January 6, 2004
BSE - it sounds like the truth, but there is a problem here
updated 1/09/04 See end of article.
There is an article in today's NY Times that is well worth reading With Diseased Animals, Disposal Isn't Simple.
(Please see addendum at the end of this Uncommon Thought post).
Denise Grady discusses the difficulty in destroying the piron that causes BSE (mad cow disease). It goes on to talk about a plan to utilize a tissue digestor, and then the remains could be utilized as fertilizer. I think it is interesting that there is finally an admission in the mainstream press about how difficult it is to destroy the causative agent of BSE. I also think it is twisting the truth to say that this "digestor" will render such remains safe.
The Times article goes on to discuss that the Agriculture Department favors "digestion" as a way to destroy the contaminated tissue. The patent for this process for tissue digestion is held by a company called WR2. However, the prion involved in BSE and vCJD appears darn near indestructable. Will WR2's process destroy the prion?
Well, the company claims by that their process WR2 that claim that their process "Converts animal, human, and microbial tissues into a sterile, neutral, aqueous solution suitable for disposal to a sanitary sewer." This process utilizes"alkaline hydrolysis" in a sealed vessel to raise the internal temperature to about 250 degrees for a period of three hours. Supposedly, this sterilizes the remains. Patrick Condon at Twin Cities.com discusses the process as being used with a variety of different infected tissues (Iowa lab tests for BSE).
But does it sterilize the remains?
The Andean Community (CAN) apparently isn't satisfied - CAN broadens prohibition against imports that could open the way to "mad cow disease".
According to a May 16, 2002 report OPINION AND REPORT ON : THE TREATMENT OF ANIMAL WASTE BY MEANS OF HIGH TEMPERATURE (150°C, 3 HOURS) AND CORRESPONDING HIGH PRESSURE ALKALINE HYDROLYSIS. by the Scientific Steering Committee from the European Commission on Health & Consumer Protection
BACKGROUND AND MANDATE Commission Services received a submission and accompanying dossier from a commercial company requesting endorsement of a process for the safe disposal of animal waste which may be contaminated by TSEs. This process consists of a treatment of animal waste by means of high temperature (150°C, 3 Hours) and corresponding high pressure alkaline hydrolisis.Scientific Steering Committee (SSC) was requested to address the following questions:
1. Can the treatment of animal waste, as described by the dossier, be considered safe in relation to TSE risk? Can the liquid residues be considered safe in relation to TSE risk?2. Can the by-products resulting from this treatment (i.e. ash of the bones and teeth of vertebrates ) be considered safe in relation to TSE risk?
It is not in the remit of the SSC to endorse specific commercial products and processes. This opinion therefore relates only to the nature of the process as it relates to possible human health and environmental risks. The opinion does not address practical issues such as economics and potential throughput of carcasses/tissues.
The SSC appointed a rapporteur to address the mandate in a scientific report to be discussed by the TSE/BSE ad hoc Group. This report, amended in the light of the discussions by the TSE/BSE ad hoc Group on 2 May 2002, is attached.
OPINION
1. Regarding the first question of the mandate the SSC concludes that the liquid residue after a 3-hour digestion cycle could retain infective potential. Under controlled laboratory conditions in a single experiment the treatment of animal waste by means of high temperature (150°C, 3 Hours) and corresponding high pressure alkaline hydrolysis has been shown to reduce the infectivity of TSE/BSE by a factor of 103.5 – 104.5.No infectivity was found after 6 hours. This may indicate that the clearance after 6 hours processing time is higher than after 3 hours. However, these experiments can only give a measure of the minimum clearance possible and do no permit to exactly quantify the clearance factor after 6 hours.
Regarding the second question of the mandate, the SSC concludes that, on the basis of the data available, by-products of the 3-hour process could carry a risk of BSE/TSE infectivity and that this risk may decrease with the duration of processing.
The SSC refers to the attached report for some comments on the experimental
conditions, which were considered when drawing the above conclusions.2. The possible human BSE exposure risk under field conditions not only depends on the maintenance of the efficiency of the equipment during processing, but also on factors such as: the probability that a TSE-infected animal is processed, the type of material processed (e.g., carcasses as compared to by-products and waste from animals that tested negative for BSE), the relationship between effectiveness and throughput and workplace control and environmental protection measures. The consideration whether or not the inactivation capacity of a process is effective must take fully into account such
factors. The SSC opinion of 24-25 June 1999 on “Fallen Stock” provides some further guidance on which materials should be disposed of and which ones could possibly be recycled for certain uses1."
However, even if this process does seem to work, there is another concern - dioxins:
a) chlorophenols, dioxins and other polychlorinated hydrocarbons One of the principal public concerns about the incineration of animal waste is dioxin generation. It is appropriate therefore to consider whether the WR2 process might also generate toxic chemicals. Research has shown (for example: Wikstom & Marklund, 2001) that chlorophenols, dioxins, etc are formed under a number of conditions of relevance to the proposed process i.e.: - in the presence of weak to strong alkali; - at process temperatures in excess of 150° (particularly (250-400°); - in the presence of chloride and/or organochlorine compounds.Chloride is of course a common element in animal tissues. Since the proposed
process conditions involve a strong alkali and a temperature of 150°C, the extent of the possible formation of chlorophenols, dioxins and other chlorinated
hydrocarbons needs to be investigated. According to WR2 (2001) the process
does not generate detectable emissions of dioxins5, furans, SO2 or NOx, however no details of what else was looked for, nor of sensitivity limits are available in WR2 (2001)."
Their conclusion?
"The process appears to cause a very substantial reduction of BSE/TSE infectivity but after 3 hours does not result in complete destruction of TSE/BSE. From the experiments conducted by Somerville (2002) a reduction of infectivity after 3 hours of between 103.5 and 104.5 seems likely. No infectivity was found after 6 hours. The experimental set-up does however not permit to exactly quantify the clearance factor after 6 hours. One problem in interpreting the data in this study is that it is difficult to explain why in the study the highest dilution samples showed the greatest infectivity. It is important to resolve this question."
Just how tough is the BSE prion? Amazingly tough.
Biology of BSE and Related Disorders:
"Chemical disinfectants (e.g. domestic bleach), weak acids, DNAase, RNAase, proteinases (including those found in the animal gut), ultraviolet light, ionising radiation, heat (cooking tempertures), and chemicals that react with DNA (psoralins/UV light, hydroxylamine, zinc ions), all have little effect on the infectivity of the agent. High temperature autoclaving (135 degrees centegrade for 18 minutes) decreases the infectivity dramatically, as does the use of 1M NaOH, but neither will fully destroy the agent, as it has been found to remain infective after 360 degrees C for 1 hour or even after incineration. Internment of infective tissue in the soil for three years did not destroy the agent. Some phenols and proteases will decrease the infectivity of the agent but not to an adequate degree to be of value in disinfection.
Prevention of TSEsNosocomial CJDs should be prevented by prohibiting CJD, GSS, or Alpers disease patients (or those with obscure neurological conditions) from becoming blood or tissue donors, by the incineration or high temperature autoclaving of all materials that came into contact with blood, or post mortem tissue from such a patient, and by the disposal of all surgical instruments used for brain surgery on such a patient. The body should not be used for teaching anatomy or surgery. Correct action to be taken concerning BSE infected herds is currently under intense discussion."
In other words, the commission is leary of the effectiveness of the WR2 process in elimiating the BSE prion.
The prion seems virtually indestructable as is noted in the following sources:
The WellnessWise Journal (reprint 1996) by David J. DeRose, MD, MPH, who states:
"The prions differ from those similar normal proteins, however, in their three dimensional shape. Prions seem to cause disease by coming into contact with those normal proteins and then stimulating them to change their shape to mimic the prion protein. This change in shape appears to set up a chain reaction. Normal proteins change their shape to look like the prion proteins and then later influence neighboring proteins to do the same. The end result is a progressively devastating and ultimately fatal disease. No treatment has yet been discovered.Making the picture even bleaker is the resiliency of prions. They are not destroyed by the usual means used to kill infectious agents. They are resistant even to boiling at temperatures as high as 250 degrees Celsius (well over 400 degrees Fahrenheit). They are also resistant to ionizing radiation. "
Note that the temperature here is over 250 degrees (C) - well above the 150 degrees (C) that the WR2 process utilizes.
So what does it all mean?
1. The prion involved in BSE is very difficult, if not impossible to destroy.
2. The UK killed over 1.5 million cattle, it is unkown how the US will handle its outbreak.
3. The US favors utilizing the WR2 process and then using the remains as fertilizer. This is apparently what they are doing with other contaminated tissues at this time, including (one assumes) the herd of sheep that was killed because of suspected scrapies (the sheep form of BSE and suspected as a possible contaminating sources causing bovine BSE).
4. So these potentially contaminated remains could end up broadcast across the country as fertilizer, or even back in the animal food supply (bone meal).
5. Even if the process does work, a by-product is highly toxic dioxins. Given the amount of remains likely needing "digestion" this could cause a huge environmental problems with dioxin disposal. Remember the evacuation and destruction of Times Beach, Missouri (see resource links below)?
Don't you think it might be time to be asking the FDA, USDA, and our elected representatives some tough questions?
Excellent Resource Links
Re: Prions not destroyed by incineration?
Guardian/UK archive of BSE articles and resports
BSE risk in bones and blood used in meats , Lawrence, Guardian/UK, 5/22/03)
Times Beach, Missouri
Dioxin Poisoning Caused by Improper Waste Disposal in Missouri
Addendum - Snafu at the NY Times
I ran into a problem when I started to write this article. I had found the article by Denis Grady last night at the NY Times online for 1/06/04. However, this morning, the link took me to a totally different article. I thought that maybe I had screwed up the link so I went to the Times online and there was the same title link. I clicked it and it took me to a "replacement" article (Human Mad Cow Toll Up). I called the Times and was passed through a variety of people until I got to "James" who would not give me his last name. James said, that "he would check it out." When I asked how I would be able to followup, he said check the online version in about an hour.
I did check back and guess what? The original article is back. I guess that sometimes it helps to complain!
Addendum
I also posted the article at Correspondences. The Chairman of the Board of WR2 wrote a response. Below is Dr. Kaye's response and my response to that.
Name: Dr. Gordon I. Kaye
Email Address: gkaye@wr2.net
URL: http://www.wr2.net
Comments:
Dear Dr. Wolf:
No one in the scientific or regulatory communities has ever minimized the difficulty of destroying the agents that cause TSE. Unfortunately, your commendable attempt to emphasize this may do more to confuse the issue than clarify it because it appears to be based largely on incomplete, inaccurate, and out-of-date information.
The WR2 statement that the process “Converts human and microbial tissues into a sterile, neutral, aqueous solution suitable for disposal to a sanitary sewer” is based on extensive validation testing with ALL of the standard indexed agents required for testing for approval of any process for treatment and disposal of regulated medical waste (RMW) in the various states of the United States. In fact, the most rigorous state health department, that of New York, was the first to specifically approve the WR2 Process for RMW treatment based on TOTAL elimination of all of the index organisms tested by an independent laboratory. Subsequently, every other state health department that has undertaken or required validation studies has also approved the process, following the same demonstration of TOTAL destruction of all the organisms tested. Also, the process is carried out at 150º Celsius (approx. 302º Fahrenheit), not 250º F as noted in your article. Further, I am unaware of any testing done at any Iowa lab as there is no installed WR2 unit in Iowa nor could any reference to the Patrick Condon citiation be found at Twin Cities.com.
I have no idea what a reference to the Andean Community (CAN), a group of countries in Central and South America, banning US meat imports after the report of one BSE infected cow in Washington State has to do with the validation of the WR2 Process for any use.
The most unfortunate incomplete and out-of-date information in your article, however, refers to the opinion and report of the Scientific Steering Committee of the European Union Commission on Health and Consumer Protection. The Opinion and Report you cite was superceded by two subsequent reports in which errors in that report that were identified by WR2 and Waste Reduction by Waste Reduction Europe, Ltd. (WRE) were corrected and some of the non-scientific and bizarre questions and conclusions, such as the reference to the possible generation of dioxins in an aqueous solution1 were answered or removed. The Final Opinion and Report was published only in April 2003 and specifically recommended approval of the WR2 Process for use for treatment and disposal of Category 1 animal byproducts, i.e., highly infectious materials and materials contaminated with BSE. In fact, the final regulations for use of the process are currently being edited and, when the text is approved by the 15 member Council, will take on the force of law in the EU.
The quotation from the “Biology of BSE and Related Disorders” (no citation presented) is interesting and potentially informative general information but has NO RELATIONSHIP TO THE CONCLUSION DRAWN FROM IT BY YOU THAT “In other words, the commission is leary [sic!] of the effectiveness of the WR2 Process in eliminating the BSE prion”. As noted immediately above, contrary to what you state, the Commission recommended approval of the WR2 Process for treatment of Category 1 animal byproducts.
We regret that your access to incomplete and inaccurate information led you, in your commendable zeal to try to clarify an issue with which many people who do not have the background and experience in the field have recently become concerned, to write the article without checking with the primary sources concerned. We would have been happy to direct you not only to the correct information had you contacted us but to several experts in the elimination of prion infectivity who could have provided you with additional accurate scientific references. We hope you will seek such resources in your future discussion of this and other important health and science matters.
1 The Dioxin question was a particularly glaring, annoying, and expensive canard. It was repeatedly raised by one member of the SSC who had only ever worked with incinerators and did not understand the chemistry of the WR2 Process. Dioxins are produced during oxidation reactions, almost always by burning materials, and at temperatures above 250º C. Dioxins are thus produced by incinerators, crematoria, woodstoves, and fireplaces. They can only be produced by transformation of chlorinated phenolic compounds such as those found in plastics and wood. THERE ARE NO CHLORINATED PHENOLIC COMPOUNDS NATURALLY PRESENT IN ANIMAL TISSUES. The WR2 Process is a reductive process, hence the company name, and takes place in an aqueous solution at 150º C. There is no question that chloride, the element , is present in animal tissue. It is an essential ion in most cellular reactions and essential for maintenance of cellular integrity in animal tissues. If dioxins could be produced in aqueous solutions in boiling water, we would have eliminated human life on earth as soon as we started cooking with salt! Ironically, the authors of the one citation in the dioxin canard, Drs. Wikstrom and Marklund, both indicated to the SSC that their work was done with a fluidized bed incinerator model using a municipal waste sample and that, as chemists, they KNEW that dioxins could not be produced in an aqueous solution. Despite this, WR2 was forced to undertake an extensive and expensive controlled experiment involving analyzing undigested animal tissue, digested animal tissue, and even the water and alkali used in the process for the presence of dioxins. The analyses of the samples produced were carried out by one of only two laboratories in the world with the capability of undertaking precise analysis on such minute quantities of dangerous chemicals which prepared a report for the SSC that proved that NO DIOXINS OR FURANS WERE PRODUCED BY DIGESTING ANIMAL TISSUES WITH THE WR2 PROCESS!
Gordon I. Kaye, Ph.D.
Chairman of the Board
WR², Inc.
My Response to Dr. Kaye
I would like to thank Dr. Kaye for giving such an extensive reply and directing me to the April 10-11, 2003 EU Scientific Steering Committee FINAL OPINION AND REPORT ON : A TREATMENT OF ANIMAL WASTE BY MEANS OF HIGH TEMPERATUR(150°C, 3 HOURS) AND HIGH PRESSURE ALKALINE HYDROLYSIS. http://europa.eu.int/comm/food/fs/sc/ssc/out358_en.pdf.
Let me state a couple of things up front in my response. First, as methods of disposal of contaminated tissue goes, the process used by WR2 appears to be among the best. Also, the updated report from the EU SSC indicates that WR2 has made improvements on its original process to decrease emmissions of toxic gases and liquids. Therefore, the concerns of significant dioxin residues are reduced. Lastly, my concern in writing the original piece was not to demean WR2, but concerns about the overall approach to dealing disposing of BSE (and related agents) contaminated items - including tissue.
For clarity's sake, and as a reference point, let me quote the following from the WR2 website The WR2 Process - http://www.wr2.net/process.htm. The emphases are mine - not WR2's
Automatic Treatment CycleDuring operation, a measured amount of alkali, proportional to the weight of tissue loaded into the basket, is automatically added after the load has been weighed by built-in load cells. Water, also proportional to the weight of the tissue, is then added and the vessel is sealed pressure-tight. The contents are heated while the digestion solution is continuously recirculated. There are no moving parts inside the vessel. High level agitation is provided in the fluid circulating system. Standard digestion cycle time is determined by temperature; approximately 3 hours at 150° C (In emergency situations this time can be reduced substantially). The tissues rapidly dissolve during this heating time and are hydrolyzed into smaller and smaller molecules. The temperature, heating time, and recommended alkali-to-tissue ratios for particular types of loads, selected after extensive laboratory testing, result in a sterile, non-gelling, purple/coffee-colored, slightly alkaline, true solution with a soap-like odor. This solution can be discharged in accordance with local and federal guidelines regarding pH and temperature.*** If KOH is used as the akali, the resulting solution is suitable, after dilution, for direct application as a liquid fertilizer, containing Nitrogen and Potassium, for crop or landscape application.
In examining the EU SSC Final Opinion, I do not see the ringing endorsement that Dr. Kaye implies. The report discusses findings and concerns that linger. Many of their lingering concerns address the difference in potential outcome between small scale, highly controlled, experiments and the use of the technology in a real life environment.
The SSC continues to argue that some degree of TSE/BSE infectivity persists with 3 hours of process ind continues to recommend 6 hours of high pressure (5 bars) high heat processing.
" ... the SSC concludes that, on the basis of the data available, by-products of the 3-hour process could carry a risk of BSE/TSE infectivity and that this risk may decrease with the duration of processing; further data would be needed in order to make a definitive statement. "
They have issues with how levels, throughput and training may vary from experimental contitions:
"The possible human BSE exposure and/or environmental contamination risks under field conditions not only depends on the maintenance of the efficiency of the equipment during processing, but also on factors such as: the probability that a TSE-infected animal is processed, the type of material processed (e.g., carcasses as compared to byproducts and waste from animals that tested negative for BSE), the relationship between
effectiveness and throughput and workplace control, dilution of the possible residual infectivity, and environmental protection measures."
And that release into the human environment is not recommended:
"The consideration whether or not the inactivation capacity of a process is effective must take fully into account such factors, but the SSC nevertheless considers, as a principle, that the release into the environment of residual TSE infectivity should be avoided.
They do not recommend the release of processed materials into sewers as "it must thus be assumed that any residual BSE/TSE material could co-precipitate and hence be accessible to sewer vermin." and further: "On the basis of the above evidence, the SSC considers that for the time being the direct discharge of the liquid residues to the sewer without further treatment is not appropriate."
Further, they do not recommend dispersing the byproducts on the land. They point the reader to an SSC Opinion of June 24-25, 1999. That document http://europa.eu.int/comm/food/fs/sc/ssc/out58_en.pdf states on page 45 that after incineration or alkaline treatment (similar to WR2's) that the waste should be encapsulated in a controlled landfill.
The Conclusions from the Final Opinion are quoted below in full (emphases mine).
IV. CONCLUSIONS
1. The process appears to cause a reduction of BSE/TSE infectivity after 3 hours but does not result in complete destruction of TSE/BSE infectivity. From the experiments conducted by Somerville (2002) a reduction of infectivity after 3 hours of between 103.5 and 104.5 seems likely.No infectivity was found after 6 hours. The experimental set-up does however not permit to exactly quantify the clearance factor after 6 hours. One problem in interpreting the data in this study is that it is difficult to explain why in the study the highest dilution samples showed the greatest infectivity. It is important to resolve this question.
The experiments did not investigate the inactivation for durations between 4 and 6 hours. The data indicate that the process applied for 3 hours it is more effective than the heat/pressure rendering process at 133°C during 20 minutes and at 3 bars which is currently accepted to have a TSE infectivity reduction capacity of approx. 103.0 (EC, 1999). However, such comparisons are problematic because the impact of the rendering refers to the industrial scale process, while the alkaline hydrolysis infectivity reduction study was carried out under laboratory conditions and the equipment was used optimally (supervised by company experts). It may well be the case that, in the field situation, less substantial reductions in infectivity would be achieved using alkaline hydrolysis.
2. Pirnie (2000) states that the levels of 68 priority pollutant semi-volatiles were low and that odour emission was moderate. Recent detailed analysis provided by the company (WR2, 25 June 2002, i.e., after the adoption on 16 May 2002 of the SSC’s previous opinion) have shown that
dioxin in the air could not be detected nor chlorophenols and other polychlorinated hydrocarbons in the residual fluid. Most of the numerous
analysed VOCs were reported to be below the given chemical detection limits. For the compounds detected, most concentrations were below their respective odour thresholds. Nevertheless, the alkaline hydrolysis system could produce air emissions with potential to cause odour impact, especially for some reduced sulphur compounds, some VOCs and amines. Odours should be controlled via appropriate trapping devices or failing this via air ventilation exhaust system. The treatment goal for the waste management facilities exhaust air would be to produce a treated air stream with the concentration of all compounds below their odour threshold concentration prior to discharge to environmental atmosphere.3. Detailed analyses provided by the company shows (1) that dioxins in the air could not be detected nor chlorophenols and other polychlorinated hydrocarbons in the residual fluid of the alkaline process and (2) that the process did not generate dioxins nor polychlorodibenzofurans in the alkaline tissue digest beyond any dioxins possibly already contained in the original animal carcass tissue.
The SSC considers that, although the data were obtained from laboratory scale studies and experiments and the levels of chloride were probably low, the results provide sufficient reassurance that the levels of dioxin release into the environment during dispersal of the digestate are unlikely to constitute a risk.
4. Before the process can be recommended in a substantially scaled up form, measurement of appropriate parameters under actual practical plant conditions is essential. An effective monitoring regimen for the day-to-day performance of the equipment must also be devised.
5. Associated with the process, safe procedures for storage and handling of carcasses to be processed, which may be contaminated with TSE/BSE will need to be identified and implemented. These procedures should include consideration of the issues identified in the Notes of 27 October 2000 of the Scientific Steering Committee on the safe handling, transport and temporary storage of meat-andbone meal which may be contaminated with a BSE agent or other pathogens.
6. On the basis of the evidence available, the liquid residues after process duration of 3 hours retain a significant BSE/TSE infectivity risk [if the starting material contained high levels of infectivity]. They contain also very high BOD and COD values. It is therefore not appropriate to permit their direct discharge to the sewer.
Moreover, from a practical viewpoint the solidification of the hydrolysate on cooling is of concern in respect of the disposal. If hydrolysate is released on a large scale to a sewer in a warm condition without extensive dilution it is likely to precipate. In the absence of data to the contrary it must be assumed that any residual BSE/TSE material could co-precipitate and thence be accessible to sewer vermin.
If it is proposed that the residue is incinerated, hydrochloric acid should not be used as a neutralizing agent since it will facilitate dioxin formation.
As Dr. Kaye noted, "No one in the scientific or regulatory communities has ever minimized the difficulty of destroying the agents that cause TSE."
My concerns are not significantly relieved. In the original NY Times article stated the (US) Agriculture Department favored the treatment proposed by WR2. It then goes on to state (emphases mine):
"The process leaves behind only about 76 pounds of bone and teeth remnants that can be crumbled by hand into bone-meal powder, and 375 gallons of a sterile solution of water containing sugars, soaps and molecules that are the building blocks of proteins. Both the liquid and the powder can be used as fertilizer. The liquid, which the company described as "nonjelling" and "with a soaplike odor," can be safely dumped into a sanitary sewer, the company says. But large volumes of the liquid would need sewage treatment before being released, because the fertilizer content is high enough to cause ecological problems in waterways."
Therefore, while the SSC is recommending encapsulated burial in a contained site, the US seems to be recommending releasing the waste into the sewer system, and/or to be used as fertilizer. This simply does not seem prudent to me. While I do not have access to the final standards and controls, the final vote based on the recommendation of the SSC (as Dr. Kaye notes) "will take on the force of law in the EU." That does not necessarily mean the the US will follow the same standard.
Asides
Dr. Kaye stated that there was no known testing of BSE in Iowa, nor of a disposal system there. The Times article clear refers to testing and disposal in Iowa:
The Agriculture Department uses tissue digestors at its laboratories in Ames, Iowa, and Laramie, Wyo., and the veterinary college at Colorado State University in Fort Collins uses one to destroy the carcasses of deer and elk with chronic wasting disease, the company said. In Florida, the State Anatomical Board operates a digestor at Shands Hospital in Gainesville to dispose of cadavers used to teach anatomy.The digestor in Ames, a 7,000-pound model, was trucked there on an emergency basis in 2001 to destroy more than 50,000 pounds of carcasses from a herd of sheep that the department had seized from a Vermont farm. The sheep, imported from Belgium, were destroyed because health officials suspected they had eaten feed contaminated with tissue carrying mad cow disease. The Ames digestor will be permanently installed sometime early this year, Mr. Wilson said.
---
The Andean Community source -
The press release was included because it discussed the CAN resoulution that it they would not accept import of any products or byproducts capable of spreading BSE. If the US were to approve use of treated BSE tissue as fertilizer, then that ban could impact not just export of fertilizer, but crops on which that fertilizer was used. In other words, by dispersing the treated waste as fertilizer it could dramatically effect the exportablity of US crops.
Where's Upton Sinclair when we need him ?
Posted by: biLL wHITLATCH at January 6, 2004 11:39 AM