
When the Southwood Report was being put together, MAFF contacted IDFA at quite a late stage (and it was me in those days) to ask whether the baby food industry used these materials. We said 'no' (both IDFA and individual companies were contacted) but it was all by telephone, (MAFF wanted a quick response so they could advise the Southwood Committee) - so unfortunately there is nothing on record (at least IDFA records)! - Except, after the Southwood Report was published IDFA complained to the then Minister about their handling of the issue which implied a change in baby food industry practice.
Of course when the consultation on the Regulations took place IDFA did not comment as we did not use SBOs and so we had no objections. Again no written record! But the fact is UK baby food manufacturers did not use these materials in their products.
The moral of the story is of course always place your comments on record - even when you have 'no objections'. Hindsight is a wonderful thing!
All the best
Heather
Regards Ralph
******************************************************************
J Ralph Blanchfield MBE Food Science, Food Technology & Food Law Consultant Chair, IFST External Affairs Web Editor, Institute of Food Science & Technology IFST Web address
******************************************************************
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Subject: Baby Food * June 23, 1999 BSE Inquiry
From: "Terry S. Singeltary Sr."
Date: Tue, 30 Nov 1999 11:16:54 -0600 Content-Type: text/plain Parts/Attachments: text/plain (125 lines)
######### Bovine Spongiform Encephalopathy
Terry S. Singeltary Sr., Bacliff, Texas USA
> Greetings everyone, I thought these comments were interesting. Thought
> some of you might find some interest in them...
>
> 2 MR LAWRENCE: Yes.
> 3 MR WALKER: I think you thank Mr Cockbill later for help on
> 4 the idiosyncracies of the meat products regulations. Is
> 5 that what he helped on?
> 6 MR LAWRENCE: I think that is right. But I think in
> 7 conjunction with what I was being asked to do, I think
> 8 Charles Cockbill was considering, am I right, the
> 9 possible regulations in relation to baby food?
> 10 MR WALKER: Yes.
> 11 MR LAWRENCE: So he was also making an assessment of those
> 12 tissues which might contain infective agent for that
> 13 piece of legislation.
> 14 MR WALKER: Yes. He was head of Food Standards Division,
> 15 reporting to Mrs Attridge.
> 16 MR LAWRENCE: Yes.
> 17 MR WALKER: And I think we have seen documents which
> 18 suggest he was in correspondence with Dr Pickles at the
> 19 Department of Health in relation to the baby food
> 20 regulations.
> 21 MR LAWRENCE: I think I have seen some of those, yes.
> 22 MR WALKER: Can you recall whether he was helping you on
> 23 the tissues, then, that might be infective?
> 24 MR LAWRENCE: It may well be. I cannot quite recall.
> 25 I mean there were a lot of documents at the time. But
> 1 obviously I gleaned information from various different
> 2 sources because, you know, I did produce a draft,
> 3 I think of 27th April. So whether I took on board some
> 4 of the information that I had seen from Charles or not,
> 5 I do not know. It may well have been, yes.
> _______________________________________________________
>
> 15 Could you just help us on the manuscript that we
> 16 see here? Is this from Mr Meldrum to you dated 14th
> 17 May?
> 18 MR LAWRENCE: Yes, I think that is.
> 19 MR WALKER: And he said:
> 20 "Thank you for a chance to comment. I think there
> 21 is some danger of Don fusing the proposed legislation on
> 22 baby foods and a wider ban on brains, spinal cord et
> 23 cetera. I am a little uneasy about some of the
> 24 assumptions made because I am advised that some bovine
> 25 brains are used for human consumption."
>
> 1 Have I deciphered that correctly?
> 2 MR LAWRENCE: Yes, I think that is right.
> 3 MR WALKER: We see on the left, against that reference to
> 4 some bovine brains being used for human consumption:
> 5 "But not in meat products".
> 6 MR LAWRENCE: I think that is my writing.
>
> 4 MR WALKER: That is very helpful. Thank you very much.
> 5 That comment, is that something that, from your point of
> 6 view, you simply took at face value?
> 7 MR LAWRENCE: Well, yes. I mean, as a non-scientist I was
> 8 really relying on their expertise to advise me, you
> 9 know, in what I should be putting up to the Minister in
> 10 the way of advice, yes.
> 11 MR WALKER: Did you see it as your role to seek to identify
> 12 what the level was in animals suffering from the disease
> 13 and how much lower the level was in these sub-clinically
> 14 infected animals?
> 15 MR LAWRENCE: No.
> 16 MR WALKER: From your point of view, that was a matter for
> 17 the expert advisers?
> 18 MR LAWRENCE: Yes. I mean, I think I have said in perhaps
> 19 a rather simplistic way I simply wanted to know from
> 20 these blokes which tissues they felt should be banned
> 21 from human consumption. And it did not concern me, you
> 22 know, about titre levels or anything else. It was
> 23 really yes or no.
> 24 MR WALKER: Yes, thank you.
> _____________________________________________________
>
> 1 MR WALKER: Why was it you were saying to UKASTA that the
> 2 SBO ban was simply to maintain public confidence?
> 3 MR LAWRENCE: Well, can I again read out what I intend to
> 4 say in...
> 5 MR WALKER: Yes.
> 6 MR LAWRENCE: I am saying in response to what you are
> 7 asking me I think the answer to that is that it was. As
> 8 I have already stated, the risks from BSE were regarded
> 9 as remote so the SBO ban was a measure of additional
> 10 reassurance against that remote risk. The determination
> 11 of which tissues to proscribe was a scientific
> 12 assessment based on the scrapie analogy of those offals
> 13 which might contain the agent in cattle with
> 14 pre-clinical disease.
> 15 My minute, again, may be a bit of shorthand
> 16 because I wanted to refer, and I will do when I send the
> 17 supplementary note, to another document I sent out on
> 18 that very same day; and that was the consultation letter
> 19 in relation to the proposed SBO ban, which is reference
> 20 YB 89/7.26/1.1.
> 21 In that what I am saying, in the letter, amongst
> 22 other things, is that scientific advice, including that
> 23 reflected in Southwood Report, is that in clinically
> 24 diseased animals and those which may be incubating the
> 25 disease, the BSE agent might be present in the brain,
> lawrence
>
> 1 spinal cord, spleen, thymus, tonsils and intestines.
> 2 The Southwood Working Party suggested, merely as a
> 3 precautionary measure, that manufacturers of baby food
> 4 should refrain from using certain offals in their
> 5 products.
> 6 In all the circumstances, Ministers have decided
> 7 that the most effective way of ensuring the protection
> 8 of public health would be to make regulations under the
> 9 Food Act 1984, those regulations being the SBO ban.
> 10 So, yes, you know, my minute in the way it is
> 11 worded -- sorry, the minute you are referring to, yes,
> 12 does look as if it was simply maintaining public
> 13 confidence. But I think in the letter I sent the same
> 14 day, the consultation letter, I am explaining it in more
> 15 detail, you know, the reasoning behind it that there was
> 16 a scientific reason for going a bit further..................
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Subject: Southwood Working Party advice on baby food. >witness statement 184e - Meldrum issued 10/14/99
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Tue, 30 Nov 1999 12:32:34 -0600 Content-Type: text/plain Parts/Attachments: text/plain (872 lines)
######### Bovine Spongiform Encephalopathy
Terry S. Singeltary SR., Bacliff, Texas USA
(or hoping), that BSE could not be transmitted to humans. Unfortunately, they found out different...
___________________________________________________________
Southwood Working Party advice on baby food
5.In my oral evidence (T69, Vol. T7, Tab 9, page 74 to 75) I stated that it was normal practice when an expert working party reported for the recommendations to be accepted as they stood. As regards the Southwood Report, I went on to say that it was not until later when I and my colleagues came to think through the advice on baby food that it became clear that it appeared to lack some logic, "that if particular tissues should be removed from baby food, why should not those same tissues be removed from the food of adolescents or pregnant mothers or adult people? Where do you draw the line? So it was a gradual thinking process in part accelerated by the request from Sir Donald Thompson that he put in about the same time when he asked us to consider the possibility of removing from the human food chain adult cows and adult ewes at the end of their life….".
6.At first sight the advice that baby food manufacturers should avoid the use of ruminant offal and thymus did make sense; (a) the Southwood Working Party had concluded that the risk of transmission of BSE to humans was remote, (b) it was accepted at the time that the young were more susceptible to the TSEs, (c) nevertheless steps had already been taken to ensure that clinically affected cattle should not enter the human food chain, (d) but if the BSE agent were to be present in an animal it was most likely to be in the spleen and lymphatic tissues in the early stages of infection, and in brain and neural tissue as the disease progressed, (e) accordingly consideration had been given to the risks from products containing tissues from sub-clinically infected cattle, and (f) it was believed that the risks as perceived at that time did not justify action beyond that advised for baby food manufacturers. When further pressed on the matter in oral evidence, I reiterated that at the time the Southwood Report was submitted and considered by Ministers, I was quite content with the recommendations as they stood. It was not until shortly thereafter, and arising from discussions with colleagues and representatives from outside organisations, that there appeared to be a certain element of illogicality in the advice (T69, Vol. T7, Tab 9, page 76 to 77), i.e. how do you define a baby, do you draw the line at toddlers and what about adolescents. My view that consideration of the advice for baby food manufacturers was a gradual process is supported by Sir Derek Andrews' oral evidence (T81, Vol. T9, Tab 1, page 117, line 21 to page 118, line 23).
7.It follows that since it was a gradual thinking process, so too the advice to Ministers developed gradually. This advice might not have been formulated to expressly state that the recommendation "made no sense", but rather that certain aspects of it required clarification before steps could be taken to implement it. Also, whilst such advice may have been gradual, Ministers nevertheless did receive advice on (i) the definition of offals as used in the Southwood Report advice on baby food, (ii) whether the definition included liver and kidney, and (iii) why one should distinguish between babies and older humans. Even if it was not me personally who put forward the advice, it was put forward by other MAFF officials and I was aware that the issues were being discussed and Ministers kept informed by virtue of the fact that I was a copy recipient of numerous minutes. If I had felt that I needed to put forward additional separate advice to express my view as CVO I would have done so, as indeed I did later in relation to the draft regulations on baby food (see the section below on "Development of the SBO ban"). Ministers themselves took a very keen interest in BSE and the Southwood Report, asked many questions and put forward their views themselves on the options open to MAFF. They were therefore intimately involved with discussions on the development of the Government’s policy on the disease.
8.Turning to point (i) in paragraph 7 above, the Southwood Report did identify the offals in question, albeit indirectly, and also explained why such offals and thymus caused concern. Paragraph 5.3.5 of the Southwood Report referred to the generic term "offal" and cross-referred by a footnote to those regulations from which the definition of that term had been taken. When asked subsequently (see sub-paragraph 9(a) below), Sir Richard Southwood confirmed that the intention was that the reference was to mean offal as described in the regulations identified within that paragraph of the Southwood Report. As regards the reasons why such offals and thymus should cause concern, this follows from the statement earlier in paragraph 5.3.5 of the Southwood Report (IBD 2, Vol. IBD 1, Tab 2) that if the BSE agent were to be present in an animal it would most likely be in the spleen, lymphatic tissues, brain and neural tissue. Whether or not it was realised at that stage what the specific definition of offals was intended to be, it would be clear that if those were the tissues where the BSE agent might be found, then "offal" (even if defined as just brain and spleen) could be a concern. Similarly, if lymphatic tissue might harbour the agent, then thymus, which is part of the lympho-reticular system, could be a concern.
9.In any event, the definition of offals used in the Southwood Report was clarified in the course of consideration of the advice to baby food manufacturers. As the events set out below show, Ministers were aware of and were advised on this process of clarification, and particularly whether liver and kidney were included in the Southwood Report definition. Some of the key events are as follows: a.13th February, 1989. In Mr Lawrence's minute and brief for Ministers and the Permanent Secretary (copied to me) it was stated in relation to the advice on baby food that thymus was not used in baby foods but on the other hand kidneys and liver, but no other offals were. Manufacturers' agreement would be sought to using non-ruminant liver and kidney as a replacement in baby foods (YB89/2.13/4.1-4.15).
b.15th February, 1989. In a minute to Mr Cruickshank (copied to me), Mrs Attridge pointed out that liver and kidney were the major element of offal likely to be found in baby foods and constituted an important part of a baby's diet. Mrs Attridge said there could be a risk of malnutrition if the rather vague recommendation in the Southwood Report led to the removal of cow and sheep liver from baby food. She suggested referring the matter to the CMO so that further investigations could be made on the risks involved (YB89/2.15/2.1-2.2).
c.20th February, 1989. In a minute to Mr Cruickshank (copied to me), Mrs Attridge raised concerns over parts of the submission and question and answer brief for the Southwood Report that related to baby food. She said that definitive answers were needed so that MAFF would not be accused of spreading uncertainty over products which actually had very considerable nutritional advantages for all sectors of the population (YB89/2.20/1.1).
As well as being copied to me, Mrs Attridge's minute dated 15th ebruary, 1989 (YB89/2.15/2.1-2.2) was copied to the Minister (Mr MacGregor) and the minute dated 20th February, 1989 (YB89/2.20/1.1) was copied to Private Offices (i.e. Ministers and the Permanent Secretary). As such, Ministers received information and advice on the need to clarify the definition of offals used in the outhwood Report.
d.21st February, 1989. In a minute to Mrs Stagg (PS/Minister) (copied to me), Mr Cruickshank stated that the reference to the baby food advice in the paper for MISC138 had been amended to reflect Mrs Attridge's suggestion. The paper stated that the Southwood Working Party had not examined all the scientific evidence relating to offal, particularly liver and kidney in baby food, and the CMO would therefore consider this further and advise on any action required (YB89/2.21/2.1-2.19).
It should be noted that the wording in the paper reflected that suggested by Mrs Attridge as a way of enabling MAFF to assess the risks of any ban on liver and kidney without causing too many presentational difficulties. This minute was copied to Private Offices.
e.23rd February, 1989. A minute from Mr Garnett to Mrs Stagg (PS/Minister) (further copied to me by the original copy recipient Mr Cruickshank) recorded the CMO's clarification with Sir Richard Southwood of what was meant by the reference to "ruminant offal and thymus" in the Southwood Report. Mr Garnett explained that it was intended that the reference would be to offal as described in the Meat Products and Spreadable Fish Products Regulations 1984 (L11 Tab 6). This meant that liver, kidney and heart which might otherwise be regarded as "offal" would not be restricted by the Southwood Working Party's advice. The CMO's advice, cleared with Sir Richard Southwood, would be that they need not be concerned at the inclusion in infant diets of kidney, liver and heart (YB89/2.23/7.1-7.2).
The CMO had passed this information on to the Minister Mr MacGregor) at a meeting on 23rd February, 1989 which was also attended by the Secretary of State for Health. I did not attend this meeting but did receive a copy of the note of the meeting (YB89/2.23/3.1-3.3). As such I was aware of Mr MacGregor's iscussions with the Department of Health on this issue. The note of the meeting records that after the CMO explained the confirmation received from Sir Richard Southwood as to the definition of offals, it was felt appropriate for the Government to take legislative steps to implement the advice on baby foods. If the Minister had felt that he was not clear on the Southwood Working Party's advice or had not received sufficient advice on the issue, I am of the view that he would not have come to the judgement to proceed with legislation.
10.Turning to point (ii) in paragraph 7 above, Mr Garnett's minute of 23rd February, 1989 (YB89/2.23/7.1) indicates that the Southwood Working Party had never intended the reference to offal to include liver and kidney, but rather it had been part of their deliberations prior to submitting the Southwood Report to Ministers that the offals they were concerned about were those described in the Meat Products and Spreadable Fish Products Regulations 1984 (L11 Tab 6) (see also the oral evidence of the Southwood Working Party; T 106, Vol. T11, Tab 6, pages 101 and 102). The question as to whether this was a correct conclusion for the Southwood Working Party to make is, more properly, an issue on which the members of the Southwood Working Party might care to comment rather than me. In addition, the question of the risks to babies from liver and kidney was quite properly identified as a matter for the CMO to follow up with Sir Richard Southwood. I was aware from the minutes and meeting notes (YB89/2.23/3.1-3.3) that were copied to him that this was how it was being pursued, with the full knowledge of the Minister (Mr MacGregor).
11.Finally, turning to point (iii) in paragraph 7 above, whilst it is correct to say that the Southwood Report did not appear to give any explanation why a distinction could be drawn between babies and other groups of people, the contemporaneous documents demonstrate that the reasons for this were known and explained to Ministers. In addition I was aware at the time of the thinking on the susceptibility of the young to which I have already referred in paragraph 6 above (see point (b)). For example:
(a) 24th February, 1989. The Q&A brief circulated to the Prime Minister's office, the Cabinet Secretary and members of MISC 138 included a question n why there should be concern about offal in baby food and not food for adults. The answer was that young animals were more susceptible than adults to orally acquired SEs (YB89/2.24/10.1-10.13).
The version of the Q&A brief circulated to the Minister and Private Offices on 21st February, 1989 (see paragraph 9(d) above) also included this nformation.
(b) 3rd April, 1989. At a meeting between the Parliamentary Secretary and Compassion in World Farming, Mr Lowson referred to the possibility that oung 'animals' might be more susceptible than older ones (YB89/4.05/1.1-1.3).
This view was also expressed by Dr Pickles in a letter to Mr Cockbill (YB89/4.13/2.1-2.3), although I was not involved in Mr Cockbill's discussions with the Department of Health relating to the drafting of the baby food regulations.
Development of the SBO ban
12.As I explained in my oral evidence and as referred to in the sections above on "Assessment of the Southwood Report" and "Southwood Working Party advice on baby food", it was a "gradual thinking process" that led to the decision being made by Mr MacGregor in June 1989 that wider action was needed on offals to meet concerns about some tissues from sub-clinically infected animals and the possibility that cattle affected with BSE were "getting through the net to the market" (YB89/6.7/7.1-7.2). Events preceding the meeting with Mr MacGregor on 6th June, 1989 should be seen as development of the thinking by a number of people on the need to take wider action than that advised by the Southwood Working Party on baby food and earlier agreed by Ministers.
13.Mr Thompson requested advice on 21st March, 1989 as to whether MAFF should consider requiring that cull cows be excluded from human consumption as a precautionary measure as such animals could be culled before they started to display clinical symptoms of BSE (YB89/3.21/5.1). This was one of the factors contributing to the "gradual thinking process". In oral evidence, I referred to this as having in part "accelerated" that process (T69, Vol. T7, Tab 9, page 75). Mr MacGregor's thinking appears in his manuscript note dated 26th February, 1989 querying, amongst other things, whether MAFF should be taking further action on offal in new product preparations and that given that animals are slaughtered the moment they show signs of BSE, whether there were any risks from animals just before that stage (YB89/02.24/14.1). It is not clear whether that note was passed to any particular MAFF official or whether it was for Mr MacGregor's use only. I cannot recall seeing this note. However, my minute of 5th April, 1989 to Mr Lawrence (YB89/04.05/2.1) indicates that he was aware that both Mr MacGregor and Mr Thompson were concerned about the human health implications of consumption of high risk material derived from both cattle and sheep. In that minute I noted that Mr Thompson had asked about the disposal of cull ruminants and the Permanent Secretary (Mr Andrews) was speaking to Mr MacGregor about the use of brain and spinal cord in meat preparations and that a meeting might be called if Mr MacGregor so wished. There was no suggestion by this minute that either Mr Thompson or Mr MacGregor had made a specific proposal for action on sub-clinical cases. At that stage, these were concerns in respect of which advice was requested and provided.
14.In any event, my previous minute to Mr Lawrence dated 30th March, 1989 (YB89/3.30/2.1) appears to indicate that Mr Andrews' concerns stemmed from the adverse publicity being received on the use of brains, etc. in human food generally rather than specifically in relation to risks to human health from BSE, or more particularly from sub-clinically infected cattle (YB89/3.30/2.1). When Mr Thompson told me that the concerns he had expressed about cull cows actually related to the remote risk associated with the consumption of brain and spinal cord derived from cows, bulls, ewes and rams at the end of their working life, this served to clarify the detailed issue on which he required advice (YB89/4.10/2.1). Following consultation with the CVL, advice was put forward by Mr Lawrence on 22nd May, 1989 (YB89/5.22/1.1-1.4). So far as I can recall, prior to May 1989 no other events took place that could amount to a proposal from either Mr Thompson or Mr MacGregor, or indeed any other source, for "action on sub-clinical cases".
15.My minute of 26th May, 1989 (YB89/5.26/5.1-5.2) was put forward to Mr MacGregor after discussion with Mr Andrews, so that I could express my own views in a note to go to Mr MacGregor in parallel with the submission which Mr Andrews would be putting forward. That submission had been prepared by Mr Cockbill (YB89/5.26/4.1-4.12) to seek Ministers' approval for proceeding to public consultation on the draft regulations prohibiting the use of certain specified offals in baby food. As the note had to go from me in parallel with Mr Andrews' submission which was going forward on 26th May, 1989 (YB89/5.26/5.1-5.2), the minute (YB89/5.26/5.1-5.2) was prepared hurriedly and I recognise that the wording of that minute is not as clear as I feel it could have been if I had had more time to draft it. However, any imperfections would have been ironed out at the later meetings with Ministers.
16.As noted in Mr Cockbill's minute to Mr Ryder on the draft regulations, and in paragraph 4 of the submission itself, the list of prohibited offal in the draft regulations had been made wider than the limited list in the Southwood Report for "ease of enforcement and for the sake of consistency with other regulations made under the Food Act" (YB89/5.23/4.6). The draft regulations thus included offal from all mammalian species and covered a number of tissues which, although not likely to be significant in BSE terms, were equally not used in baby foods. This is the context in which the sentence in my minute of 26th May, 1989 (YB89/5.26/5.1-5.2) which reads, "I am becoming increasingly concerned that Ministers are being forced to consider a ban on the use for human consumption of certain offals, such as brain, spinal cord and spleens, derived from both cattle and sheep, even though there is no scientific evidence to support such action", should be read. It should also be noted that the reference to evidence in this part of the minute refers to cattle and sheep and not to one species alone; this is important in the context of later comments in the minute where reference is made to the scientific findings of Professor Hadlow and others. Mr Cockbill's minute to Mr Ryder (YB89/5.5/9.1-9.2) (copied to Mr MacGregor and Mr Andrews) had also noted that the proposals for the regulations as to baby food might stimulate suggestions that the ban should be extended to all meat products. My concerns expressed in his minute related to a large extent to the possibility that the proposals in Mr Cockbill's submission (YB89/5.26/4.1-4.12) might lead to pressure on MAFF to take action on sheep offals when scrapie had been in the UK and other countries for around 250 years without any scientific evidence of it being a human hazard. In addition, the control of scrapie in sheep and goats would have been a virtually impossible task at that time. This point had been made by me in a minute dated 30th March, 1989 to Mr Lawrence (YB89/3.30/2.1). Paragraph 5 of my minute dated 26th May, 1989 (YB89/5.26/5.1) further clarifies where my concerns lay and what action I did support; "it could be argued that the brain, spinal cord and spleen of adult cattle should be removed from the human food chain for the reasons expressed above but to go further and extend this to sheep would reopen the whole of the scrapie issue and would signal that we were concerned about the human health aspects of that disease".
17.My minute of 26th May, 1989 (YB89/5.26/5.1-5.2) went on to note that the argument for prohibiting the use of offals such as brain, spinal cord and spleens derived from adult cattle was more persuasive as we were dealing with a new condition in cattle and could not be certain that the agent could not jump yet another species barrier and affect man. This is clearly an indication of my support for a policy of destruction of potentially infective tissues in the event that Ministers felt that such action was necessary. In my minute, I specifically pointed out that on occasions the BSE agent would be present in the brain of apparently healthy cattle that were in the incubative stage and the BSE agent was also likely to be present on occasion in other materials such as spleen, lymph glands and nerves. This is information that I discussed at the meeting with Dr Kimberlin on 16th May, 1989 (YB89/5.18/5.1; YB89/5.16/1.1-1.3; paragraph 7 of section F of WS 184A).
18.Having received the information I did as a result of the meeting with Dr Kimberlin and Pedigree Petfoods, it is difficult to see how I either could or would oppose or fail to support a policy of destruction of potentially infective material in the event that Ministers decided to pursue such a policy. Once the decision to go further than the Southwood Working Party had advised had been taken, Dr Kimberlin's knowledge was applied to determine what tissues could sensibly be included in any ban. I knew from Dr Kimberlin that it was possible to extrapolate from Professor Hadlow's work in sheep. This was not new scientific evidence, but Dr Kimberlin’s assessment of the risk was new so far as I was concerned. It should also be noted that this was not scientific evidence on the BSE agent, rather it was a scientific comparison based on published data on the distribution of the scrapie agent in clinically affected sheep. In my oral evidence (T69, Vol. T7, Tab 9, pages 87 to 88), I explained that it was clear to me that Dr Kimberlin thought it was a "good idea" to keep those offals with the highest infectivity load out of the human food chain. It is important to note that I used the words "good idea" and that I did not say that such action on offals was either necessary or warranted at that time. A different distinction was made at a later date in the light of further assessments and knowledge.
19.In any event, the issue was discussed in detail with Ministers. In my minute of 26th May (YB89/5.26/5.1-5.2), I advised that Ministers should consult with Sir Richard Southwood, and asked for a meeting with Ministers himself to discuss the issues. The meeting between Mr MacGregor, MAFF officials and Dr Metters took place on 6th June, 1989 (YB89/6.7/7.1-7.2) and the meeting with Sir Richard Southwood took place on 7th June, 1989 (YB89/6.8/4.1-4.2).
20.Finally, I wish to comment on my recollection of the meeting on 16th May, 1989 with Dr Kimberlin. I described this in my previous statement (WS 184A, section F, paragraph 7). At the time I was preparing my previous statement (WS 184A) the only documents which I had available to me were my own handwritten notes of the meeting. Since then a number of additional documents have been found by the MAFF Liaison Unit which are relevant to the meeting. Whilst confirming that the meeting with Dr Kimberlin was on a confidential basis, these documents indicate that it was also attended by Mrs Owen, Mr Garnett and Dr Woolfe. I believe that there were two meetings. The first was attended by MAFF officials, Pedigree Petfoods and Dr Kimberlin (YB89/5.18/5.1) and the second was a more open meeting between Dr Kimberlin and myself. It was at that later meeting that Dr Kimberlin gave me a copy of the Pedigree Petfoods papers, in confidence. As regards the point of clarification over the number of documents which I received from Dr Kimberlin at the meeting, I can confirm that I received the five documents dated 2nd September, 1988 (M49 Tab 6)), January 1989 (M49 Tab 6A), February 1989 (two documents(M69 Tab 6B and 6C) and March 1989 (M69 Tab 6D). I did not recognise the earlier reference to five documents since my set of five documents are bound together as two separate documents.
Approach taken to the Southwood Working Party advice
21.I have been asked to consider whether the approach to be taken to advice from the Southwood Working Party should have been as follows:
"(1) where the Working Party had expressed their view on a scientific question (e.g. whether there was a risk that tissues from sub-clinically infected animals could be infective to humans if eaten or accidentally inoculated, and the best estimate of the extent of that risk in scientific terms) Ministers should not depart from this unless they had scientific advice to cast doubt about it;
(2) where such a body had made a value judgement as to whether any articular risk merited the taking of any particular steps it was for government to assess the costs and benefits of those steps in the light of scientific advice.
22.It is very difficult to draw such a clear cut distinction as between an advisory committee's view on a scientific question and a value judgment as to the merit of taking any particular steps, such a value judgment having been made as a result of a view taken on a scientific issue. To a certain extent it is agreed that an advisory committee's view on a scientific question could and should not be challenged except with further scientific data (see paragraphs 1 to 6 on the section above on "Relationship with the Southwood Working Party" which set out views on the Southwood Working Party and the approach to advisory committees in general; see also paragraph 18 of the section above on "Assessment of the Southwood Report".)
23.Taking, as an example, the Southwood Working Party's view on the scientific question as to the risks to human health from tissues from sub-clinically infected cattle, and their value judgment as to whether those risks as perceived at that time merited particular steps, be it labelling or advice to baby food manufacturers, I did not advise Ministers that they should not depart from or go further than the Southwood Working Party's advice that baby food manufacturers should avoid using ruminant offals and thymus. As explained in the section above on "Development of the SBO ban", my minute of 26th May, 1989 (YB89/5.26/5.1-5.2) did not amount to advice that Ministers should not go further than the Southwood Working Party's value judgment that the risks as perceived did not justify requiring the labelling of food products containing brain and spleen. If I had advised Ministers not to depart from this value judgment, then there may never have been an SBO ban. It was the assessment of the steps suggested by the Southwood Working Party that led to the development of the thinking behind the SBO ban.
24.In the context of this section, I have also been asked to consider the following matters: a.Southwood Report "unnatural practices" recommendation.
I was questioned on the issue of the Southwood Working Party's proposed "unnatural practices" recommendation in my oral evidence. I was asked whether it was my own view that, as stated by Mr Suich in a minute of 10th January, 1989 (YB89/1.10/2.1-2.2) to the Permanent Secretary, "such a controversial recommendation went wider than the Southwood Committee's remit". My answer was: "It would have been the general view at the time, whilst on the other hand accepting that if Government and Ministers decide to appoint an expert working party, it is most unhelpful to then fetter them in the ecommendations that they can make. Therefore this was simply and solely an issue of reporting that this consideration was taking place and to make sure that the Permanent Secretary … was in fact alerted to it" (T69, Vol. T7, Tab 9, page 72). In this respect, I would also comment that there were spurious suggestions in the press at the time that MAFF had influenced and altered the Southwood Report and that the final wording had been cleared with MAFF. As the contemporaneous documents show, this was not the case. Indeed, as far as I can recall, I was never formally consulted on the draft Southwood Report in the way that it appears to have been suggested that I would be (YB89/1.17/9.1). I believe it was quite proper that I should not be invited to comment in this way. When the Permanent Secretary (Mr Andrews) suggested to Sir Richard Southwood that I should attend the final meeting of the Southwood Working Party to discuss rendering practices, this was turned down by Sir Richard Southwood, who made it clear that my input was not equired (YB89/1.31/1.1-1.8; YB89/2.2/2.1). In any event, at the time it was recognised that the Southwood Working Party seemed intent on including the recommendation on "unnatural practices" in its final report. However, it was felt that a paper rom MAFF making the Southwood Working Party aware of what the rendering industry did and its scale of activity, would at least leave room for the Government to examine a number of options apart from a prohibition on the use of recycled animal waste in animal feed (YB89/1.10/2.1-2.2).
b.Southwood Report advice for baby food manufacturers.
It was accepted that the wording of the advice for baby food manufacturers was less than precise and some clarification was subsequently required, but the drafting of the Southwood Report was a matter for the Southwood Working Party and them alone. This has been discussed in more detail in the section above on "Southwood Working Party advice on baby food"
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*** BABY FOODS 2001
Subject: FSA ADMITS ERROR OVER BABY FOOD - BABY FOODS AND MAD COW DISEASE back on table...
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Sat, 20 Oct 2001 10:19:30 -0700 Content-Type: text/plain Parts/Attachments: text/plain (203 lines)
######## Bovine Spongiform Encephalopathy
Saturday, 20 October, 2001, 02:24 GMT 03:24 UK
FSA admits error over baby food
Many parents remain concerned over baby food ingredients The Food Standards Agency has admitted its chairman wrongly asserted that British sheep were not used in baby food production.
Sir John Krebs said lamb from the UK was not being used in baby food.
He suggested there was a voluntary agreement by the food industry to use lamb only from countries like New Zealand.
Sir John hoped the assertion would be reassuring for those who feared sheep might harbour BSE.
But a spokesman for the baby food industry, Heather Payne, told the BBC manufacturers are still using British lamb.
"The lamb that baby food manufacturers use comes from a number of different sources. But it includes the UK, New Zealand, France and Germany.
"We had a meeting earlier this year with the Food Standards Agency and we explained all our procedures and all our operations to them.
"They advised us there was no need to change our source of lamb."
Lethal illness
There have been fears that BSE could be present in the national flock, sparking fears of a mass slaughter.
BSE-infected meat is widely believed to be the source of the lethal vCJD illness in humans
The FSA said in August that there was a "theoretical risk" BSE was in sheep, but stressed it was not asking people to stop eating lambs.
There have previously been concerns, fiercely denied by the baby food industry, that mechanically-recovered meat from heavily infected areas of cattle could have been used in the 1980s.
The FSA has joined in the chorus of criticism after it was revealed on Friday that scientists investigating whether BSE was in sheep had actually been examining the brains of cattle.
http://news.bbc.co.uk/hi/english/health/newsid_1609000/1609832.stm
Greetings list members,
we debated this issue in great length on Nov. 25, 1999. i even got a spanken from Ralph for being a bit rude for attacking Heather. But thought since the issue is back in the media and Heather is making comments again, some might be interested in the debate of 1999 on baby foods and BSE. no attack intended on Heather...
with kind regards, Terry S. Singeltary Sr., Bacliff, Texas USA
Re: Girl, 13, shows CJD symptoms. [re-baby food]
Date: Thu, 25 Nov 1999 22:30:36 +0000
J Ralph Blanchfield
snip...
It is easy with the 20/20 vision of hindsight to say now that certain animal derivatives should not have been used in baby foods (and indeed we do not know that they were, and Heather Paine is quoted as saying that to her knowledge they were not). Until the investigations of the Southwood Committee, there was anyway no reason to suppose that these materials, from apparently healthy cows, were other than wholesome or had any connection with BSE or indeed vCJD (the existence of which was at that point unknown). As it happens, the food manufacturer for which I worked in the early 1950s, among its many canned, bottled, frozen and dehydrated products, manufactured a range of baby foods including a beef broth, which was made from Argentinian frozen beef -- no offals of any kind.
But each manufacturer decided for itself what ingredients to use, and they were/are in no way controlled or "overseen" by a trade association, which is what the Infant and Dietetic Foods Association was/is. So Terry, your attack on Heather Paine was unwarranted and badly misconceived, and I think you owe her an apology.
I happen to know Heather well in an entirely different connection, and a more honest and conscientious person it would be hard to find.
snip...
===================================
At 11:35 AM 11/24/99 -0600, Terry wrote:
Heather Paine should be educated on the products she over-sees. These children's health are at risk, and if she does not know what has and has not been going into baby-foods, she does not need to hold that position. The Inquiry was very concerned about baby foods, and at one point said something about;
It is very unlikely that baby food would contain SBO's, since baby food is the most highly regulated and safest of all commercial foods.
So, if baby food is suspected as a vehicle for BSE->ukCJD, then it would be base on its containing normal cuts of meat. Baby foods contain more liver than the general population eats, so perhaps there could be a correlation there.
Babies of all species have more porous intestinal membranes, so uptake of prions would be expected to be more efficient.
snip...
========================================
99. Mr. Lawrence wrote a letter to Sir Richard on 6 January 1989 (110) explaining that there were _no_ special regulations with regard to the composition of baby food except in relation to additives, and that there was therefore _nothing_ in the rules that would exclude certain parts of animal being incorporated into baby foods as long as they were fit for human consumption.
152. There is _no_ evidence of written assurances from the manufacturers supplied to either MAFF or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus.
155. The reply also outlined the following actions already taken or to be taken by the Government in response to the Working Party's recommendations. 1) As a precautionary measure the Government would enact secondary legislation to ensure it was illegal to sell Baby Food containing brain, spinal cord, spleen and intestines.
165. On 23 May 1989 Mr. Cockbill prepared draft regulations prohibiting the use of certain _specified offals_ in Baby Foods...
snip...
========================================
for anyone interested and wanting to search data of this thread, search BSE-L archive NOVEMBER 1999. towards the bottom, #35.
kind regards, Terry S. Singeltary Sr., Bacliff, Texas USA
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Subject: Re: FSA ADMITS ERROR OVER BABY FOOD - BABY FOODS AND MAD COW DISEASE back on table...
From: J Ralph Blanchfield
Reply-To: Bovine Spongiform Encephalopathy
Date: Sat, 20 Oct 2001 19:15:48 +0100 Content-Type: text/plain Parts/Attachments: text/plain (249 lines)
######## Bovine Spongiform Encephalopathy
Hello Terry and Everyone,
The question of the sources of lamb used is of course a totally different issue from that of the past allegations about the use of MRM,, as Terry is very well aware, and he deserves another (and severe) spanking for intentionally misrepresenting the two issues as the same issue ("since the issue is back in the media").
Sir John had obviously been badly briefed when in an interview he said that no UK lamb was used in babyfood, when in fact FSA actually knew that it was one of the sources. Moreover, on advice published by FSA there was no reason why it should not have been one of the sources (actually UK lamb "of scrapie-free lineage").
As regards the "lamb brains" paste from the early 1990s that turned out to be cow brains paste, Terry has assumed his usual "conspiracy theory" explanation. Generally speaking, in real life sensible people examine the likelihood of cock-up before jumping to the conclusion of conspiracy I certainly think there was no excuse for the curious timing and obscure method of disclosure (the Jo Moore syndrome?), but as to the wrong material being tested for four years, I think that this was the major cock-up of all time. Fortunately, a separate investigation, at the Weybridge veterinary laboratories has been proceeding in parallel, on 163 scrapie-affected present-day sheep and so far no BSE has been found. And before Terry produces his usual condescending lecture and mantra about "absence of evidence is not evidence of absence", all of those with any sort of scientific background on this list were trained to understand that as a basic principle long before he entered this list and picked up the phrase.
Best wishes Ralph
******************************************************
Prof J Ralph Blanchfield, MBE Food Science, Food Technology and Food Law Consultant Chair, External Affairs, Institute of Food Science and Technology Webmaster / Editor, Institute of Food Science and Technology Vice President, European Food Law Association of the UK Chair, IFT Committee for Global Interests Past Chair, IFT British Section Adjunct Professor, Michigan State University IFST Web address
*****************************************************
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Subject: Re: FSA ADMITS ERROR OVER BABY FOOD - BABY FOODS AND MAD COW DISEASE back on table...
From: Brian MATTHEWS
Reply-To: Bovine Spongiform Encephalopathy
Date: Mon, 22 Oct 2001 15:33:42 +0100 Content-Type: text/plain Parts/Attachments: text/plain (270 lines)
######## Bovine Spongiform Encephalopathy
Ralph,
Regarding the second part of the posting (sheep), would this be the same or a different study to that reported in the last week or so where the wrong animals' brains were examined.
Given the latest display of ineptitude on the part of UK scientists, what faith can be placed in the data?
Regards,
Brian Matthews lt09@dial.pipex.com
https://lists.aegee.org/cgi-bin/wa?A2=ind0110&L=BSE-L&P=R11463&X=4F0C9B3D9F1736BD9D&Y=flounder9%40verizon.net
Subject: Re: FSA ADMITS ERROR OVER BABY FOOD - BABY FOODS AND MAD COW DISEASE back on table...
From: J Ralph Blanchfield
Reply-To: Bovine Spongiform Encephalopathy
Date: Mon, 22 Oct 2001 19:00:08 +0100 Content-Type: text/plain Parts/Attachments: text/plain (311 lines)
######## Bovine Spongiform Encephalopathy
Hello Brian and Everyone,
I only have access to the same information that you do. I thought it was crystal-clear, and I think I reflected that in the second part of my posting, that there were two separate experiments, namely
1) the experiment at the Institute of Animal Health (the so-called Bostock experiment) supposedly on a paste of scrapie-infected sheep collected in 1990 for a different purpose along with brains from BSE-infected cattle. Because of fears of cross-contamination, DEFRA referred a sample of the sheep-brain paste for testing to the Laboratory of the Government Chemist which has now determined by DNA that the supposed ovine material was in fact wholly bovine. This is the experiment that I described as "the major cock-up of all time". But whose cock-up? Before rushing to blame the IAH scientists, I would want to know exactly what was the provenance of the material provided to them to test.
2) A totally separate experiment on a number (too-small, 163) of present-day scrapie infected sheep brains, carried out by Veterinary Laboratory Agency in Weybridge, which so far has produced no evidence of BSE.
Best wishes Ralph
******************************************************
Prof J Ralph Blanchfield, MBE Food Science, Food Technology and Food Law Consultant Chair, External Affairs, Institute of Food Science and Technology Webmaster / Editor, Institute of Food Science and Technology Vice President, European Food Law Association of the UK Adjunct Professor, Michigan State University IFST Web address
******************************************************
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Subject: Re: FSA ADMITS ERROR OVER BABY FOOD - BABY FOODS AND MAD COW DISEASE back on table...
From: Brian MATTHEWS
Reply-To: Bovine Spongiform Encephalopathy
Date: Mon, 22 Oct 2001 19:22:09 +0100 Content-Type: text/plain Parts/Attachments: text/plain (334 lines)
######## Bovine Spongiform Encephalopathy
Dear Ralph,
I seems at least possible that the mix up of brain material involved the former MAFF laboratories. This is currently under investigation, of course. Perhaps this information will also be published in a government press release at 22.30!
If the MAFF scientists were involved in the first cock-up, why should their information be seen to be any more reliable for the second experiment unless it is first vetted by independent scientists? After all, the same people did not all come out with glowing testimonials in the BSE Inquiry report.
Another aspect of the cock-up that concerns me is that the work was being undertaken in a laboratory that could not, according to all accounts I have seen, undertake a DNA test to confirm the source of the materials sent to them. It seems surprising that the work should continue for so long without such a basic test of veracity being applied.
Regards,
Brian Matthews lt09@dial.pipex.com
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===================== *** BABY FOOD 2005 *** =====================
===============: BSE 'may have entered baby food in 70s' ===================
LISTS.AEGEE.ORG ( BSE-L: 61 matches (only the first 50 will be shown).. )
Subject: Re: BSE 'may have entered baby food in 70s'
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Fri, 4 Mar 2005 17:09:14 -0600 Content-Type: text/plain Parts/Attachments: text/plain (956 lines)
##################### Bovine Spongiform Encephalopathy #####################
THE BABY FOOD (PROHIBITED OFFAL) REGULATIONS 1989
http://collections.europarchive.org/tna/20080102185118/http://www.bseinquiry.gov.uk/files/yb/1989/05/00002001.pdf
http://collections.europarchive.org/tna/20080102185203/http://www.bseinquiry.gov.uk/files/yb/1989/05/00001001.pdf
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UK EXPORTS BOVINE SEMEN
http://web.archive.org/web/20030331015257/http://www.bseinquiry.gov.uk/files/mb/m11g/tab04.pdf
BABY FOODS
There are 4 brands available for a quick survey - Boots, Cow & Gate, Heinz and Robinson.
None of the meat dishes included 'offal' in the ingredients.
Steak & Kidney and Beef and Oxtail did, however, include kidney and oxtail.....
snip...
http://collections.europarchive.org/tna/20080102185207/http://www.bseinquiry.gov.uk/files/yb/1989/01/17006001.pdf
http://web.archive.org/web/20090506001348/http://www.bseinquiry.gov.uk/files/mb/m11g/tab04.pdf
About the only item it seems many remain to be decided next week is what if anything we say about offal in baby food. I enclose now in confidence the draft as it stands at present concerning this aspect. It might be that no action is recommened. On the other hand, the working party, PERSUADED BY THE ANIMAL EVIDENCE THAT IMMATURE ANIMALS ARE MORE SUSCEPTIBLE TO INFECTION WITH THE AGENTS OF SPONGIFORM ENCEPHALOPATHY, may make some recommendations either about labelling or about banning offal in baby food.......
http://collections.europarchive.org/tna/20080102185215/http://www.bseinquiry.gov.uk/files/yb/1989/01/25001001.pdf
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BSE SOUTHWOOD REPORT
CONFIDENTIAL
snip...
BABY FOODS
7. The working Party consider that manufacturers of baby foods should, as a precautionary measure, avoid the use of ruminant offals and thymus. Sir Richard Southwood has told the Minister of Agriculture, Fisheries and Food that the likelihood of problems arising through the use of these products in baby food is very low indeed and that this suggestion is counsel of ''extreme prudence''. In practice thymus is not used in the preperation of baby foods, kidneys and liver are because of their nutritional value. Officials will contact manufacturers urgently to seek their reaction to the suggestion...
snip...
http://collections.europarchive.org/tna/20090506060319/http://www.bseinquiry.gov.uk/files/yb/1989/02/17005001.pdf
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This would enable us to assess more fully what the actual risks are and what the risks are of any ban on liver and kidney in baby foods.
We do not wish to create problems for young children and ethnic minorities simply on the basis of poorly substantiated speculation. On the other hand, if there is clear evidence this must be taken into account. My understanding is that the evidence is not clear-cut and does need further consideration...
snip...
http://web.archive.org/web/20030506230546/http://www.bseinquiry.gov.uk/files/yb/1989/02/15002001.pdf
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BSE AND BABY FOOD
snip...
1. We spoke about MacGregor's concern about baby food and how, if asked about beef liver and kidney, he was proposing replying:
"I understand that the committee (Southwood's) did not have the opportunity to examine thoroughly all the scientific evidence relating to offal particularly liver and kidney in human and baby food. I therefore propose to refer the matter to the CMO to seek his advice before taking any further action."
2. Whilst we agreed this clearly was passing the buck, I guess it's the best MacGregor can do.....
snip...
http://collections.europarchive.org/tna/20080102140603/http://www.bseinquiry.gov.uk/files/yb/1989/02/20006001.pdf
NEW URL LINK 2022
POWERS TO REGULATE BABY FOODS
DEFINITION OF BABY FOOD
1. There is no definition of baby food (nor of baby) for food legislation purposes...
snip...
http://collections.europarchive.org/tna/20080103002304/http://www.bseinquiry.gov.uk/files/yb/1989/02/23014001.pdf
NEW URL LINK 2022
Heinz Baby Foods
WE guarantee that __________________ are free from offal OTHER THAN that which is named in any product description and in particular contain no thymus, brains, spinal chord, spleen, and intestine.
THE ONLY OFFALS USED IN __________________ ARE KIDNEY, LIVER, AND OXTAIL when they are always identified on the lable, both in the product description and in the list of ingredients.
PICTURE OF BABY FOOD JAR NAMED STEAK AND KIDNEY LUNCH
INGREDIENTS - WATER, BEEF, CARROTS, POTATOES, KIDNEY, MODIFIED CORN FLOUR, SPLIT GREEN PEAS, FLOUR, TOMATO PUREE, LIVER, .....
snip...
ANOTHER PICTURE OF BABY FOOD JAR NAMED BEEF AND OXTAIL DINNER
ingredients listed also, but difficult to read, name self explanitory, contains beef and OXTAIL...TSS
ANOTHER BABY FOOD JAR NAMED LIVER AND BACON DINNER, ingredients listed
ANOTHER BABY FOOD JAR NAMED STEAK AND KIDNEY DINNER, ingredients listed
ANOTHER BABY FOOD JAR NAMED BRAISED STEAK AND KIDNEY, ingredients listed
ANOTHER BABY FOOD JAR NAMED LAMB AND LIVER CASSEROLE, NO INGREDIENTS LISTED (WHAT ABOUT LAMB AND BSE ??? TSS)
http://collections.europarchive.org/tna/20080103002829/http://www.bseinquiry.gov.uk/files/yb/1989/02/23015001.pdf
NEW URL LINK 2022
for someone to claim no risk from these products to young children with todays science and with the documented pictures of the baby food jars with ingredients, is like johann saying there is NO RISK from canadian beef. just aint so folks...CASE IN POINT;
107 Vet Pathol 42:107 108 (2005) Letters to the Editor Editor:
Absence of evidence is not always evidence of absence.
In the article Failure to detect prion protein (PrPres) by immunohistochemistry in striated muscle tissues of animals experimentally inoculated with agents of transmissible spongiform encephalopathy, recently published in Veterinary Pathology (41:78 81, 2004), PrPres was not detected in striated muscle of experimentally infected elk, cattle, sheep, and raccoons by immunohistochemistry (IHC). Negative IHC, however, does not exclude the presence of PrPSc. For example, PrPres was detected in skeletal muscle in 8 of 32 humans with the prion disease, sporadic Creutzfeldt-Jakob disease (CJD), using sodium phosphotungstic acid (NaPTA) precipitation and western blot.1 The NaPTA precipitation, described by Wadsworth et al.,3 concentrates the abnormal isoform of the prion, PrPres, from a large tissue homogenate volume before western blotting. This technique has increased the sensitivity of the western blot up to three orders of magnitude and could be included in assays to detect PrPres. Extremely conspicuous deposits of PrPres in muscle were detected by IHC in a recent case report of an individual with inclusion body myositis and CJD.2 Here, PrPres was detected in the muscle by immunoblotting, IHC, and paraf- fin-embedded tissue blot. We would therefore caution that, in addition to IHC, highly sensitive biochemical assays and bioassays of muscle are needed to assess the presence or absence of prions from muscle in experimental and natural TSE cases. Christina Sigurdson, Markus Glatzel, and Adriano Aguzzi Institute of Neuropathology University Hospital of Zurich Zurich, Switzerland References 1 Glatzel M, Abela E, et al: Extraneural pathologic prion protein in sporadic Creutzfeldt-Jakob disease. N Engl J Med 349(19):1812 1820, 2003 2 Kovacs GG, Lindeck-Pozza E, et al: Creutzfeldt-Jakob disease and inclusion body myositis: abundant diseaseassociated prion protein in muscle. Ann Neurol 55(1): 121 125, 2004 3 Wadsworth JDF, Joiner S, et al: Tissue distribution of protease resistant prion protein in variant CJD using a highly sensitive immuno-blotting assay. Lancet 358:171 180, 2001tss
COW AND GATE BABY FOODS
snip...
Further to our telephone conversation today, I would like to confirm to you that ____________________ babyfoods do not contain brain, bowels, feet, testicles or lever (oh my...TSS). WE DO have a babymeal variety which contains kidney, but I can confirm that this is correctly labelled in line with current UK legislation...
snip...
http://collections.europarchive.org/tna/20080103002321/http://www.bseinquiry.gov.uk/files/yb/1989/02/23016001.pdf
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ANNEX 2
Dear Dr. Woolfe,
This is to confirm that the only offal used in ____________________ beef kidney, which is used in Steak and Kidney Junior Meal. The kidney is purchased to a tight specification and is checked for quality.
We do not use any other offal material, such as liver, brain, intestines, spinal cord etc...
snip...
http://collections.europarchive.org/tna/20080103002614/http://www.bseinquiry.gov.uk/files/yb/1989/02/24015001.pdf
http://web.archive.org/web/20090506060408/http://www.bseinquiry.gov.uk/files/yb/1989/02/24015001.pdf
http://collections.europarchive.org/tna/20080103002506/http://www.bseinquiry.gov.uk/files/yb/1989/02/24016001.pdf
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http://web.archive.org/web/20030516041446/http://www.bseinquiry.gov.uk/files/yb/1989/02/27015001.pdf
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BABY FOODS WARNING
snip...
Although we are aware from Dr. Woolfe's enquiries that none of these particular offals are CURRENTLY used in baby food... nonetheless the Ministers wishes to go ahead urgently........
snip...
http://collections.europarchive.org/tna/20080102143408/http://www.bseinquiry.gov.uk/files/yb/1989/02/28006001.pdf
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NEWSPAPER ARTICLE ABOUT BABY FOOD WARNING
http://collections.europarchive.org/tna/20080103002737/http://www.bseinquiry.gov.uk/files/yb/1989/02/28007001.pdf
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HERE IS A MOST DISTURBING DOCUMENT.
2. In his fourth paragraph, Mr. Cockbill says that in notifying the EC Commission we can claim the need for urgent action on the basis of a ''KNOWN HEALTH RISK''. I am concerned that this might be misinterpreted by the Commission and others. The Southwood Report concluded that, from present evidence, cattle are likely to prove a dead-end host for the BSE agent and that BSE is most unlikely to have any implications for human health. Our action in banning offal in baby foods is therefore a precautionary measure and not one to deal with a known risk.
3. In view of the sensitivity of this issue could I ask that you keep us in close touch with developments at your end and let us HAVE THE OPPORTUNITY TO SEE DRAFTS OF THE NOTIFICATION, SUBMISSION ETC?
snip...
http://web.archive.org/web/20030714134945/http://www.bseinquiry.gov.uk/files/yb/1989/03/03003001.pdf
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MANIPULATING AND MANAGING STATEMENTS TO THE MEDIA
http://collections.europarchive.org/tna/20080103005917/http://www.bseinquiry.gov.uk/files/yb/1989/03/03009001.pdf
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http://collections.europarchive.org/tna/20080103010010/http://www.bseinquiry.gov.uk/files/yb/1989/03/09001001.pdf
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IN CONFIDENCE
5. IT might be PRUDENT to advise that where bovine or ovine bones are required for food purposes PARTICULARLY FOR BABY FOODS THEY SHOULD BE OBTAINED FROM LIMB BONES ALONE...
R BRADLEY MARCH 4, 1989
http://collections.europarchive.org/tna/20080103010144/http://www.bseinquiry.gov.uk/files/yb/1989/03/04001001.pdf
STILL CONCERNS OF TAIL MEAT IN BABY FOOD
http://collections.europarchive.org/tna/20080103010345/http://www.bseinquiry.gov.uk/files/yb/1989/03/07005001.pdf
NEW URL LINK 2022
THE BABY FOOD (PROHIBITED OFFAL) REGULATIONS
SNIP...
WE need however to consider those offals that are included in Part Heart, liver and kidney have all been discussed and agreed as suitable for use in baby foods. Diaphragm, head meat (muscle meat) and tongue are not offals in the accepted sense. This leaves pancreas and tail meat to be considered. .........
snip...
IN reaching your views on these issues, could I please draw to your attention the relationship that they will have for meat products general. Although the Southwood Report confined itself to offals baby foods, opinions are already being expressed publicly (some medical practitioners) that similar prohibitions should extend to all meat products. SINCE SOME MEAT PRODUCTS WILL UNDOUBTEDLY BE CONSUMED BY BY YOUNG CHILDREN OR TEENAGERS, IT MAY BE DIFFICULT TO DRAW A LINE BETWEEN BABY FOODS AND OTHERS. ...
snip...
http://collections.europarchive.org/tna/20090114064151/http://www.bseinquiry.gov.uk/files/yb/1989/03/28001001.pdf
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THE BABY FOOD (PROHIBITED OFFAL) REGULATIONS 1989
http://collections.europarchive.org/tna/20080102185118/http://www.bseinquiry.gov.uk/files/yb/1989/05/00002001.pdf
http://collections.europarchive.org/tna/20080102185203/http://www.bseinquiry.gov.uk/files/yb/1989/05/00001001.pdf
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BABY FOODS
There are 4 brands available for a quick survey - Boots, Cow & Gate, Heinz and Robinson.
None of the meat dishes included 'offal' in the ingredients.
Steak & Kidney and Beef and Oxtail did, however, include kidney and oxtail.....
snip...
http://collections.europarchive.org/tna/20090506014316/http://www.bseinquiry.gov.uk/files/yb/1989/01/17006001.pdf
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About the only item it seems many remain to be decided next week is what if anything we say about offal in baby food. I enclose now in confidence the draft as it stands at present concerning this aspect. It might be that no action is recommened. On the other hand, the working party, PERSUADED BY THE ANIMAL EVIDENCE THAT IMMATURE ANIMALS ARE MORE SUSCEPTIBLE TO INFECTION WITH THE AGENTS OF SPONGIFORM ENCEPHALOPATHY, may make some recommendations either about labelling or about banning offal in baby food.......
http://collections.europarchive.org/tna/20081106023518/http://www.bseinquiry.gov.uk/files/yb/1989/01/25001001.pdf
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2. The Southwood report recommended that baby foods manufactureres should not use ruminant offal and thymus in baby foods. This was interpreted as any offal listed in Schedule 2 Part 2 of the Meat Product Regulations. The Committee, in effect, are advising the Ministry that ANY offal which carries ANY risk of transmitting the BSE agent to baby foods should not be used in their manufacture. The offal listed in Part 2 Schedule 2 of the MPSFPR is by NO MEANS EXHAUSTIVE, and OTHER ORGANS EXIST e.g. ENDOCRINE AND PITUITARY GLANDS, which are HIGH 'RISK' from the point of view of the presence of BSE or Scrapie agent. Therefore I feel that any regulations should widen the scope of the definition of offal to include any of these organs NOT mentioned in Part 2...
snip...
5. I had some reservations about TAILMEAT because of its close association with the spinal cord.
http://collections.europarchive.org/tna/20080102143359/http://www.bseinquiry.gov.uk/files/yb/1989/03/03008001.pdf
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WE need however to be wary of casting the net too wide in case we catch products for which there is no justification on restricting them. What I have in mind here is your suggestion that we should also cover all products produced from offals. Rennet is of course produced from CALVES STOMACHS and LARD or TALLOW may be produced from mammalian offals. SO far as I am aware thse are produced at sufficiently high temperature that there is no need to restrict their use in baby foods...
http://collections.europarchive.org/tna/20081105215137/http://www.bseinquiry.gov.uk/files/yb/1989/03/08002001.pdf
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COMMENTS FROM Dr. Hilary Pickles;
To pick out some of these tissues but not others would be difficult to justify. Within this group I would include pancreas (sweetbread) and PERIPHERAL NERVES (which brings in oxtail) and possibly liver too. I WOULD NOT RECOMMEND INCLUDING THESE IN ANY BAN AT PRESENT, but it should perhaps be recognised that the level of suspicion is somewhat higher than with other tissues such as muscle mass (steaks etc).
RENNET SHOULD BE OF NO CONCERN SINCE IT IS AN EXTRACT OF STOMACH ............
http://collections.europarchive.org/tna/20081105215142/http://www.bseinquiry.gov.uk/files/yb/1989/04/13002001.pdf
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THE BABY FOOD (PROHIBITED OFFAL) REGULATIONS 1989
BSE-BABY FOODS R BRADELY
(written letter hard to read...TSS)
info- and to ensure we DO NOT GET THE BLAME FOR LEGISLATION THAT CAN BE ??? ON A SCIENTIFIC BASIS.
snip...
4. An important OMISSION IS LYMPH NODE. This was NOT identified specifically in previous regulations but IS A HIGH RISK TISSUE IF BSE FOLLOWS THE LINE OF SCRAPIE...
http://collections.europarchive.org/tna/20080102195408/http://www.bseinquiry.gov.uk/files/yb/1989/05/05002001.pdf
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The idea therefore that the Richmond Committee should now examine the wider issue of offals in foods and the risks of BSE does NOT seem to me to be a logical consequence from Dr Pickles letter of 13 April.
SNIP...
I think any reference to that in the letter should be deleted and we should stick firmly to the line that we have from Alan Lawrence that the Richmond Committee should leave this TOPIC WELL ALONE;
http://collections.europarchive.org/tna/20080103005147/http://www.bseinquiry.gov.uk/files/yb/1989/05/05009001.pdf
IN CONFIDENCE
http://collections.europarchive.org/tna/20080103005355/http://www.bseinquiry.gov.uk/files/yb/1989/05/09001001.pdf
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They classify offals into two groups as follows:-
(i) Diaphragm, head meat (muscle only), heart, kideny, liver, pancreas, tail meat, thymus, tongue.
(ii) Brains, feet, intestine, lungs, oesophagus, rectum, spinal cord, spleen, stomach, texticles udder.
Group (i) can be used in ALL MEAT PRODUCTS AND CAN COUNT TOWARD THE MEAT CONTENT OF THOSE PRODUCTS
Group (ii) can only be used in cooked meat products and cannot count towards meat content.......
21 pages;
http://collections.europarchive.org/tna/20080102200106/http://www.bseinquiry.gov.uk/files/yb/1989/05/23004001.pdf
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Terry S. Singeltary Sr. P.O. Box Bacliff, Texas USA 77518
Terry S. Singeltary Sr. wrote:
##################### Bovine Spongiform Encephalopathy #####################
BSE 'may have entered baby food in 70s'
James Meikle, health correspondent Friday March 4, 2005 The Guardian
Scientists are to test a hypothesis that young people who have died from the human form of BSE were infected by contaminated baby foods as far back as 1970.
The controversial idea supposes that some meat products were harmful to people 16 years before BSE in cows was even recognised, and 25 years before young adults began dying from its dreadful human equivalent.
Should this prove true, it will mean rethinking the likely future course of the disease, which is predominantly British, although cases have occurred in other countries.
Variant CJD here appears to be on the wane. Only nine people died in 2004, the fewest since 1995, its first recorded year, giving rise to the hope that no more than a few hundred may eventually succumb to it. Since 1995, 154 Britons have been identified with the disease, a handful of whom are still alive.
But the hypothesis advanced by Stephen Dealler, a microbiologist at Lancaster Royal infirmary, suggests that only the "first wave" is declining.
He argues that there were further infections in the mid- to late-1980s, when teenagers and others ate contaminated meat, including burgers. By then hundreds of thousands of cattle were carrying BSE and the tissues most likely to contain infection were not banned in food until 1989.
Babies are more susceptible to infection because their gut walls are more permeable, Dr Dealler said yesterday. But even in them the disease took about 25 years to take its course.
People infected later would take far longer, up to 40 or 50 years, to develop the clinical disease, indeed might never do so at all, but could still be in fectious; a nightmare for blood transfusion services, which depend on the under 40s for donations.
Dr Dealler put his ideas to the Spongiform Encephalopathy Advisory Committee, a government advisory body, which greeted them with scepticism.
But even doubters are concerned that the average age of victims at death is still in the late 20s, an average which ought to be getting higher as more years pass since the food controls introduced in the late 1980s.
Extrapolation from studies of otherwise healthy appendixes have suggested that as many as 3,800 people may be carrying the infection.
Moreover, all those who have died from the disease so far have been from one genetic group, but evidence of vCJD infection in the spleen has been found in a patient who died from another cause and had a different genetic make-up.
This raised the fear that far more people may yet go down with the disease while displaying different symptoms.
Dr Dealler claims that his hypothesis fits the evidence from animals with similar diseases, and from cannibals in Papua New Guinea acciden tally infected with a brain disease.
"It has been shown that neonatal animals are more easily infected, and with lower doses of disease, than older animals," he said. "The real epidemic of BSE in humans has not actually started. What we are just seeing is the beginning with young children."
Proving his ideas will be difficult, and food manufacturers have refused to give him data from the 1970s and 1980s.
The possible drawbacks to his hypothesis include the fact that many of the 15 people infected with vCJD recorded abroad had never been to Britain, and only one, from the US, was a baby in Britain.
Other scientists question his assumptions about the incubation periods in animals and humans.
Professor James Ironside, of the CJD surveillance unit in Edinburgh, was cautious, but admitted: "Exposure to baby food is indeed a possibility."
Professor Chris Higgins of Imperial College London, who chairs Seac, was blunter: "There is a lot of anecdote there, rather than hard and fast data.
"We really need to go away and assess that before anyone jumps to any conclusions. I think we would all accept there is some age range during which infection probably occurs. But I am not at all convinced at the moment, until we have looked at all the details, that the idea that it is first the very young, and secondly pre-the main epidemic is likely to be right at all."
The Infant and Dietetic Foods Association, representing baby food manufacturers, insists on its website that manufacturers "have never used any of the high risk materials banned as a result of the controls on BSE".
http://www.guardian.co.uk/bse/article/0,2763,1430267,00.html
https://lists.aegee.org/cgi-bin/wa?S2=BSE-L&X=4F0C9B3D9F1736BD9D&Y=flounder9@verizon.net&q=FSA+ADMITS+ERROR+OVER+BABY+FOOD+&s=&f=&a=&b=
From: "Terry S. Singeltary Sr."
152. There is _no_ evidence of written assurances from the manufacturers supplied to either MAFF or the Department of Health asserting that Baby Food did not contain bovine brain, spinal cord, spleen, intestines or thymus. 155. The reply also outlined the following actions already taken or to be taken by the Government in response to the Working Party's recommendations.
1) As a precautionary measure the Government would enact secondary legislation to ensure it was illegal to sell Baby Food containing brain, spinal cord, spleen and intestines. 165. On 23 May 1989 Mr. Cockbill prepared draft regulations prohibiting the use of certain _specified offals_ in Baby Foods...
Kind Regards, Terry S. Singeltary Sr., Bacliff, Texas USA
"Robert A. LaBudde" wrote:
> > At 11:35 AM 11/24/99 -0600, Terry wrote:
> >Heather Paine should be educated on the products she over-sees. These
> >children's
> >health are at risk, and if she does not know what has and has not been
> >going into
> >baby-foods, she does not need to hold that position. The Inquiry was very
> >concerned about baby foods, and at one point said something about;
> > It is very unlikely that baby food would contain SBO's, since baby food is
> the most highly regulated and safest of all commercial foods.
> > So, if baby food is suspected as a vehicle for BSE-
>ukCJD, then it would be
> base on its containing normal cuts of meat. Baby foods contain more liver
> than the general population eats, so perhaps there could be a correlation
> there.
Babies of all species have more porous intestinal membranes, so uptake of prions would be expected to be more efficient. > >
================================================================ > Robert A. LaBudde, PhD, PAS, Dpl. ACAFS e-mail: ral@lcfltd.com > Least Cost Formulations, Ltd. URL: http://lcfltd.com/ > 824 Timberlake Drive Tel: 757-467-0954 > Virginia Beach, VA 23464-3239 Fax: 757-467-2947 > "Vere scire est per causae scire" > ================================================================ >
snip...
Date: Sat, 27 Nov 1999 12:03:22 +0000
Reply-To: BSE-L Sender: BSE-L
From: J Ralph Blanchfield Organization: Consultant
Subject: Re: Girl, 13, shows CJD symptoms. [re-baby food] In-Reply-To:
BSE-L
Hello Terry and Everyone,
On Fri, 26 Nov 1999 10:36:34 -0600, Terry wrote:
Hello Ralph and All,
>I think you are correct Ralph, after reading back over my comments, I was a bit >hasty, and in a friends eyes, may have even seemed rude.
>For that I would like to apologize to Heather and You.
Thank you. I shall forward your post on to Heather, and invite her to send me a response, which I shall forward to BSE-L.
It still does not change my position on the matter. It would have been better
>directed, if I would have directed my haste, to the _whole_ industry involved, as
>opposed to Heather and the Baby Food industry. For obvious reasons, if the DFA's are accurate, and the statements within from the Working Party and the Gov. and the statement from the manufacturers of Baby Foods,
>where they are stating in DFA 9;
>"152. There is no evidence of written assurances from the manufacturers supplied >to either Maff or the Department of Health asserting that Baby Food did not
>contain bovine brain, spinal cord, spleen, intestines or thymus".
snip...end
SNIP....
From: J Ralph Blanchfield
Subject: Re: Girl, 13, shows CJD symptoms. [re-baby food]
Hello Terry and Everyone, On Sat, 27 Nov 1999 18:54:39 -0600, Terry wrote:
snip...end...2008...tss
SOME GOOD READING AND DEBATING IN NOV. 1999 ;
1. Girl, 13, could be youngest BSE case * Girl, 13, could be youngest BSE case
(99 lines) From: tom
(116 lines) From: Terry S. Singeltary Sr.
(36 lines) From: Roland Heynkes
(56 lines) From: Terry S. Singeltary Sr.
(58 lines) From: Roland Heynkes
(217 lines) From: Terry S. Singeltary Sr.
(227 lines) From: Univ.-Prof.Dr.Herbert Budka
(115 lines) From: Terry S. Singeltary Sr.
(49 lines) From: Roland Heynkes
(57 lines) From: Roland Heynkes
(37 lines) From: Terry S. Singeltary Sr.
(76 lines) From: Univ.-Prof.Dr.Herbert Budka
(80 lines) From: Debora MacKenzie
(90 lines) From: Terry S. Singeltary Sr.
(55 lines) From: Robert A. LaBudde
(90 lines) From: Terry S. Singeltary Sr.
(82 lines) From: Robert A. LaBudde
(214 lines) From: J Ralph Blanchfield
(47 lines) From: Roland Heynkes
(50 lines) From: Rachel Shepherd
(42 lines) From: Tim Sly
(48 lines) From: Roland Heynkes
(60 lines) From: Roland Heynkes
(303 lines) From: Terry S. Singeltary Sr.
(84 lines) From: Robert A. LaBudde
(100 lines) From: Tam Garland
(402 lines) From: J Ralph Blanchfield
(588 lines) From: Terry S. Singeltary Sr.
(179 lines) From: J Ralph Blanchfield
(79 lines) From: Roland Heynkes
(55 lines) From: Rachel Shepherd
(73 lines) From: Torsten Brinch
(69 lines) From: Roland Heynkes
(64 lines) From: Rachel Shepherd
(95 lines) From: Roland Heynkes
TSS
######### https://listserv.kaliv.uni-karlsruhe.de/warc/bse-l.html ##########
######### https://listserv.kaliv.uni-karlsruhe.de/warc/bse-l.html ##########
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https://lists.aegee.org/cgi-bin/wa?S2=BSE-L&X=1D1B9A2D19721D3331&Y=flounder9@verizon.net&q=baby+foods&s=&f=&a=&b=
END...TSS...2008
P.S. check out the USDA CERTIFIED DEAD STOCK DOWNER COW SCHOOL LUNCH PROGRAM IN THE USA (biggest long term case study in the USA of children exposed to the deadly mad cow disease atypical BSE, more virulent to humans)
DEAD STOCK DOWNER COW SCHOOL LUNCH PROGRAM USDA
http://downercattle.blogspot.com/
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http://madcowfeed.blogspot.com/2008/04/substances-prohibited-from-use-in.html
http://prionunitusaupdate2008.blogspot.com/
Terry S. Singeltary Sr. P.O. Box
