Subject: Use of Materials Derived From Cattle in Human Food and Cosmetics [Docket No. 2004N-0081] RIN 0910-AF47
Date: April 17, 2008 at 2:41 pm PST
http://www.fda.gov/OHRMS/dockets/98fr/05-17693.htm
http://www.fda.gov/ohrms/DOCKETS/dockets/04n0081/04N-0081_emc1148-02.pdf
http://www.fas.usda.gov/info/fr/2004/071404BSEFDA1.htm
http://edocket.access.gpo.gov/2005/pdf/05-17693.pdf
In experimentally infected cattle, brain and spinal cord were again been confirmed to be infectious, but in addition the distal ileum (lower small intestine) also contained significant amounts of infectivity(31, 32). Two key ganglia, which are key intermediate points linking the central and peripheral nervous systems, namely TAFS 3 the trigeminal and dorsal root ganglia (DRG), were also clearly infectious(32, 33). This is not surprising given their close association with central nervous tissue. Peripheral nerves have also been demonstrated to become positive after the brain and spinal cord(1, 19). Completion of bioassay studies has also enabled a better understanding of the sequence of events, and rate of accumulation of infectivity, especially in relation to ileum, brain and spinal cord(1,2), and have confirmed the basic assumptions upon risk management policy were based.
PAGE 3
http://www.tseandfoodsafety.org/position_papers/TAFS_POSITION_PAPER_SPECIFIED%20RISK%20MATERIALS_2009_feb.pdf
Thursday, April 17, 2008
Use of Materials Derived From Cattle in Human Food and Cosmetics [Docket No. 2004N-0081] RIN 0910-AF47 [Federal Register: April 17, 2008 (Volume 73, Number 75)] [Rules and Regulations] [Page 20785-20794] From the Federal Register Online via GPO Access [wais.access.gpo.gov] [DOCID:fr17ap08-7]
http://cjdmadcowbaseoct2007.blogspot.com/2008/04/use-of-materials-derived-from-cattle-in.html
Monday, February 01, 2010
Import Alert 17-04 BSE CJD HIGH RISK TISSUES, Nutritional Supplements and Cosmetics
http://creutzfeldt-jakob-disease.blogspot.com/2010/02/import-alert-17-04-bse-cjd-high-risk.html
SEE HISTORY OF COSMETICS AND MAD COW TYPE DISEASE
-------- Original Message --------
Subject: Docket No. 2004N-0081 and or RIN number RIN-0910-AF47 Use of Materials Derived From Cattle in Human Food and Cosmetics [comment submission]
Date: Tue, 13 Jul 2004 16:08:38 -0500
From: "Terry S. Singeltary Sr." T
o: fdadockets@oc.fda.gov
CC: burt.pritchett@fda.gov, Agriculture@mail.house.gov
COMMENT SUBMISSION [Docket No. 2004N-O081] RIN-0910--AF47 Use of Materials Derived From Cattle in Human Food and Cosmetics
http://www.fda.gov/OHRMS/DOCKETS/98fr/04n-0081-nir0001.pdf
Greetings FDA,
I would kindly like to comment on the potential for TSE transmission from cosmetics to humans and why I think that ALL animal by-products should be excluded from cosmetics. IF we look at the TSE 'KURU'. Kuru is a transmissible spongiform encephalopathy that was identified in Papua New Guinea in the late 1950s. Several thousand cases of the disease occurred during a period of several decades. Epidemiologic investigations implicated ritual endocannibalistic funeral feasts as the likely route through which the infectious agent was spread. The incubation period in females was estimated to be shorter than that in males. The shortest incubation periods were estimated in adult women, who may have been exposed to the largest doses of infectious material. MY question is, was the woman exposed to larger doses, are was it the route of the agent that may have been the factor of shorter incubation in woman, or both?
What is Kuru? Kuru is a rare and fatal brain disorder that occurred at epidemic levels during the 1950s-60s among the Fore people in the highlands of New Guinea. The disease was the result of the practice of ritualistic cannibalism among the Fore, in which relatives prepared and consumed the tissues (including brain) of deceased family members. Brain tissue from individuals with kuru was highly infectious, and the disease was transmitted either through eating or by contact with open sores or wounds. Government discouragement of the practice of cannibalism led to a continuing decline in the disease, which has now mostly disappeared.
snip...
PLEASE NOTE the later ''or by contact with open sores or wounds.''
and the disease was transmitted either through eating or by contact with open sores or wounds.
http://www.ninds.nih.gov/health_and_medical/disorders/kuru.htm
the Fore women would scoop the brains of their dead relatives out of their skulls by hand before cooking. They then wiped the residual liquid and cadaver tissue over their paint-daubed bodies, leaving it caked in their hair and on their bodies for weeks after a mortuary feast.
Jennifer Cooke: kuru deaths continue in 1999
Sydney Morning Herald, Saturday, August 28, 1999
TSE INFECTION does takes place when the skin surface has been broken by scarification (Taylor et al, 1996).
The transmission of KURU into animals supported the belief that the disease had been transmitted through ceremonial cannibalistic rituals in New Guinea with a possible route of spread involving handling fresh tissue and inoculation through mucous membranes and wounds including skin abrasions (Gajdusek, 1977)
Masters, C.J., Gajdusek, D.C. and Gibbs, C.J., (1980). The spongiform encephalopathies: the natural history of CJD and its relationship to kuru and scrapie.
* Gajdusek D.C. (1996). Kuru: From the New Guinea field journals 1957-1962. Grand Street, 15:6-33
* Gajdusek D.C. (1973). Kuru in the New Guinea Highlands. In Spillane JD (ed): Tropical Neurology. New York, Oxford University Press.
* Gajdusek D.C., Gibbs C.J., and M. Alpers (1966). Experimental transmission of a kuru-like syndrome to chimpanzees. Nature, 209:794.
* Lindenbaum S. (1979). Kuru Sorcery. Mountain View, Ca, Mayfield Publishing Company.
SCCNFP/0724/03, final THE SCIENTIFIC COMMITTEE ON COSMETIC PRODUCTS AND NON-FOOD PRODUCTS INTENDED FOR CONSUMERS OPINION CONCERNING USE OF SPECIFIED RISK MATERIAL IN COSMETICS CLARIFICATION FOR TALLOW DERIVATIVES adopted by the SCCNFP on 30 July 2003 by means of the written procedure SCCNFP/0724/03, final Opinion on the Use of specified risk material in cosmetics - Clarification for tallow derivatives
____________________________________________________________________________ _________________
2 1. Background
snip...
http://europa.eu.int/comm/health/ph_risk/committees/sccp/documents/out229_en.pdf
4. For GBR-C III and IV countries, tallow derivatives are safe if, in addition to the above (3), the specific risk materials have been removed and are not used for the production of tallow/tallow derivatives.
PLEASE NOTE, under the old BSE GBR, the USA would be re-classified as at least a GBR III risk assessment, if not a GBR IV in my opinion due to the misgivings from USDA/APHIS et al, some documented below in my references from Docket No, 04-047-l Regulatory Identification No. (RIN) 091O-AF46 NEW BSE SAFEGUARDS (comment submission).
Report on the Assessment of the Geographical BSE - Risk of USA (July 2000) (220kb)
http://europa.eu.int/comm/food/fs/sc/ssc/out137_en.pdf
snip...end
Subject: DFA 18 Cosmetics...[There have been reports of BSE outbreaks in Germany, France, and even in the U.S.A., a prime market for Jersey cattle]
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Mon, 1 Nov 1999 09:28:04 -0600
Content-Type: text/plain
Parts/Attachments: text/plain (66 lines)
Reply
Terry S. Singeltary Sr., Bacliff, Texas USA --
Greetings,
I have been reading over the latest DFA 18, about cosmetics, and the possible route of BSE, through this source. Several interesting comments I find, that have brought several questions in mind, ones in which I have asked before, and still no answer. The CDC refuses to answer any of my questions through their site, and no one else seems to know the answer. Is the U.S.A. considered to be B.S.E. free, by other Countries? I asked this question to Dr. Detwiler, her reply was; "To the best of my knowledge there are no countries in the world which restrict any animals or animal products from the United States due to a risk from BSE. I am not sure if all such countries are using the term BSE free"...
The reason in bringing this up, I find several statements in this draft, that pertains to this, statements that I find quite interesting;
Page 24, DFA 18, -- "the line taken on cosmetics including sourcing from overseas was based on that given for licensed medicinal products by a group that included Drs. Kimberlin, Watson and Will, as well as other MAFF officials. There is no question that the UK is an "infected area": the only question is whether other countries should be included too. The Licensing Authority, quite reasonably in my view, feels they can only insist on sourcing in Countries where there is no evidence of BSE and the veterinary service and reporting system is adequate to detect it were it is present. Most manufacturers of mainline pharmaceuticals are not risking having to change sources yet again and so are looking to Australasia. If the CVO thinks he has enough evidence, _say concerning the USA_, to persuade the CSM, CDSM etc to advise more strongly against sourcing there too, he should present that evidence in a convincing form and in writing. I do not see this as a matter for our group, since there are statutory responsibilities under the Medicines Act. What we should do is ensure consistent advice is given for those borderline products (like these "cosmetics" with medicinal claims) that currently fall outside that Act."
Page 60, DFA 18, cosmetics -- 4. If it is possible for humans to contract "mad cow" disease from cosmetics, the risk is greater from "exotica" products because, unlike soap ingredients, the ingredients are not subject to repeated boiling and some are just merely chilled. MAFF have advised the CTPA that the only safe source is Australasia. Along with other European countries, France and Germany have imported from the UK infected feedstuff and live cattle. There have been reports of BSE outbreaks in Germany and France and _even in the USA_, a prime market for Jersey cattle. The Germans claim that they have "cured" their infected cattle by bathing them in a special dip they have developed but MAFF say there is no magic German cure. The French are masters at suppressing bad news. However, their higher scientific committee has issued "approved BSE guidelines" for French industry to follow. These guidelines cover, amongst other things, cosmetic products and are based on guidelines issued by MAFF. The French have not credited MAFF at all and are touting their guidelines around the Commission.
I suppose my question would still be, does the EU, and or all the rest of the European Countries, consider the U.S.A. to be B.S.E. Free?
------------------ http://www.uni-karlsruhe.de/~listserv/ -------------------
https://lists.aegee.org/cgi-bin/wa?A2=ind9911&L=BSE-L&P=R270&1=BSE-L&9=A&I=-3&J=on&X=2D25604264697D83A3&Y=flounder9%40verizon.net&d=No+Match%3BMatch%3BMatches&z=4
Subject: COSMETICS, TOILETRY AND THE PERFUME INDUSTRY & B.S.E.
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Sun, 3 Sep 2000 10:55:19 -0700
Content-Type: text/plain
Parts/Attachments: text/plain (305 lines)
Reply
######### Bovine Spongiform Encephalopathy
Greetings List Members,
Human transmission: There are some in the media and even the medical profession who are trying to make connections between BSE and the human disorder CJD. There is _no_ evidence of any association nor would we expect any cases by now even were BSE to be transmissible to humans. Dr Wills' study (see 2i above) will monitor the situation for the next decade or two.
I thought i would break off the vaccines & BSE related issues just briefly, to show you another fine example of the, hmmmmmmmm, i will not use _cover-ups_, because people cannot accept that, even if that is where the truth lies. So i will call them, the _purposely miss judgements_, or _happen-stances of mega-ignorance_.
kind regards, Terry S. Singeltary Sr., Bacliff, Texas USA
=======================================================================
dti
Miss Marion Kelly Cosmetic, Toiletry and Perfumery Association 35 Dover Street London W1X3RA
Department of Trade and Industry
10-18 Victoria Street London SW1H ONN
Enquiries 01-215 5000
Telex 8811074 DTHQ G
01 215 3324
1 February 1990
Dear Marion
As you know there is no record of bovine spongiform encepalopathy crossing to humans, but we need to take precautions to avoid any risk.
There a number of cosmetric products on sale in the United Kingdom such as anti-ageing creams that contain extracts of bovine offal, primarily from spleen and Thymus.
The purpose of this letter is to ask you to ask your members to eliminate any risk by reformulating such products to eliminate these extracts, or alternatively to use material derived from cattle reared outside the UK, Eire or the Channel Islands.
Please let me know if you have any trouble persuading your members to do so.
Yours sincerely
R J ROSCOE
CONSUMER SAFETY UNIT
ROOM 407
90/02.01/14.1
==============
BSE110/1 0080
DEPARTMENT OF HEALTH AND SOCIAL SECURITY HANNIBAL HOUSE Room No ELEPHANT AND CASTLE LONDON SE1 6TE
1 February 1990
Mr R Roscoe Consumer Affairs Department of Trade and Industry 10-18 Victoria Street London SW1
Dear Richard
USE OF BOVINE OFFAL IN COSMETICS
I am replying to your request for advice on the safety of the use of extracts of bovine offal in certain cosmetics, such as skin products claimed to have 'anti-ageing' properties with respect to bovine spongiform encephalopathy (BSE). As you are aware there are a number of cosmetic products on sale in the UK that contain small amounts of such extracts, primarily from spleen and thymus.
we accept that the risk of transmission is likely to be remote, but believe that it would be prudent to eliminate any risk by reformulating such products. Alternatively if the incorporation of bovine extracts is retained, material derived from cattle reared outside the UK, Eire or the Channel Islands should be used.
We would be grateful if you would transmit these recommendations to industry via the Trade Association CTPA.
I attach background briefing prepared by medical colleagues from those sections most involved with consideration of BSE in DH, together with a copy of the Southwood report.
Please let me know if you need any further information.
Yours sincerely
DR R J FIELDER
Enclosure
90/2.1/7.1
===========
BSE110/1 0081
BACKGROUND BRIEFING
presence of Bovine Offals in Cosmetics and Bovine Spongiform Encephalopathy
(1) Extracts of bovine spleen and thymus are present at between ca 0.1 and 5% in certain cosmetic preparations, for example certain products claimed to delay the signs of ageing of skin. The concern about the increasing incidence of BSE in cattle in the UK has made it necessary to reconsider the safety of such products.
The disease
BSE is a progressive neurological disorder in cattle, which results from infection with an "unconventional viral' agent. The first case was described in cows in 1986. By 19 January 1990 there had been 9436 confirmed cases in the UK on 5474 farms. There are no confirmed cases outside the British Isles, apart from a case in a cow recently exported from England. BSE is one of a family of spongiform encephalopathies which also include scrapie in sheep and kuru and Creutzfeldt Jakob disease (CJD) in man. The infection which leads to BBE appears to have been introduced into cattle from the contaminated feeding stuff, meat and bone meal, made partly from sheep offal: scrapie is endemic in sheep in the UK.
The causative agents of these diseases are thought to be unconventional transmissible agents (referred to variously as prions, virinos, filamentous viruses or slow viruses). They are extremely resistant to most denaturing processes eg heat, UV, high salt concentration, formalin and alkylating agents. The current DH guideline for treating items used on CJD patients is a temperature of 134-138 C (at 2 atmospheres) held for 18 minutes. They are also not removed by normal microbiological filters. It is thus unlikely that the mild processing techniques used to obtain the extracts used in cosmetics would remove the causative agents.
(2) Government action to date includes:
a. An expert working party was set up under Sir Richard Southwood and reported in February 1989. All their recommendations have been acted upon.
b. The disease has been made notifiable in cattle.
c. All suspect animals are slaughtered and carcases destroyed (50% compensation policy but 100% if diagnosis not confirmed); milk from such animals is also destroyed.
d. Sale or supply of animal protein from ruminants for feeding to ruminants prohibited - hopefully to prevent any new infections in cattle. This has had a major effect on the rendering industry.
e. Another committee was set up under Dr David Tyrrell to report on research needs. An interim report was published in January 1990 together with an announcement about additional funding. Much research work into the disease is currently in progress and additional studies are being planned.
Regulations in November 1989 introduced a ban on various
90/2.1/7.2
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BSEllO/1 0082
bovine offal for human consumption, going wider than the Southwood recommendations which were for such a ban to affect baby food only.
The Medicines Control Agency have gathered information from pharmaceutical companies about use of bovine ingredients in parenteral pharmaceuticals and issued interim guidelines. Many biological products and vaccines use such ingredients. The MCA are considering whether action on specific products is appropriate.
h. The Health and Safety Executive (HSE) is reviewing its guidance to those who come into direct contact with bovine 'risk' tissues. A press release for those who handle BSE carcases has been issued and one for abattoir workers is in preparation. The HSE ara also discussing risks from BSE exposure with the veterinary profession.
i. All UK cases of CJD will be monitored in a study to be conducted by Dr R G Will in Edinburgh, funded by the Department of Health: this should allow detection of any spread of infection to hummans, although this possibility is considered remote.
(3) Current live issues
Research: Dr Tyrell's interim report identified a large research programme classed as high priority. Almost all of this research falls to MAFF {Central Veterinary Labs} or the AFRC, although the MRC also has an interest. Substantial money has been made available for this work but research will be laborious and results will come slowly.
Food: There has been constant pressure on MAFF about the supposed risk to humans from eating beef and beef products. Infected animals who are incubating the disease but do not show any abnormalities cannot be detected at present and will be entering the human food chain. The offal ban removes the highest 'risk' tissues. Some critics may not be satisfied by this. However, others may argue the action to date is over the top, not demanded by the experts, and illogical since scrapie-infected sheep can still be eaten and doing so for the last 200 years has not caused harm to humans. We expect BSE agent to be resistant to irradiation as applied to food, as well as relatively resistant to cooking.
Other animals: There is no evidence that animals other than cattle (and domesticated, deer) have been or could be affected by BSE, other than experimentally, but there are pressures to extend the ruminant protein ban: at present pigs and poultry receive this sort of feed. Such action, as well as being hard to justify scientifically, would increase costs for the industry and cause perhaps insurmountable problems for abattoirs, who would find renderers no longer willing to accept offal. Many 1000's of tons of offal need to be disposed of daily.
Compensation: This has been set at 50% for BSE, although for some other diseases it is higher. Some critics believe this encourages evasion, with cows affected minimally being sent for human consumption. Even the current level of compensation is proving expensive for MAFF.
Exports: Some foreign countries have banned British exports of seman, embryos and livestock. The EC now no longer accepts live cattle over 6 months of age. The Germans are creating difficulties over beef exports too. The EC are also considering making BSE
90/2.1/7.3
=============
BSE110/1 0083
notifiable and banning ruminant protein feeding to rminants, as we have done here. At present, British meat and bone meat can still be exported and might spread infection overseas (MAFF claim importers have been warned that it is not regarded suitable for feeding to ruminants).
Human transmission: There are some in the media and even the medical profession who are trying to make connections between BSE and the human disorder CJD. There is _no_ evidence of any association nor would we expect any cases by now even were BSE to be transmissible to humans. Dr Wills' study (see 2i above) will monitor the situation for the next decade or two.
90/2.1/7.4
=========== [like i have said, they really did miss the boat on this whole ordeal. from day one, to date, and they still continue to deny the inevitable.] TSS
=========== [also, found this in this pile, so will just add...tss] ===========
BOVINE SPONGIFORM ENCEPHALOPATHY
I have been asked to provide a draft reply to the attached letter from Sir Richard Southwood to the Minister. The Minister has indicated that we must meet Sir Richard's points (a} on the need for him to be fully briefed as to developments and (b) on the urgency of making progress with the transmission study.
On (a), I would suggest that the draft reply should indicate that you will be in touch with Sir Richard regularly to keep him in the picture. On (b), I hope we can now tell Sir Richard that the arrangements for the purchase and relocation of the animals are under way.
A R Cruickshank
20 June 1989
Mr A J Lawrence
AH
cc Mr K C Meldrum Dr W A Watson Mr R C Lowson
89/6.20/8.1
============
############ http://mailhost.rz.uni-karlsruhe.de/warc/bse-l.html ############
https://lists.aegee.org/cgi-bin/wa?A2=ind0009&L=BSE-L&P=R2540&1=BSE-L&9=A&I=-3&J=on&X=57C86A263C194B4411&Y=flounder9%40verizon.net&d=No+Match%3BMatch%3BMatches&z=4
From: TSS (216-119-138-155.ipset18.wt.net)
Subject: FAT LIPS/SHINY HAIR/Creams (Cosmetics) PRETTY WOMEN $ MOVIE STARS $ MAD COW DISEASE ...
Date: June 10, 2001 at 8:24 am PST
Greetings ALL,
was reading a 'smut' magazine about the 'babes' and came across this article about the different movie stars 'fat lips' (collagen injections). something in the article caught my eye. ONE was Collagen and the other was HASK PLACENTA No-Rinse Treatment. (if containing animal tissues, and then running down into the eye's, seems like a potential transmission route, if you consider kuru and the fact transmission of that TSE agent via topical applications {rubbing of organs etc on skin, cuts etc...TSS}).
""Attention, Goldie Hawn: You might want to forget about more collagen infections for that full-lipped look. Collagen for the procedure usually comes from cows -- as in "mad cow disease". So what's a girl to do? Some docs are using an acid found in roosters' combs instead of collagen. Others use collagen from 'ELITE' herds that don't mix with common bovines. And one scientist is awaiting approval for a human collagen from the foreskin of infant boys -- further proof that beauty is only skin deep""-- 'The National Enquirer' 5/6/01
are these babes in far a 'rude' awakening. firstly, these so called 'ELITE' herds they speak of, are what they call, 'tissue donor herds', that are suppose to be fed 'only' certain products that _do not_ include ruminant feed of any sort. AND from the exact question i asked at the infamous '50 STATE EMERGENCY CONFERENCE CALL' of Jan, 9, 2001, sadly we find, there is absolutley, NO SUCH THING. It was all a joke. The 'partial' ruminant to ruminant feed ban of August 4, 1997, never was enforced, and most knew nothing about it, and/or chose to ignore it.
http://bseusa.blogspot.com/2010/04/upcoming-bse-webinar-on-thursday-april.html
Hask Placenta® No-Rinse Hair Repair Treatment
Nature's protein treatment. Excellent for hair that is abused by relaxing, tinting, bleaching and exposure to the sun.
Price: US$4.95 Package: 5 fl oz (150 ml) Item No.: P8225 **discontinued** - replaced by Perm-Aid® No-Rinse Conditioning Treatment
Placenta, the most powerful natural protein for the hair instantly restores life and luster to day brittle hair.
Directions:
Shake well. Apply after shampooing. Use pump and spray until hair is saturated. Massage thoroughly. Do not rinse. Wait 3 minutes: proceed as usual with setting or styling.
Ingredients:
Water, SD Alcohol 40, Placental Protein, Cetrimonium Bromide, Lactic Acid, Fragrance, Stearamide MEA, Polysorbate 80, Phenoxyethanol, Methylparaben, Butylparaben, Propylparaben, Stearyl Imidazoline, Cetearyl Alcohol, Dimethicone, FD&C Yellow #5.
http://www.folica.com/shampoos/haskplacenta.htm
Hask Perm-Aid® Revitalizing Treatment
Special care for permed hair, also for chemically damaged and extremely abused hair.
Price: US$3.95 Package: 2.5 oz (70.94 grams) Item No.: P8216 Availability: **discontinued** recommend Perm-Aid No Rinse Conditioning Treatment
This product had been discontinued by the manufacturer, we recommend Perm-Aid® No Rinse Conditioning Treatment, which is more potent!
http://www.folica.com/shampoos/haskpermaid_revtre.htm
Part No : 1227 Description : Hask Placenta Treat.Vial 24/unit
This product is in stock, and will ships in one to two business day. If the order is received before 1:00 pm Pacific Time, usually ships on same business day.
http://www.beautycentury.com/mall/stockIS.asp?sku=1227
HASK PLACENTA products are leaders in the Deep Conditioner segment of Hair Care. Henna-n-Placenta Pacs are #13 in Unit Sales of ALL conditioners and #1 of all DEEP conditioners in the Drug Class*. Hask Placenta Instant Hair Repair, with No-Rinse treatment, is a top-10 unit seller*. National Media Support drives the brand and Hask’s strong professional heritage has consumer recognition.
http://www.ecrm-epps.com/Expose/V4_7/Table_Profiles/Alleghany.html
BSE INQUIRY
Use of Bovine offal in Cosmetics;
http://collections.europarchive.org/tna/20081105233036/http://www.bseinquiry.gov.uk/files/yb/1990/02/01004001.pdf
http://web.archive.org/web/20040625033734/www.bseinquiry.gov.uk/files/yb/1990/02/01007001.pdf
6. Information on the transfer of spongiform encephalopathies indicates that the risks from parenternal exposure are greater than orally; though the transfer through intact skin is probably unlikely, the effect of a cut or abrasion to the skin is unknown. ...
http://web.archive.org/web/20030516061153/http://www.bseinquiry.gov.uk/files/yb/1990/01/26018001.pdf
http://collections.europarchive.org/tna/20080102164040/http://www.bseinquiry.gov.uk/files/yb/1990/01/29001001.pdf
http://web.archive.org/web/20030526094945/http://www.bseinquiry.gov.uk/files/yb/1990/01/29015001.pdf
http://web.archive.org/web/20030515204421/http://www.bseinquiry.gov.uk/files/yb/1990/01/31014001.pdf
*** (Third paragraph: The wording of this paragraph will raise NEW concerns which cannot be scientifically answered. We would ask that the third paragraph be OMITTED.)
http://collections.europarchive.org/tna/20081105233038/http://www.bseinquiry.gov.uk/files/yb/1990/01/31014001.pdf
NOT FOR PUBLICATION
http://collections.europarchive.org/tna/20080102164021/http://www.bseinquiry.gov.uk/files/yb/1991/06/00005001.pdf
(there may still be some strange products administered by injection that are trying to _evade_ the Medicines Act by calling themselves cosmetics. If _any_ of those involve bovine ingredients, they need to _comply_ with the CSM guidelines)...
http://collections.europarchive.org/tna/20080102164014/http://www.bseinquiry.gov.uk/files/yb/1991/07/25003001.pdf
http://collections.europarchive.org/tna/20081105233044/http://www.bseinquiry.gov.uk/files/yb/1991/06/26003001.pdf
http://web.archive.org/web/20030529120226/http://www.bseinquiry.gov.uk/files/yb/1991/06/30001001.pdf
http://collections.europarchive.org/tna/20080102164053/http://www.bseinquiry.gov.uk/files/yb/1991/10/15002001.pdf
http://collections.europarchive.org/tna/20080102164025/http://www.bseinquiry.gov.uk/files/yb/1991/10/31009001.pdf
BSE110/1 0180
RUMINANT-DERIVED MATERIAL IN COSMETICS
The Department of Health wishes to reinforce the advice given to the Cosmetics Industry in February 1990 (ref.)
It is possible that some ruminant-derived materials are being incorporated into cosmetics or beauty treatments which are then marketed as 'natural products.
The particular materials that should not under _ANY_ circumstances be used in the manufacturer of cosmetics or beauty treatments are:
1. bovine (cattle)-derived offals, or proteins derived from these offals. These offals are: brain, spinal cord, spleen, thymus, tonsils, intestines of Bovine offal (prohibition) regulations
2. ovine (sheep)-derived offals and ovine placenta.
In view of the current uncertainty about the incidence of infection with spongiform encephalopathy agents it is probably advisable that these recommendations apply to the above ruminant-derived materials of ANY COUNTRY OF ORIGIN...
31 October 1991
91/10.31/9.1
It also emerged from the 16- volume report of Lord Phillips, released on Thursday, that people who bought anti-aging cream may have exposed themselves to BSE unwittingly.
The report describes their use as “a potential pathway to infection” because some creams may have included cattle brain placenta.
http://www.sesahs.nsw.gov.au/albionstcentre/infection_control/newsletter6.htm
A CONSIDERATION OF THE POSSIBLE HAZARD OF GELATIN TO MAN IN RELATION TO THE TRANSMISSION OF BSE
http://collections.europarchive.org/tna/20080102120826/http://www.bseinquiry.gov.uk/files/sc/seac13/tab07.pdf
Subject: BSE aka MAD COW DISEASE AND TOPICAL APPLICATIONS COSMETICS (cuts/abrasions etc.)
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Wed, 12 Sep 2001 16:51:36 -0700
Content-Type: text/plain
Parts/Attachments: text/plain (257 lines)
Reply
######## Bovine Spongiform Encephalopathy
Greetings everyone,
since the debate on this ended abruptly, i thought some might be interested in the following;
TOSS =====
DOA 18
Cosmetics
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73. On 29 January 1990 Dr Pickles sent a minute to Dr Singh, copied to Mr Love and Mr Maslin. Dr Pickles referred to a conversation about Dr Singh’s draft letter to Mr Roscoe, and stated:[73]
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But I think application to broken skin is getting rather close to parenteral administration. Together with problems of policing the 6 month limit, and the fact that the ‘benefit’ from such material is so dubious, I would prefer to see a complete ban.’
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75. On 29 January 1990 Mr Sloggem replied to Mrs Shersby’s minute of the same date. He said:[75]
“1. The advice from Dr Fielder seems fine to me. There could be a problem with abraded skin providing a route of entry. Spleen and placenta could well have high titres, assuming the analogy with scrapie holds good. Sourcing abroad would seem the sensible thing to do. Some tissues may have higher titres earlier than brain tissue eg gut, hence these are best avoided from British sources.
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“… the line taken on cosmetics including sourcing from overseas was based on that given for licensed medicinal products by a group that included Drs Kimberlin, Watson and Will, as well as other MAFF officials. There is no question that the UK is an “infected area”: the only question is whether other countries should be included too. The Licensing Authority, quite reasonably in my view, feels they can only insist on sourcing in countries where there is no evidence of BSE and the veterinary service and reporting system is adequate to detect it were it present. Most manufacturers of mainline pharmaceuticals are not risking having to change sources yet again and so are looking to Australasia. If the CVO thinks he has enough evidence, say concerning the USA, to persuade the CSM, CDSM etc to advise more strongly against sourcing there too, he should present that evidence in a convincing form and in writing. I do not see this as a matter for our group, since there are statutory responsibilities under the Medicines Act. What we should do is ensure consistent advice is given for those borderline products (like these “cosmetics” with medicinal claims) that currently fall outside that Act.”
http://www.bse.org.uk/dfa/dfa18.htm
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136. On 25 July 1991, Dr Pickles replied to Mr Murray’s request. She agreed that the geographical aspects needed updating. She said ‘[the] background briefing is not really appropriate in that form (it was not something I had intended should have gone to DTI in any case).’ She also suggested that it could be pointed out that there were potential concerns:[142]
‘* for workers in the cosmetic industry who may be exposed frequently to these materials, especially if inoculation injuries might occur and
* those who by repeated application particularly to thinned, scarified or diseased skin might absorb material including infective agent that way, also
* there may still be some strange products administered by injection that are trying to evade the Medicines Act by calling themselves cosmetics. If any of those involve bovine ingredients, they need to comply with the CSM guidelines.’
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‘I have the feeling we are far too remote from the industry to make meaningful comments. Contacts via DOH/DTI do not inspire me with confidence. I would advise we need to know what bovine materials are really used in cosmetics and for what purposes. We either need to send someone into the industry (as I did for tripe, casings and rennet) or have a closer contact via the trade association. I am not satisfied yet that the industry is ‘in the clear’ and it is us that may shoulder some blame if it is later found ladies are rubbing cow brain or placenta on to their faces. It may not be our job but if we have any responsibility we need to get at the facts.’
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‘Cosmetics
3. In February 1990 the Department of Health wrote to the Department of Trade and Industry, following a request for advice on the safety of using extracts of bovine offal in certain cosmetics. Placenta is used for its supposed anti-ageing properties. Gangliosides, spleen and thymus may also be used, although there is no firm knowledge on this.
4. DTI issued advice to the industry, via the Trade Association, to the effect that even though the risks were remote it would be prudent to reformulate these products or source from countries free from BSE. In this context it was agreed at the Tyrrell committee meeting on 28 June that DTI would be reminded that since BSE had been found in other countries their guidance to cosmetic manufacturers needed to be updated.
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‘MK and JS said that the cosmetics of concern can be divided into two – 10% expensive ‘exotica’ which could contain the particular tissues of concern to DH such as cerebrocides, placenta (either human or other animal) and 90% are the routine products, many of which are based on collagen, elastin and gelatin. …
MK explained that the French cosmetics industry was soon to hold discussions with their Department of Health and it was likely that the use of placental material, particularly human, would be discontinued in any cosmetics. The main producers of ‘exotica’ were French and American, the products very expensive and therefore the companies would have the resources to ensure the safety of their products by safe sourcing eg from Australasia where there is no scrapie and no BSE. Small UK manufacturers would not be producing products containing animal materials but would rely on vegetable materials. They were not thought to be likely to be incorporating materials of concern, and this was also true for those producers of ‘natural’ products who would not necessarily be members of the CTPA.’
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The delegation thought that cosmetic products applied to the mucous membranes or around the eyes were the most dangerous.
http://www.bse.org.uk/dfa/dfa18.htm
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Subject: Use of Materials Derived From Cattle in Human Food and Cosmetics [Docket No. 2004N-0081] RIN 0910-AF47
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Thu, 17 Apr 2008 12:46:56 -0500
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Subject: CHINA TO START IMPORTING COSMETICS FROM COUNTRIES WITH BSE
From: "Terry S. Singeltary Sr."
Reply-To: Bovine Spongiform Encephalopathy
Date: Sun, 1 Apr 2007 13:05:42 -0500
Volume 7 Medicines and Cosmetics 8. Cosmetics and toiletries Introduction Exotica Standard topical products Collagen implants How the issue was handled
8.1 In this chapter we consider the Government's response to the risks posed by the use of bovine material in cosmetics. Cosmetics, as defined by the Cosmetics Products (Safety) Regulations 1996, include:
any substance or preparation intended to be placed in contact with any part of the external surfaces of the human body (that is to say, the epidermis, hair system, nails, lips and external genital organs) or with the teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance, protecting them, keeping them in good condition or correcting body odours except where such cleaning, perfuming, protecting, changing, keeping or correcting is wholly for the purpose of treating or preventing disease. 1
8.2 Cosmetics using bovine materials fell into three categories: (i) products using lightly treated high-risk bovine offals: 'exotica'; (ii) standard topically applied products using heavily processed bovine by-products; and (iii) implants using bovine collagen.
Exotica
8.3 Concern about a risk of possible BSE contamination focused mainly on those cosmetic products commonly described as 'exotica'. These included 'premium priced facial skin care products' such as certain anti-ageing and anti-wrinkle creams. There was no ban on the use in them of animal material such as 'cellular extracts' that was deemed an unacceptable risk in food and medicines, and accordingly proscribed under the food safety and medicines safety legislation. Such material might be only lightly processed or simply chilled. Possible ingredients identified relatively early on were gangliocides extracted from the brain; and placental material, spleen and thymus. 2
Standard topical products
8.4 Although never considered a serious risk, questions were also raised about how to ensure the safety of more standard cosmetic products. These included the full range of topically applied cosmetics, ie, creams and toiletries applied to the skin, lips and eyelids, and included soaps, skin creams, shaving sticks and stick deodorants. Many of these used heavily processed bovine by-products such as collagen, elastin, gelatine and tallow derivatives. 3
Collagen implants
8.5 Concern was also expressed about bovine collagen used in implants. Although not mentioned in the highly condensed minutes of the CSM/BSC meeting of 2 November 1988, Dr Pickles's own note at the time records that this came up at the meeting as an area of concern: 'Some collagen implants of bovine origin as used by cosmetic clinics are not even licensed.' 4 Collagen products intended for correction of contour deficiencies of the skin were considered licensable under the Surgical Materials Order SI 1971 No. 1276. DH has told us that although collagen implants might have been used for 'cosmetic' reasons, this would have been under medical supervision as they were 'prescription only' medicines. 5
How the issue was handled
8.6 Although specifically identified in the Tyrrell Report in June 1989 as a small-scale user that might not be covered by the regulations and guidelines then in place, 6 the cosmetics industry was not itself the subject of advice or guidance until February 1990.
8.7 In January of that year Mr Richard Roscoe of the Department of Trade and Industry (DTI), the Department with policy responsibility for the safety of cosmetics, had on his own initiative asked DH for advice about the risk from BSE associated with the use of bovine offal in certain cosmetics. 7 DH's advice was that although the risk of transmission of BSE was remote, it would be prudent to reformulate, or source bovine material from cattle reared outside the British Isles. 8 DTI passed this advice on to the cosmetics industry trade association, the Cosmetics, Toiletries and Perfumery Association (CTPA), which in turn informed its members. 9
8.8 SEAC considered the use of bovine material in non-food products generally in June 1991. 10 By that time, BSE had been identified in countries other than the UK, and it was suggested that the advice issued to the cosmetics industry in February 1990 should be updated to take this into account. Updated advice was not sent to the CTPA until April 1992. 11
8.9 One approach that was considered within DH was the introduction of a voluntary ban on bovine materials from countries in which cases of BSE had been reported. Such a ban, if it were to be introduced, would have to be implemented at EU level, so as not to fall foul of European law. The question of BSE and cosmetics was therefore taken forward in the EC Working Party on Cosmetics (ECWPC). Progress at EC/EU level was slow; by the end of October 1994 the Scientific Committee on Cosmetology (SCC) had produced only an interim statement suggesting that material from animals with the potential to transmit infectious agents should not be used in the manufacture of cosmetics. 12 In February 1995 the ECWPC decided that the existing Cosmetics Directive did not need alteration. 13 This decision was based in part on assurance by COLIPA, the European cosmetics trade association, that its members were following certain approved basic precautions on a voluntary basis. 14
8.10 When, in March 1996, the EU ban on the export from the UK of bovine products destined for use in cosmetic, medicinal and pharmaceutical products was introduced, 15 the CTPA conducted a survey of its members and reported that almost all had been using non-UK-sourced bovine material for some time. 16
8.11 In the sections that follow we look first at the regulatory framework on cosmetics safety, which was markedly different from that on either food or medicinal products safety. The sponsoring Department for the industry, which was also responsible for its regulation, was DTI. As we shall see, there was some confusion at various points in the sequence of events about the respective responsibilities of DTI and DH for minimising risks to human health from the production and use of cosmetic products.
8.12 In the final section of the chapter we review some lessons that emerge from the way BSE was handled.
http://web.archive.org/web/20010218202403/http://www.bseinquiry.gov.uk/report/volume7/chapter8.htm#416223
Volume 7 Medicines and Cosmetics 8. Cosmetics and toiletries Regulatory framework Enforcement DTI handling of cosmetics DH's role in cosmetics safety
8.13 The regulation of cosmetics is based on the EU Cosmetics Directive (1976), which was implemented in the UK by regulations made under the Consumer Protection Act 1987. Under this system, cosmetic products must meet various safety requirements, but, unlike medicinal products, they do not require a licence.
8.14 The Cosmetics Directive seeks to ensure the safety of cosmetics and their unhindered trade throughout the EU. In relation to safety, Article 2 provides:
Cosmetic products put on the market within the Community must not be liable to cause damage to human health when applied under normal conditions of use. 1
8.15 Dr Robin Fielder of DH told us that the Cosmetics Directive places the onus on manufacturers and suppliers to ensure that the product is safe for the use intended. 2
8.16 Member States have a duty to 'take all necessary measures to ensure that only cosmetic products which conform to [the Directive] may be put on the market'. 3 The Annexes to the Cosmetics Directive list substances that must not be used in cosmetics and substances whose use is regulated. They also contain lists of substances ('the prescribed lists') permitted for certain uses (preservatives, colourants, sun screens) and only these substances may be used for those purposes in cosmetic products. 4 The prescribed lists may be amended following consideration by the European Commission's Cosmetic Products Working Party, which consists of representatives from the Member States and the industry. DTI led for the UK on this with DH also having a role. The final decision is taken by the Committee on the Adaptation to Technical Progress, which is chaired by the Commission and consists of representatives from Member States. Both the Working Party and the Commission have access to the opinions of the Scientific Committee on Cosmetology (SCC), an independent multidisciplinary body of scientists appointed by the Commission to assess the safety of cosmetics ingredients, as well as to advice from their own national scientific advisers. 5
8.17 The Cosmetics Directive limits the action individual Member States can take to regulate cosmetics. 6 If a product complies with the relevant Annex, the UK Government cannot prohibit its use unless, on the basis of a 'substantiated justification', it represents a hazard to health. 7
8.18 Regulations made, in part, under section 11 of the Consumer Protection Act 1987 give effect to the Cosmetics Directive in UK law. The Cosmetic Products (Safety) Regulations 1984 (made under a predecessor of the Act) were replaced on 1 January 1990 by the Cosmetic Products (Safety) Regulations 1989 ('the 1989 Regulations').
8.19 The main provisions of the 1989 Regulations are as follows: 8
1.A cosmetic product shall not be liable to cause damage to human health when it is applied under normal conditions of use (reg. 3(1)). 2.No cosmetic product may contain any substance listed in column 2 of Schedule 1, unless it is only a trace that could not reasonably have been removed during or after manufacture (reg. 4(2)). 3.A cosmetic product must not contain any substance listed in column 2 of Schedule 2 unless specified requirements in that schedule are satisfied (reg. 4(3)). 4.The Secretary of State may authorise the use in a cosmetic product of any substance not listed in either schedule 1 or 2 (reg. 5(1)). In giving authorisation the Secretary of State may impose conditions relating to the use of the substance (reg. 5(2)). 5.There are various conditions and standards for labelling and packaging (reg. 6).
8.20 The Consumer Protection Act imposes a general safety requirement on all consumer goods. Section 10 of the Act makes it an offence to supply consumer goods that fail to comply with the general safety requirement. For this purpose, consumer goods fail to comply with the safety requirement if they are not reasonably safe having regard to all the circumstances. 'Safe' means that there is no risk (apart from one reduced to a minimum) that the goods will (whether immediately or later) cause death or personal injury to any person. 9
8.21 The Cosmetics Directive and the 1989 Regulations left only limited scope for the application of section 10 of the Act. Since the introduction of the General Product Safety Regulations 1994 10 there has been virtually no scope for its application.
8.22 In practice informal contact and voluntary cooperation played an important part in the regulation of the cosmetics industry.
Enforcement
8.23 DTI had policy responsibility for the safety of cosmetics in the UK. Day-to-day enforcement of safety regulations such as the 1989 Regulations fell to the trading standards departments of local authorities. 11
8.24 Supplying consumer goods that failed to comply with the general safety requirement or with certain requirements of safety regulations was an offence and punishable in the courts. 12
8.25 In addition, enforcement authorities (which for these purposes meant DTI and the trading standards departments of local authorities) had power to serve a suspension notice prohibiting the person on whom it was served from supplying goods for up to six months; power to apply to the court for a forfeiture order; 13 and power for an authorised officer of the enforcement authority to enter any premises, inspect any goods, or examine any procedure, or in appropriate circumstances to seize and detain goods. 14
8.26 The Secretary of State also had the power to serve a notice on a person prohibiting the person from selling consumer goods if the Secretary of State considered them to be unsafe (a prohibition notice), or requiring the person to publish a warning about such goods (a notice to warn). 15 However, these powers applied only to the person on whom the notice was served or against whom the order was sought, rather than to a general category of goods, and no power existed to recall products under these provisions. 16
8.27 DTI told us that it was unaware of any instance in which these powers had been used in respect of a BSE risk in cosmetics. 17
DTI handling of cosmetics
8.28 Within DTI overall responsibility for the safety of cosmetics lay with the Consumer Safety Unit (CSU). Within the CSU, the Chemical Hazards Section (CHS) had day-to-day responsibility for cosmetics. 18
8.29 Mr David Jones, a Grade 5 official, was Head of the CSU until 1995. Mr Roscoe, a Grade 7 official, was Head of the CHS from 1983 to 1992, with specific responsibility for ensuring the safety of cosmetics sold in the UK. 19 He was succeeded by Mr John Walker. Mrs M L Payne, a Higher Executive Officer in the CSU from 1990, was responsible for developing policy on regulation covering chemicals, including ingredients used in cosmetics. 20
8.30 The CTPA was the peak representative body for the UK cosmetics industry and the channel through which DTI distributed cautionary guidance on BSE to cosmetics manufacturers.
DH's role in cosmetics safety
8.31 Although DTI had overall regulatory responsibility for cosmetics, DH also played a role as DTI's adviser on toxicity. 21 The relevant Division in DH was MED TEP (Medical Toxicology Environmental Protection), 22 later evolving into the HEF M (Health Aspects of Environment and Food Medical), 23 which would give advice when necessary.
8.32 Mr Roscoe told us that whenever the CHS was alerted to the presence of a potentially 'risky' ingredient in a particular cosmetic product it would refer the matter to DH. 24 Upon receipt of advice from DH, the CHS would then decide on a course of action. According to Mr Roscoe, DTI would always act on this advice 'unless there were very strong reasons for not doing so'. 25
8.33 Mr Roscoe also told the Inquiry that he believed that when DH encountered a new risk it was its responsibility to pass on the information to DTI. 26
8.34 The DH adviser on toxicology over the period of concern was Dr Fielder, who was assisted by Dr Dewhurst (1988-90), Dr Gott (1991-93) and Ms Mulholland (1993-97). 27
http://web.archive.org/web/20010218200336/http://www.bseinquiry.gov.uk/report/volume7/chapteg2.htm
COSMETICS-further reading from the inquiry on this subject;
http://web.archive.org/web/20010218201247/http://www.bseinquiry.gov.uk/report/volume7/chapteg3.htm
http://web.archive.org/web/20010218201548/http://www.bseinquiry.gov.uk/report/volume7/chaptef4.htm
http://web.archive.org/web/20010624184106/http://www.bseinquiry.gov.uk/report/volume7/chapted5.htm
http://web.archive.org/web/20020328132354/http://www.bseinquiry.gov.uk/report/volume7/chapteb6.htm
http://web.archive.org/web/20010624172330/http://www.bseinquiry.gov.uk/report/volume7/chapteb7.htm
http://web.archive.org/web/20010624184940/http://www.bseinquiry.gov.uk/report/volume7/chaptea8.htm
Volume 7: Medicines and Cosmetics 8. Cosmetics and toiletries 1997/98
8.145 Although outside the period covered by the Inquiry, it is of interest to note the Cosmetics Directive was subsequently amended by Commission Directive 97/1/EC on 10 January 1997 to prohibit the use in cosmetics of:
Bovine, ovine and caprine tissues and fluids from the encephalon, the spinal cord and the eyes, and ingredients derived therefrom. 1 8.146 The Cosmetics Directive was further amended by Commission Directive 98/16/EC on 5 March 1998 to prohibit the use in cosmetics of: 2
(a) the skull, including the brain and eyes, tonsils and spinal cord of: - bovine animals aged 12 months, - ovine and caprine animals which are aged over 12 months or have a permanent incisor tooth erupted through the gum; (b) the spleens of ovine and caprine animals and ingredients derived therefrom. However, tallow derivatives may be used provided that the following methods have been used and strictly certified by the producer: - Transesterification or Hydrolysis at at least: 200ºC, 40 bars (40,000 hPa) for 20 minutes (glycerol and fatty acids and esters); - Saponification with NaOH 12 M (glycerol and soap); - Batch process: at 95ºC for three hours, or - Continuous process: at 140ºC, two bars (2000 hPa) for eight minutes or equivalent conditions.
http://web.archive.org/web/20010218200025/http://www.bseinquiry.gov.uk/report/volume7/chapteri.htm
http://web.archive.org/web/20020328151016/http://www.bseinquiry.gov.uk/report/volume7/chapte10.htm
8.227 These matters stretch well beyond our remit. However, it appears to us, as it did to the Tyrrell Committee, that cosmetics were indeed a potential pathway for pathogens, and that not enough was known about this. Future occasions could arise when, as with BSE, there needs to be a means of turning off the tap at source, rather than catching droplets downstream. Consideration might usefully be given to what powers and processes would assist this.
http://web.archive.org/web/20030702111440/http://www.bseinquiry.gov.uk/report/volume7/chapter9.htm
http://web.archive.org/web/20020328140201/http://www.bseinquiry.gov.uk/report/volume7/chapteh2.htm
http://web.archive.org/web/20010218201146/http://www.bseinquiry.gov.uk/report/volume7/chapteh3.htm
9.63 Mr Bradley replied by letter dated 17 June 1990 to Dr Pickles's letter of 11 June. He stated in relation to A1d:
I have not got far with this. Where do fetal calves, placenta and uteri go and are any uses made of lymph nodes? Cosmetics, ointments, oils, indeed anything that is used on the skin (it could have a lesion) could presen an increased hazard. I have some concern over mesenteric lymph nodes though they are not eaten, though DOH/MAFF agreed earlier there was no need to include them in the offal ban. This is one to discuss in Committee. 34
I understand that there is concern on the Tyrrell Committee recommendation A1d on pharmaceuticals and cosmetics. This has never been considered a primary responsibility of MAFF although collaboration with the principals (DOH and industry) was anticipated.
I suspect the VMD approach will be to avoid or selectively reduce use of bovine tissues in medicinal products for animals. Presumably the authorities responsible for human medicinal products and cosmetics have taken similar action. 35
http://web.archive.org/web/20010624174011/http://www.bseinquiry.gov.uk/report/volume7/chapteg4.htm
(iii) Non-food uses of bovine material. The Committee asked for a note on the use of bovine material for cosmetics in particular, although it might make sense to cover all the non-food uses that we can think of (harp strings, tennis rackets etc). I think that all that is required is a factual note about the range of uses, and quantities, together with an assessment of possible risk factors. It looks to me like a job for Dr Pickles. 1
http://web.archive.org/web/20010624170118/http://www.bseinquiry.gov.uk/report/volume7/chaptee5.htm
http://web.archive.org/web/20010218184950/http://www.bseinquiry.gov.uk/report/volume7/chaptec6.htm
http://web.archive.org/web/20010624181038/http://www.bseinquiry.gov.uk/report/volume7/chaptec7.htm
http://web.archive.org/web/20010624173202/http://www.bseinquiry.gov.uk/report/volume7/chapteb8.htm
http://web.archive.org/web/20030506095053/http://www.bseinquiry.gov.uk/report/volume7/chaptea9.htm
Annex 2 to Chapter 9: Uses made of the cattle carcass
Item Products derived Additional comments
HEAD
Brain Human food Laboratory reagents Veterinary medicines Pharmaceuticals Cosmetics
http://web.archive.org/web/20010218201535/http://www.bseinquiry.gov.uk/report/volume7/glossary.htm
http://web.archive.org/web/20020328150145/http://www.bseinquiry.gov.uk/report/volume7/whoswho.htm
http://web.archive.org/web/20010624175300/http://www.bseinquiry.gov.uk/report/volume7/index.htm
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http://web.archive.org/web/20010221160108/http://www.bseinquiry.gov.uk/report/volume7/volume73.htm
http://web.archive.org/web/20030907100258/www.bseinquiry.gov.uk/report/volume7/volume74.htm
http://web.archive.org/web/20010221160018/http://www.bseinquiry.gov.uk/report/volume7/volume75.htm
4.4 On 10.1.90 I attended the second meeting of the CSM BSE Working Party. The discussions which took place and the conclusions reached can be found in the Minutes of the meeting [YB 90/1.10/1.1-1.24]. I provided comments to Dr Singh in Med TEH on his draft letter to DTI which responded to a request for advice on the safety of the use of bovine offal (in particular, spleen and thymus) in cosmetics [YB 90/1.29/1.1-1.2]. My briefing notes were used to accompany the reply to DTI [YB 90/2.1/4.1]. I indicated I was not happy about the use of bovine offal from calves under 6 months in cosmetics (in contrast to foods) because on damaged skin such use could be close to parenteral administration so the nearest parallel might be injectable medicines. Besides there were no compensating benefits.
57. April 1990
57.1 The formation of SEAC was announced by Mr Gummer on 3.4.90 [YB 90/5.24/4.1-4.2]. As requested, I supplied comments on the draft Agenda prepared by Mr Lowson for SEAC's first meeting [YB 90/4.6/4.1-4.3] and I supplied a list of documents to accompany the formal papers for background information. I offered to put together a discussion paper on bovine eyeballs and the use of bovine material in cosmetics. This draft paper entitled Routes of Possible Transmission into Man was later sent to Mr Lowson for comment [YB 90/4.12/1.1-1.4]. It met with the approval of Mr Lowson but it was not submitted to SEAC at that time as CVO indicated he thought a more detailed paper was needed [YB 90/4.24/3.1-3.2 and see YB 90/4.23/1.1].
http://www.bse.org.uk/witness/htm/stat115.htm
http://www.telegraph.co.uk:80/et?ac=003789727059657&rtmo=weoeinKb&atmo=rrrrrrrq&pg=/et/96/9/7/wbse07.html
http://www.telegraph.co.uk:80/et?ac=003789727059657&rtmo=weoeinKb&atmo=rrrrrrrq&pg=/et/99/11/2/nbse02.html
http://www.telegraph.co.uk:80/et?ac=003789727059657&rtmo=weoeinKb&atmo=rrrrrrrq&pg=/et/00/10/29/nbse129.html
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BSE Inquiry report criticises ex-Tory ministers
Sat, Sep 2, 2000 PA News
Conservative former ministers and Whitehall officials face strong criticism in the official report into the BSE crisis, it was reported tonight. The inquiry chairman Lord Phillips is believed to have notified several former health and agriculture ministers that they are facing criticism in the 13-volume report he is to publish in a few weeks.
Reports in several Sunday newspapers suggested the former ministers would be taken to task for being "too adamant" in their assurances that British beef was safe, and for failing to react swiftly enough to scientists' findings that the disease could spread to humans. Scientists first suspected that there was a risk to humans eating BSE-infected offal in the mid-80s, but it was not until March 1996 that Tory ministers admitted that there was a danger to the public.
But the ex-ministers could come off lightly compared with senior civil servants who ran the two departments as the decade-long saga unfolded.
Lord Phillips' two-year inquiry is said to have concluded that too much importance was attached to the interests of the livestock industry, and not enough to those of consumers. The BSE affair led to a worldwide ban on British beef exports which is estimated to have cost the taxpayer 4.6 billion.
Comment (webmaster): It is unclear why the judge released the findings prior to publication. What purpose is served anyway with polite criticism (1, 2) of long-departed political figures and retired civil servants? Keith Meldrin, who masterminded the coverup within MAFF for 10 years, also receives a wrist-slap for a leading role in 82 human deaths. His successor at MAFF who continued these abominable policies was forced into retirement this year but given a handsome 400,000 pound retirement package. MAFF itself has spent 7 million pounds of public money on lawyers even and successfully fought the Inquiry practise of publishing fulltext of government memos on the Internet.
However, these documents can still be obtained in print form. Terry S. Singeltary Sr. of Bacliff, Texas, has obtained many of the documents alluded to in the Inquiry but never released. These have been optically character read into electronic form and distributed to the German BSE listserve archive as well as to this web site:
BSE offals used in cosmetics, toiletry and perfume industry
Sun, 3 Sep 2000. Unpublished Inquiry documents obtained by CJD activist Terry S. Singeltary Sr. of Bacliff, Texas
Miss Marion Kelly Cosmetic, Toiletry and Perfumery Association 35 Dover Street London W1X3RA
Department of Trade and Industry 10-18 Victoria Street London SW1H ONN Enquiries 01-215 5000 Telex 8811074 DTHQ G 01 215 3324 1 February 1990
Dear Marion
As you know there is no record of bovine spongiform encepalopathy crossing to humans, but we need to take precautions to avoid any risk.
There a number of cosmetric products on sale in the United Kingdom such as anti-ageing creams that contain extracts of bovine offal, primarily from spleen and thymus. [Two of the highest risk tissues. Note the epidemic has been raging for 4 years by the time of the non-binding voluntary suggestions here. -- webmaster]
The purpose of this letter is to ask you to ask your members to eliminate any risk by reformulating such products to eliminate these extracts, or alternatively to use material derived from cattle reared outside the UK, Eire or the Channel Islands. [Eire, Channel Islands, and many other countries were thoroughly infected by then -- webmaster]
Please let me know if you have any trouble persuading your members to do so.
Yours sincerely
R J ROSCOE CONSUMER SAFETY UNIT ROOM 407
90/02.01/14.1 ==============
BSE110/1 0080
DEPARTMENT OF HEALTH AND SOCIAL SECURITY HANNIBAL HOUSE Room No ELEPHANT AND CASTLE LONDON SE1 6TE
1 February 1990
Mr R Roscoe Consumer Affairs Department of Trade and Industry 10-18 Victoria Street London SW1
Dear Richard
USE OF BOVINE OFFAL IN COSMETICS
I am replying to your request for advice on the safety of the use of extracts of bovine offal in certain cosmetics, such as skin products claimed to have 'anti-ageing' properties with respect to bovine spongiform encephalopathy (BSE). As you are aware there are a number of cosmetic products on sale in the UK that contain small amounts of such extracts, primarily from spleen and thymus.
We accept that the risk of transmission is likely to be remote, but believe that it would be prudent to eliminate any risk by reformulating such products. Alternatively if the incorporation of bovine extracts is retained, material derived from cattle reared outside the UK, Eire or the Channel Islands should be used.
We would be grateful if you would transmit these recommendations to industry via the Trade Association CTPA.
I attach background briefing prepared by medical colleagues from those sections most involved with consideration of BSE in DH, together with a copy of the Southwood report.
Please let me know if you need any further information.
Yours sincerely DR R J FIELDER Enclosure 90/2.1/7.1 ===========
BSE110/1 0081
BACKGROUND BRIEFING
Presence of Bovine Offals in Cosmetics and Bovine Spongiform Encephalopathy
(1) Extracts of bovine spleen and thymus are present at between ca 0.1 and 5% in certain cosmetic preparations, for example certain products claimed to delay the signs of ageing of skin. The concern about the increasing incidence of BSE in cattle in the UK has made it necessary to reconsider the safety of such products.
BSE is a progressive neurological disorder in cattle, which results from infection with an "unconventional viral' agent. The first case was described in cows in 1986. By 19 January 1990 there had been 9436 confirmed cases in the UK on 5474 farms. There are no confirmed cases outside the British Isles, apart from a case in a cow recently exported from England. BSE is one of a family of spongiform encephalopathies which also include scrapie in sheep and kuru and Creutzfeldt Jakob disease (CJD) in man. The infection which leads to BBE appears to have been introduced into cattle from the contaminated feeding stuff, meat and bone meal, made partly from sheep offal: scrapie is endemic in sheep in the UK.
The causative agents of these diseases are thought to be unconventional transmissible agents (referred to variously as prions, virinos, filamentous viruses or slow viruses). They are extremely resistant to most denaturing processes eg heat, UV, high salt concentration, formalin and alkylating agents. The current DH guideline for treating items used on CJD patients is a temperature of 134-138 C (at 2 atmospheres) held for 18 minutes. They are also not removed by normal microbiological filters. It is thus unlikely that the mild processing techniques used to obtain the extracts used in cosmetics would remove the causative agents.
(2) Government action to date includes:
a. An expert working party was set up under Sir Richard Southwood and reported in February 1989. All their recommendations have been acted upon.
b. The disease has been made notifiable in cattle.
c. All suspect animals are slaughtered and carcases destroyed (50% compensation policy but 100% if diagnosis not confirmed); milk from such animals is also destroyed.
d. Sale or supply of animal protein from ruminants for feeding to ruminants prohibited - hopefully to prevent any new infections in cattle. This has had a major effect on the rendering industry.
e. Another committee was set up under Dr David Tyrrell to report on research needs. An interim report was published in January 1990 together with an announcement about additional funding. Much research work into the disease is currently in progress and additional studies are being planned.
Regulations in November 1989 introduced a ban on various bovine offal for human consumption, going wider than the Southwood recommendations which were for such a ban to affect baby food only.
The Medicines Control Agency have gathered information from pharmaceutical companies about use of bovine ingredients in parenteral pharmaceuticals and issued interim guidelines. Many biological products and vaccines use such ingredients. The MCA are considering whether action on specific products is appropriate.
h. The Health and Safety Executive (HSE) is reviewing its guidance to those who come into direct contact with bovine 'risk' tissues. A press release for those who handle BSE carcases has been issued and one for abattoir workers is in preparation. The HSE ara also discussing risks from BSE exposure with the veterinary profession.
i. All UK cases of CJD will be monitored in a study to be conducted by Dr R G Will in Edinburgh, funded by the Department of Health: this should allow detection of any spread of infection to hummans, although this possibility is considered remote.
(3) Current live issues
Research: Dr Tyrell's interim report identified a large research programme classed as high priority. Almost all of this research falls to MAFF {Central Veterinary Labs} or the AFRC, although the MRC also has an interest. Substantial money has been made available for this work but research will be laborious and results will come slowly.
Food: There has been constant pressure on MAFF about the supposed risk to humans from eating beef and beef products. Infected animals who are incubating the disease but do not show any abnormalities cannot be detected at present and will be entering the human food chain. The offal ban removes the highest 'risk' tissues. Some critics may not be satisfied by this. However, others may argue the action to date is over the top, not demanded by the experts, and illogical since scrapie-infected sheep can still be eaten and doing so for the last 200 years has not caused harm to humans. We expect BSE agent to be resistant to irradiation as applied to food, as well as relatively resistant to cooking.
Other animals: There is no evidence that animals other than cattle (and domesticated, deer) have been or could be affected by BSE, other than experimentally, but there are pressures to extend the ruminant protein ban: at present pigs and poultry receive this sort of feed. Such action, as well as being hard to justify scientifically, would increase costs for the industry and cause perhaps insurmountable problems for abattoirs, who would find renderers no longer willing to accept offal. Many 1000's of tons of offal need to be disposed of daily.
Compensation: This has been set at 50% for BSE, although for some other diseases it is higher. Some critics believe this encourages evasion, with cows affected minimally being sent for human consumption. Even the current level of compensation is proving expensive for MAFF.
Exports: Some foreign countries have banned British exports of seman, embryos and livestock. The EC now no longer accepts live cattle over 6 months of age. The Germans are creating difficulties over beef exports too. The EC are also considering making BSE notifiable and banning ruminant protein feeding to rminants, as we have done here. At present, British meat and bone meat can still be exported and might spread infection overseas (MAFF claim importers have been warned that it is not regarded suitable for feeding to ruminants).
Human transmission: There are some in the media and even the medical profession who are trying to make connections between BSE and the human disorder CJD. There is _no_ evidence of any association nor would we expect any cases by now even were BSE to be transmissible to humans. Dr Wills' study (see 2i above) will monitor the situation for the next decade or two.
I have been asked to provide a draft reply to the attached letter from Sir Richard Southwood to the Minister. The Minister has indicated that we must meet Sir Richard's points (a} on the need for him to be fully briefed as to developments and (b) on the urgency of making progress with the transmission study.
On (a), I would suggest that the draft reply should indicate that you will be in touch with Sir Richard regularly to keep him in the picture. On (b), I hope we can now tell Sir Richard that the arrangements for the purchase and relocation of the animals are under way.
A R Cruickshank 20 June 1989 Mr A J Lawrence AH cc Mr K C Meldrum Dr W A Watson Mr R C Lowson 89/6.20/8.1
http://www.mad-cow.org/00/sep00_news.html#aaa
update
http://europa.eu.int/comm/food/fs/sc/ssc/out109_en.html
http://europa.eu.int/comm/food/fs/sc/ssc/out80_en.pdf
P.S. -- one must consider 'accumulation' of agent over time. ...
2009
To date the OIE/WAHO assumes that the human and animal health standards set out in the BSE chapter for classical BSE (C-Type) applies to all forms of BSE which include the H-type and L-type atypical forms. This assumption is scientifically not completely justified and accumulating evidence suggests that this may in fact not be the case. Molecular characterization and the spatial distribution pattern of histopathologic lesions and immunohistochemistry (IHC) signals are used to identify and characterize atypical BSE. Both the L-type and H-type atypical cases display significant differences in the conformation and spatial accumulation of the disease associated prion protein (PrPSc) in brains of afflicted cattle. Transmission studies in bovine transgenic and wild type mouse models support that the atypical BSE types might be unique strains because they have different incubation times and lesion profiles when compared to C-type BSE. When L-type BSE was inoculated into ovine transgenic mice and Syrian hamster the resulting molecular fingerprint had changed, either in the first or a subsequent passage, from L-type into C-type BSE. In addition, non-human primates are specifically susceptible for atypical BSE as demonstrated by an approximately 50% shortened incubation time for L-type BSE as compared to C-type. Considering the current scientific information available, it cannot be assumed that these different BSE types pose the same human health risks as C-type BSE or that these risks are mitigated by the same protective measures.
http://www.prionetcanada.ca/detail.aspx?menu=5&dt=293380&app=93&cat1=387&tp=20&lk=no&cat2
I ask Professor Kong ;
Thursday, December 04, 2008 3:37 PM Subject: RE: re--Chronic Wating Disease (CWD) and Bovine Spongiform Encephalopathies (BSE): Public Health Risk Assessment
''IS the h-BSE more virulent than typical BSE as well, or the same as cBSE, or less virulent than cBSE? just curious.....''
Professor Kong reply ;
.....snip
''As to the H-BSE, we do not have sufficient data to say one way or another, but we have found that H-BSE can infect humans. I hope we could publish these data once the study is complete.
Thanks for your interest.''
Best regards,
Qingzhong Kong, PhD Associate Professor Department of Pathology Case Western Reserve University Cleveland, OH 44106 USA
END...TSS
P02.35
Molecular Features of the Protease-resistant Prion Protein (PrPres) in H-type BSE
Biacabe, A-G1; Jacobs, JG2; Gavier-Widén, D3; Vulin, J1; Langeveld, JPM2; Baron, TGM1 1AFSSA, France; 2CIDC-Lelystad, Netherlands; 3SVA, Sweden
Western blot analyses of PrPres accumulating in the brain of BSE-infected cattle have demonstrated 3 different molecular phenotypes regarding to the apparent molecular masses and glycoform ratios of PrPres bands. We initially described isolates (H-type BSE) essentially characterized by higher PrPres molecular mass and decreased levels of the diglycosylated PrPres band, in contrast to the classical type of BSE. This type is also distinct from another BSE phenotype named L-type BSE, or also BASE (for Bovine Amyloid Spongiform Encephalopathy), mainly characterized by a low representation of the diglycosylated PrPres band as well as a lower PrPres molecular mass. Retrospective molecular studies in France of all available BSE cases older than 8 years old and of part of the other cases identified since the beginning of the exhaustive surveillance of the disease in 20001 allowed to identify 7 H-type BSE cases, among 594 BSE cases that could be classified as classical, L- or H-type BSE. By Western blot analysis of H-type PrPres, we described a remarkable specific feature with antibodies raised against the C-terminal region of PrP that demonstrated the existence of a more C-terminal cleaved form of PrPres (named PrPres#2 ), in addition to the usual PrPres form (PrPres #1). In the unglycosylated form, PrPres #2 migrates at about 14 kDa, compared to 20 kDa for PrPres #1. The proportion of the PrPres#2 in cattle seems to by higher compared to the PrPres#1. Furthermore another PK–resistant fragment at about 7 kDa was detected by some more N-terminal antibodies and presumed to be the result of cleavages of both N- and C-terminal parts of PrP. These singular features were maintained after transmission of the disease to C57Bl/6 mice. The identification of these two additional PrPres fragments (PrPres #2 and 7kDa band) reminds features reported respectively in sporadic Creutzfeldt-Jakob disease and in Gerstmann-Sträussler-Scheinker (GSS) syndrome in humans.
http://www.neuroprion.com/pdf_docs/conferences/prion2007/abstract_book.pdf
Monday, October 19, 2009
Atypical BSE, BSE, and other human and animal TSE in North America Update October 19, 2009
http://bse-atypical.blogspot.com/2009/10/atypical-bse-bse-and-other-human-and.html
14th International Congress on Infectious Diseases H-type and L-type Atypical BSE January 2010 (special pre-congress edition)
18.173 page 189
Experimental Challenge of Cattle with H-type and L-type Atypical BSE
A. Buschmann1, U. Ziegler1, M. Keller1, R. Rogers2, B. Hills3, M.H. Groschup1. 1Friedrich-Loeffler-Institut, Greifswald-Insel Riems, Germany, 2Health Canada, Bureau of Microbial Hazards, Health Products & Food Branch, Ottawa, Canada, 3Health Canada, Transmissible Spongiform Encephalopathy Secretariat, Ottawa, Canada
Background: After the detection of two novel BSE forms designated H-type and L-type atypical BSE the question of the pathogenesis and the agent distribution of these two types in cattle was fully open. From initial studies of the brain pathology, it was already known that the anatomical distribution of L-type BSE differs from that of the classical type where the obex region in the brainstem always displays the highest PrPSc concentrations. In contrast in L-type BSE cases, the thalamus and frontal cortex regions showed the highest levels of the pathological prion protein, while the obex region was only weakly involved.
Methods:We performed intracranial inoculations of cattle (five and six per group) using 10%brainstemhomogenates of the two German H- and L-type atypical BSE isolates. The animals were inoculated under narcosis and then kept in a free-ranging stable under appropriate biosafety conditions.At least one animal per group was killed and sectioned in the preclinical stage and the remaining animals were kept until they developed clinical symptoms. The animals were examined for behavioural changes every four weeks throughout the experiment following a protocol that had been established during earlier BSE pathogenesis studies with classical BSE.
Results and Discussion: All animals of both groups developed clinical symptoms and had to be euthanized within 16 months. The clinical picture differed from that of classical BSE, as the earliest signs of illness were loss of body weight and depression. However, the animals later developed hind limb ataxia and hyperesthesia predominantly and the head. Analysis of brain samples from these animals confirmed the BSE infection and the atypical Western blot profile was maintained in all animals. Samples from these animals are now being examined in order to be able to describe the pathogenesis and agent distribution for these novel BSE types. Conclusions: A pilot study using a commercially avaialble BSE rapid test ELISA revealed an essential restriction of PrPSc to the central nervous system for both atypical BSE forms. A much more detailed analysis for PrPSc and infectivity is still ongoing.
http://www.isid.org/14th_icid/
http://ww2.isid.org/Downloads/IMED2009_AbstrAuth.pdf
http://www.isid.org/publications/ICID_Archive.shtml
14th ICID International Scientific Exchange Brochure -
Final Abstract Number: ISE.114
Session: International Scientific Exchange
Transmissible Spongiform encephalopathy (TSE) animal and human TSE in North America
update October 2009
T. Singeltary
Bacliff, TX, USA
Background:
An update on atypical BSE and other TSE in North America. Please remember, the typical U.K. c-BSE, the atypical l-BSE (BASE), and h-BSE have all been documented in North America, along with the typical scrapie's, and atypical Nor-98 Scrapie, and to date, 2 different strains of CWD, and also TME. All these TSE in different species have been rendered and fed to food producing animals for humans and animals in North America (TSE in cats and dogs ?), and that the trading of these TSEs via animals and products via the USA and Canada has been immense over the years, decades.
Methods:
12 years independent research of available data
Results:
I propose that the current diagnostic criteria for human TSEs only enhances and helps the spreading of human TSE from the continued belief of the UKBSEnvCJD only theory in 2009. With all the science to date refuting it, to continue to validate this old myth, will only spread this TSE agent through a multitude of potential routes and sources i.e. consumption, medical i.e., surgical, blood, dental, endoscopy, optical, nutritional supplements, cosmetics etc.
Conclusion:
I would like to submit a review of past CJD surveillance in the USA, and the urgent need to make all human TSE in the USA a reportable disease, in every state, of every age group, and to make this mandatory immediately without further delay. The ramifications of not doing so will only allow this agent to spread further in the medical, dental, surgical arena's. Restricting the reporting of CJD and or any human TSE is NOT scientific. Iatrogenic CJD knows NO age group, TSE knows no boundaries. I propose as with Aguzzi, Asante, Collinge, Caughey, Deslys, Dormont, Gibbs, Gajdusek, Ironside, Manuelidis, Marsh, et al and many more, that the world of TSE Transmissible Spongiform Encephalopathy is far from an exact science, but there is enough proven science to date that this myth should be put to rest once and for all, and that we move forward with a new classification for human and animal TSE that would properly identify the infected species, the source species, and then the route.
http://ww2.isid.org/Downloads/14th_ICID_ISE_Abstracts.pdf
Wednesday, March 31, 2010
Atypical BSE in Cattle
http://bse-atypical.blogspot.com/2010/03/atypical-bse-in-cattle-position-post.html
Tuesday, March 16, 2010
COMMONWEALTH OF AUSTRALIA Hansard Import restrictions on beef FRIDAY, 5 FEBRUARY 2010 AUSTRALIA
COMMONWEALTH OF AUSTRALIA
Proof Committee Hansard
RRA&T 2 Senate Friday, 5 February 2010
RURAL AND REGIONAL AFFAIRS AND TRANSPORT
[9.03 am]
BELLINGER, Mr Brad, Chairman, Australian Beef Association
CARTER, Mr John Edward, Director, Australian Beef Association
CHAIR—Welcome. Would you like to make an opening statement?
Mr Bellinger—Thank you. The ABA stands by its submission, which we made on 14 December last year, that the decision made by the government to allow the importation of beef from BSE affected countries is politically based, not science based. During this hearing we will bring forward compelling new evidence to back up this statement. When I returned to my property after the December hearing I received a note from an American citizen. I will read a small excerpt from the mail he sent me in order to reinforce the dangers of allowing the importation of beef from BSE affected countries. I have done a number of press releases on this topic, and this fellow has obviously picked my details up from the internet. His name is Terry Singeltary and he is from Bacliff, Texas. He states, and rightfully so:
You should be worried. Please let me explain. I’ve kept up with the mad cow saga for 12 years today, on December 14th 1997, some four months post voluntary and partial mad cow feed ban in the USA, I lost my mother to the Heinemann variant Creutzfeldt-Jakob disease (CJD). I know this is just another phenotype of the infamous sporadic CJDs. Here in the USA, when USA sheep scrapie was transmitted to USA bovine, the agent was not UK BSE—it was a different strain. So why then would human TSE from USA cattle look like UK CJD from UK BSE? It would not. So this accentuates that the science is inconclusive still on this devastating disease. He goes on to state:
The OIE— the International Organisation of Epizootics, the arm of the WTO— is a failed global agent that in my opinion is bought off via bogus regulations for global trade and industry reps. I have done this all these years for nothing but the truth. I am a consumer, I eat meat, but I do not have to sit idly by and see the ignorance and greed of it all while countless numbers of humans and animals are being exposed to the TSE agents. All the USA is interested in is trade, nothing else matters.
Even Dr Stanley Prusiner, who incidentally won the Nobel Health Prize in 1997 for his work on the prion—he invented the word ‘prion’, or it came from him—states:
The BSC policy was set up for one purpose only, trade—the illegal trading of all strains of TSE globally throughout North America, which is home to CBSC, IBSC and HBSC, many scrapie strains and two strains of CJD to date. (please note typo error, those should have read cBSE, lBSE, and hBSE...tss)
I would also like, while I have the opportunity, to explain the beef-off-the-shelves myth. At the first Senate hearing on 14 December, it was explained that the reason why they allowed BSC beef into Australia was the beef-off-the-shelves policy, whereby if we found a case of BSC in Australia they would have to recall all—
Friday, 5 February 2010 Senate RRA&T 3
RURAL AND REGIONAL AFFAIRS AND TRANSPORT
Senator HEFFERNAN—Which of course is total BS.
Mr Bellinger—Correct. This is written in the FSANZ document—Food Standards Australia New Zealand. Why isn’t this same policy in New Zealand? It is not—it is only in Australia. We are the only country in the world to have this idiotic policy. So we again call for the tabling of the WTO obligations paperwork. We do not believe that exists.
snip...see full text 110 pages ;
http://www.aph.gov.au/hansard/senate/commttee/S12742.pdf
for those interested, please see much more here ;
http://docket-aphis-2006-0041.blogspot.com/2010/03/commonwealth-of-australia-hansard.html
http://transmissiblespongiformencephalopathy.blogspot.com/
Thursday, July 08, 2010
Nosocomial transmission of sporadic Creutzfeldt-Jakob disease: results from a risk-based assessment of surgical interventions Public release date: 8-Jul-2010
http://creutzfeldt-jakob-disease.blogspot.com/2010/07/nosocomial-transmission-of-sporadic.html
Thursday, July 08, 2010
GLOBAL CLUSTERS OF CREUTZFELDT JAKOB DISEASE - A REVIEW 2010
http://creutzfeldt-jakob-disease.blogspot.com/2010/07/global-clusters-of-creutzfeldt-jakob.html
TSS
