U.S. Government Comments to the Japan Food Safety Commission - April 12, 2005

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April 12, 2005

The government of the United States welcomes the opportunity to comment on the recently concluded report of the Food Safety Commission (FSC), recommending changes to Japan's domestic BSE testing regime. In addition to providing comments below, the government of the United States would like to commend the FSC for its work on this important issue.

The report's conclusion that BSE testing of younger animals is unnecessary for ensuring food safety is particularly welcome. The report recommends changing Japan's domestic BSE testing regime from the current system that requires 100 percent testing of all slaughtered cattle to a new standard that requires testing only for slaughtered cattle over 20 months of age. This is an important step forward in harmonizing Japan's food safety standards with the international practices and OIE guidelines. Nevertheless, the government of the United States would urge Japan to move even further toward harmonization with international practice by raising the minimum age limit for BSE testing from 20 months to 30 months.

In addition to its findings on testing, the report correctly emphasizes two measures that are critically important in reducing the risk of BSE to humans:

1. Proper removal of specified risk materials (SRMs) and
2. Discontinuing the practice of pithing on cattle at slaughter.

These are essential science-based firewalls that provide multiple levels of protection for the consumer.

Scientists around the world agree that some level of testing can be a useful surveillance tool to monitor animal health. The removal of SRMs, however, is the single most important BSE-related action that can be taken to protect public health. Both the United States and Japan have strong, well-established programs in place to ensure that SRMs are removed appropriately.

Proper slaughter practices to prevent SRM contamination are an essential ingredient in ensuring the safety of beef. The report's recommendation to discontinue pithing highlights an issue that may be little-known among the Japanese public but which, even more than testing, must be part of any scientifically proven and effective plan to keep BSE out of the human food supply.

The report also emphasizes the vital importance of an effective feed ban. Prohibiting the inclusion of ruminant protein in cattle feed is critical in protecting against the spread of BSE among cattle. The United States regards this as a key element for our own efforts to counter BSE, and we commend Japan for its efforts to strengthen this safety measure through this review.

The report bases its recommendations on the government of Japan's preliminary findings that two young animals in Japan, aged 21 and 23 months of age, were detected with BSE. It is important to point out, however, that the international scientific community has not yet confirmed these findings. In order to expand scientific knowledge about BSE, it would be helpful to have an international scientific review of these cases. We urge the Government of Japan to share with the international community the results of the ongoing mouse assay confirmation tests of the preliminary findings in these two cases.

Once again, the government of the United States welcomes this opportunity to provide comment to the Food Safety Commission on this important matter, and looks forward to the commission's final approval of the recommendations made in the report. The United States also looks forward to the prompt consideration and completion by the Government of Japan of import procedures that would reopen Japan to beef imports from the United States.