HSUS Letter to Secretary Veneman Calling for a Ban on Processing Downed Animals

Secretary Ann Veneman
U.S. Department of Agriculture
1400 Independence Avenue, S.W.
Washington, D.C. 20250

Dear Secretary Veneman:

On behalf of the eight million members and constituents of The Humane Society of the United States (HSUS), the nation’s largest animal protection organization, we urge you to immediately impose a ban on the processing of any “downed animals” for human consumption.

As you know, The HSUS and other animal welfare organizations have long advocated for a ban on transporting downed animals to auctions, stockyards, or slaughterhouses. Once non-ambulatory, these creatures cannot be moved humanely; it is well documented that handlers drag these hapless creatures with chains or push them with bulldozers or forklifts – resulting in undeniable and needless cruelty. The handling of downed animals constitutes one of the most egregious abuses of animals currently permitted in the industrial livestock production system – and that is no small statement in a sector that has become notorious for its insensitivity to even the most basic care standards.

What’s more, we have long warned that the USDA is playing Russian roulette with our food supply by allowing the processing of downed and often diseased animals for human consumption. Studies in Europe reveal that downed cows provided a major pathway for the spread of Bovine Spongiform Encephalopathy (BSE or “mad cow” disease), which has been found in 21 counties on the continent. The “mad cow” recently found in Canada was a downed animal, prompting the president of the Alberta Beef Producers to remark, “Cows too sick to walk, too sick to stand, have no business being part of the food system. This animal should never have left the farm.” In January 2003, USDA wrote in the Federal Register that if BSE does occur in the U.S., it will most likely first be found among downed cattle. According to USDA, downed animals “represent a significant pathway for spread of disease if they are not handled or disposed of with appropriate safeguards.”

For the above mentioned reasons, The HSUS has diligently lobbied Congress to halt the transport and processing of downed animals. In fact, we backed amendments adopted by the House and Senate during consideration of the Farm bill in 2002 to halt the use of downed animals in the food supply. Even though both chambers approved nearly identical bills, the conference committee to the Farm bill struck the provision, calling instead for a report to be conducted on the issue – a report that USDA has failed to complete now more than one year after its due date.

Earlier this year, we lobbied the Senate in support of an amendment by Senator Daniel Akaka (D-HI) to ban any processing of downed animals for human consumption. The Senate passed this amendment, while the House rejected a similar amendment offered by Representative Gary Ackerman (D-NY) by just three votes. Again, a conference committee jettisoned this provision, pending final action by Congress on the Omnibus Appropriations Act in early 2004.

The national scare triggered by the reported BSE case in Washington state could have been considerably mitigated if the United States had adopted the very policy we had long been advocating – no processing of downed animals for human consumption. The BSE-infected Holstein cow should never have made it into a slaughter line and found its way into the American food supply. It happened only because the USDA and the Congress caved in to the unreasonable demands of a segment of the dairy and cattle industries that refuse even the most modest humane and food safety reforms. Such inaction is particularly inexcusable in light of events in Europe and Canada – where we saw the plain identification of BSE pathways through downed animals.

The USDA has rightly adopted a prohibition on allowing downed animals into the National School Lunch program. If that policy should be observed in feeding children at schools, it should be observed for feeding children and adults in domestic and commercial settings, too.

According to USDA, there are any where from 130,000 to 190,000 animals that go down ever year and cannot stand up again and presented for processing at slaughterhouses. According to the best estimates provided by USDA for 1999 - 2001, nearly three quarters of these animals are processed for human food – often on the basis of only a visual inspection at slaughterhouses. Even with the stepped-up emphasis on BSE testing by USDA (approximately 20,000 downed animals this year, according to your remarks yesterday), only 10-15 percent of downed animals are being tested for BSE. In short, inspectors with the Food Safety Inspection Service are making spot visual judgments – with no scientific testing– on whether to allow downed animals to be processed. In its January Federal Register Notice, USDA noted that “downer cattle infected with BSE often cannot be found by looking for the typical clinical signs associated with BSE, because the signs of BSE often cannot be differentiated from the signs of the many other diseases and conditions affecting downer cattle. Thus, if BSE were present in the United States, downer cattle infected with BSE could potentially be offered for slaughter and, if the clinical signs of the disease were not detected, pass antemortem inspection. These cattle could then be slaughtered for human or animal food.”

What’s more, even if a USDA inspector selects an animal for testing, that does not preclude that the animal will be processed for human food before the test result is determined. Indeed, that’s precisely what happened with the Holstein from Washington state. The animal was slaughtered and processed for human food on December 9th, and USDA obtained its first test results from a British lab on December 22nd. The fact is, statements of confidence that the food supply is safe are an expression of personal faith, rather a reflection of sound policy.

In September 2003, a Zogby poll revealed that 77% of likely U.S. voters oppose the use of downed animals for human food, and 81% are concerned that sending downed animals to slaughterhouses could put human consumers at risk for mad cow disease. Reflecting this public concern, restaurants including McDonald’s, Wendy’s, and Burger King have pledged not to use meat from downed animals. Some of the largest livestock markets in the nation, including Empire Livestock in New York and Central Livestock that serves the entire Midwest, have endorsed the removal of downed animals from human food, citing animal welfare and food safety concerns. With the recognition of this problem by some major retail and processing operations, it is reckless and irresponsible for USDA to continue to allow the processing of downed animals for food.

The only possible rationale for continuing this policy is a myopic focus on the economic arguments of individual farmers who claim they will lose revenue if they can’t sell their downed animals to slaughterhouses. As is obvious, this is a false economic equation. It is these farmers and others who will be hurt when prices for beef plummet and export restrictions are imposed upon the news of a finding of a BSE-infected animal here in the United States. What’s more, the program that attempts to manage the processing of downed animals – through inspections and testing (however inadequate it may be) -- is another major cost to taxpayers, as are quarantine enforcement programs and compensation for destroyed herds.

In short, we urge you to impose a permanent ban on the processing of downed animals for human consumption. The adoption of such an emergency rule will undo some of the damage caused by USDA’s ill-advised policy of allowing the processing of downed animals and may prevent future processing of BSE-infected animals for human food.

Sincerely,

Wayne Pacelle
Senior Vice President
Communications and Government Affairs

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Downed Animals

Related Links

HSUS Issues Statement on Announcement of Mad Cow Disease

The HSUS Demands Ban on Processing Downed Animals for Human Consumption

Downed Animal and Food Safety Protection Act