1997 U.S. Animal Health Association Resolutions

TABLE OF CONTENTS

INTRODUCTION



The following resolutions were adopted by the United States Animal Health Association (USAHA) at its convention in October, 1997. Each resolution has two parts, the background and then the resolution itself. After each resolution, you will see "PARA's Comments," an analysis that was prepared by the following members of PARA: Karen Meyer, Ronald Miller, Doug Meyer, Cheryl Miller, and Alan Kennedy.

There are several things that should be brought to your attention before reading these resolutions. First, the resolutions as set forth on this page are those that were ultimately adopted by USAHA. Before these resolutions were ultimately adopted and appear in the form as they now exist, they had been modified several times in the days preceding their vote by the USAHA. In some of PARA's comments that follow each resolution section, references will be made to prior resolutions. This is important from the standpoint of understanding events that led up to the changes that followed.

There were three different sets of resolutions. The first was the "first draft" resolutions of the National Johnes Working Group which were presented to PARA for our input and evaluation after the meeting of the NJWG on Saturday and prior to the meeting on Tuesday of the Committee on Johne's Disease.

The second set of resolutions were the "Committee on Johne's Disease" resolutions which were revisions of the "first draft" resolutions and presented at Tuesday's meeting to the Committee on Johne's Disease for their consideration.

The third set are the "final resolutions" which were adopted by the USAHA and are the resolutions cited in this page.

It should be noted that in the original "first draft" resolutions that were presented to PARA, virtually all of the resolutions contained the following background language:

  "The NAHMS '96 STUDY 'Johne's disease on U.S. dairy operations' showed that 20-40% of U.S. dairy herds are infected with Mycobacterium paratuberculosis and that Johne's disease has a significant economic impact on dairies. When compared to earlier studies on the prevalence of Johne's in the U.S., it appears that the disease is spreading. Adding to concern about Johne's are scientific publications that imply M. paratuberculosis might be a zoonotic pathogen transmissible to humans through food."  


We are very concerned that that language is nonexistent in the resolutions ultimately adopted by USAHA. Were these comments removed because of fears for potential liability after such significant admissions?

RESOLUTION 13

SUBJECT MATTER: Research Funding for Johne's Disease
BACKGROUND: There are numerous biological questions about this infectious disease that remain unanswered. Additionally, there is a desperate need for applied research on Johne's prevention through biosecurity measures, control on infected farms and herd certification program validity and cost effectiveness. Of equal or greater importance is the need to sustain and strengthen the base of academic research on paratuberculosis and to train a new generation of paratuberculosis researchers. USDA funding for paratuberculosis research has been very limited (see attached). In the past five years only two paratuberculosis research grants have been awarded through the USDA-NRICGP Animal Health Program and none have been awarded through the Food Safety Program.
RESOLUTION: USAHA urges the Secretary of Agriculture to place Johne's disease as a high priority for significant levels of intramural (ARS) and extramural research funding through both the USDA-NRICGP Animal Health Program and the USDA-NRICGP Food Safety Program. This priority should be emphasized to members of grant review panels and panel administrators should be advised to insure that this high priority is realized in the final dispersal of funds.

Members of USAHA are urged to seek greater Congressional awareness and support to adequately fund Johne's and Crohn's disease research needs.
PARA'S COMMENTS: Interestingly, the background language indicates there is a "desperate need for applied research....control...herd certification program." Our position is that if Johne's research had not been abandoned in the early '90's, we would not be in a desperate situation at the present time. The fact that a miniscule number of research grants have been awarded to Johne's research is appalling.

In addition, there have been no grants awarded through the Food Safety Program. We would like an explanation of that in light of the fact that grants have been submitted to the Food Safety Program of the USDA, but have been rejected. Specifically, in 1994 there was a grant proposal submitted by R. J. Chiodini and J. Hermon-Taylor entitled "Prevalence of Mycobacterium Paratuberculosis in Retail Dairy Products." This proposal was rejected three times by the panel. Perhaps this time the panel will reconsider its former position.

It is not clearly stated that USAHA is recommending that Congressional funding be given specifically for the relationship between Johne's and Crohn's disease. PARA wants research conducted on the relationship BETWEEN Johne's and Crohn's, not each disease independently.

At first glance, it appears that USAHA has addressed the issue on the zoonotic potential of M. paratuberculosis and Crohn's. But in light of the past positions that all governmental, regulatory and industry entities have taken on this issue, it will be necessary that PARA obtain clarification of this critical point so that we know how to proceed accordingly. Indeed, it will be vitally important that PARA members and the public at large assume the objective of "seeking greater Congressional awareness." We must not rely on others to do that for us.


RESOLUTION 16

SUBJECT MATTER: Pasteurization Standards
BACKGROUND: The NAHMS '96 study "Johne's disease on U.S. dairy operations" showed that 20-40% of U.S. dairy herds are infected with Mycobacterium paratuberculosis and that Johne's disease has a significant economic impact on dairies.

The question of M. paratuberculosis as a zoonotic pathogen remains unresolved. Multiple studies have shown that Mycobacterium paratuberculosis is excreted in the milk of infected cows. There are conflicting studies on whether pasteurization is able to effectively kill this organism. Given this evidence and consumer concerns about food safety, it is vital that the efficacy of pasteurization for killing of M. paratuberculosis be fully evaluated.

ARS pasteurization research has shown the killing of M. paratuberculosis in a laboratory scale pasteurizer does occur, data of which is to be published December 1997.

RESOLUTION: USAHA requests that FDA Food Safety Branch review scientific data on thermal tolerance of M. paratuberculosis and report to the Johne's committee of the USAHA an opinion whether current pasteurization standards are sufficient to insure completely killing of M. paratuberculosis in raw milk.
PARA'S COMMENTS: This resolution is nothing more than a smoke screen for the real issue: "Is M. paratuberculosis in our retail milk?" There are several points we must address on this resolution. It should be noted that the first draft of this resolution presented by the NJWG to PARA, stated: "USAHA requests that pasteurization standards be evaluated to determine if they insure complete killing of M. paratuberculosis in raw milk, and adjust those standards accordingly if necessary, provided any revised pasteurization process will maintain the quality of the finished product." In other words, they were willing to evaluate pasteurization and adjust the standards if necessary. But if by adjusting those standards, it meant that the milk didn't taste good anymore, then the process would not be revised. Having a good-tasting product was apparently more important than if it was making people sick. We vehemently objected to that language, and no doubt as a result of our objections, that language was deleted from the resolutions presented by the Committee on Johne's Disease. Hopefully that language will not be a consideration again in the future.

  1. In the background information there is an obvious omission of "Crohn's disease" being the target of this zoonotic pathogen.

  2. The only way to know whether pasteurization is really working is by testing the retail milk supply. There are many studies, conducted by experienced food science researchers (Grant and Ball at Queens University, etc.) which have demonstrated that M. paratuberculosis DOES survive HTST pasteurization. In fact, there is only one study which has shown conclusively that pasteurization does kill M. paratuberculosis, and that is the one by Judith Stabel, an immunologist. ALL of the other published studies say that M. paratuberculosis can survive HTST pasteurization. It should also be noted that despite the fact that the study by Dr. Stabel is scheduled for publication in December, 1997, it was an unpublished study up to that point in time, yet it is the standard the USDA and FDA have used to determine the efficiacy of pasteurization, apparently giving no credence to the published studies to the contrary which were and are at their disposal.

  3. The resolution requests that FDA review the scientific data. First of all, if USDA has not even considered this issue important enough to address in the past as evidenced by the rejection on three occasions by the Food Safety Program of USDA of the grant proposal submitted by Chiodini and Hermon-Taylor in February, 1994, entitled "Prevalence of Mycobacterium Paratuberculosis in Retail Dairy Products" (see Resolution 13), then why would FDA seriously consider this request?

  4. The issue is given such low priority that FDA is requested to give an opinion to the Johne's Committee of the USAHA, a committee that does not meet again until October, 1998. Given the seriousness of the potential for human disease, immediate measures should be undertaken by all governmental entities, including USDA and FDA. This is merely passing the buck for yet another year.

    In summary, this resolution is merely perpetuating more controversy, postponing the dreaded retail supermarket testing, in hopes that the problem will disappear. It won't. For every day that this question awaits an answer, 100 people in the U.S. will be diagnosed with Crohn's disease. Up to 2,000,000 people already suffering from I.B.D. in the U.S. may possibly have their symptoms exacerbated by consumption of contaminated dairy products. How epidemic does this problem need to be before our officials take notice?


RESOLUTION 9

SUBJECT MATTER: Reallocation of Resources
BACKGROUND: USDA-APHIS-VS has an excellent track record in disease control programs as evidenced by bovine tuberculosis, bovine brucellosis and pseudorabies in swine. If comparable efforts in time, effort and money are invested in Johne's disease, this disease too can be controlled.
RESOLUTION: USAHA urges USDA to budget funds for Johne's disease control efforts similar to past peak funding of tuberculosis, brucellosis and pseudorabies.
PARA'S COMMENTS: If M. paratuberculosis research had not been abandoned in the early '90's in favor of other research, this disease could have already been controlled. Given the zoonotic potential of M. paratuberculosis which USDA and agricultural interests were fully aware of at the time those decisions were made, we must question why Johne's disease was not considered a priority for peak funding "in addition to" the other diseases rather than virtually ignoring it.


RESOLUTION 10

SUBJECT MATTER: Symposium on Johne's Disease
BACKGROUND: Education efforts are considered top priority by the National Johne's Working Group. Under the concept of amplification of knowledge by teaching the teachers, a group of people that must be reached early in educational programs are the AVIC's, state veterinarians and chairpersons of the state Johne's advisory committees.
RESOLUTION: USAHA requests that USDA-APHIS-LIC sponsor a symposium on prevention, diagnosis and control of Johne's disease for all AVIC's, state veterinarians and chairpersons of state Johne's advisory committees.
PARA'S COMMENTS: We support any efforts to further educate on Johne's, but take the position that all of this should have been done years ago. Farmers are responsible business people who are used to dealing with animal diseases. If herd certification were mandatory in order to assure that the U.S. would be able to offer "paraTB-free" products in the future, and farmers were made aware that testing of their herds would be required, farmers would most likely educate themselves within one week, thereby saving previous time and precious dollars which would be better devoted to research into the zoonotic potential between M. paratuberculosis and Crohn's disease.


RESOLUTION 11

SUBJECT MATTER: Laboratory Certification
BACKGROUND: Diagnosis, prevention, control and certification of herds for paratuberculosis requires that accurate tests be performed in a manner reproducible between diagnostic laboratories. The National Johne's Working Group directed that National Veterinary Services Laboratory perform a pilot study for certification of laboratories to perform Johne's ELISA and fecal culture testing in cattle. Results of that study indicate that such a laboratory certification program is feasible. The study also revealed that some laboratories have unacceptably high error rates in Johne's diagnosis. To meet the anticipated demand for testing services from animal agriculture industries, it is imperative that as many laboratories as possible be certified to run diagnostic tests for Johne's disease.
RESOLUTION: USAHA urges USDA-APHIS-VS to formalize a laboratory certification program and set proficiency standards for ELISA and fecal culture testing for Johne's disease in cattle. Subsequently USAHA urges USDA-APHIS-VS to sponsor workshops to train public and private diagnostic laboratories in performance of ELISA, AGID, CF, DNA probe and fecal culture tests for Johne's disease in cattle.
PARA'S COMMENTS: We support all efforts to upgrade diagnostics in Johne's but take the position that this should have been done years ago. If we don't even have laboratories that can properly test for the bacteria, the foundation for a certification program is not even laid. Without even recognizing which animals are infected, how can we even begin to address the problem?


RESOLUTION 12

SUBJECT MATTER: CFR 80 (CFR="Code Federal Regulations")
BACKGROUND: The U.S. needs effective industry supported federal regulations to help control the spread of Johne's disease. CFR 80 was designed for this purpose but has been viewed inappropriate or unworkable by multiple sectors of animal agriculture. The result has been that CFR 80 has never been enforced.
RESOLUTION: USAHA urges USDA-APHIS-VS to rewrite CFR 80, in cooperation with experts on Johne's disease and representatives of dairy and beef cattle industries, to provide a workable, enforceable regulation.

PARA'S COMMENTS: According to the background information, this code which regulates the interstate transportation of diseased animals has not been enforced because it was considered "unworkable by multiple sectors of animal agriculture." This resolution seeks to involve the dairy and beef cattle industries in the formation of laws regarding movement of cattle. Since the dairy and cattle industries will be subject to these laws, they should not be involved in the writing of those laws. The focus of the USDA should be to act in the interest of the citizens of the U.S., and to protect the health of food consumers of the U.S. The USDA should not be acting in the commercial interests of these industries. If the dairy and cattle industries are permitted to change the law to suit themselves, then this will provide evidence that "the fox is guarding the hen house." Either our government is going to write laws that protect the public AND enforce them or they are not.


RESOLUTION 14

SUBJECT MATTER: Create a Position in USDA-APHIS-VS
BACKGROUND: Many states are beginning to devise programs for Johne's disease education, prevention, control and herd certification. In addition, the National Johne's Working Group is developing proposals for initiatives in education, and herd certification. To harmonize these efforts, lessen duplication of efforts and insure a well coordinated effort to address Johne's disease at the state and federal level, it is vital to have one or more full-time USDA staff epidemiologists dedicated to Johne's disease. The resolution to create a position in USDA-APHIS-VS to assist in coordination of activities and programs regarding Johne's disease (Resolution Number 19, 1996 USDA meeting) was not fulfilled. Presently in USDA only part-time activities of one person are devoted to Johne's disease program coordination. This request is in addition to the current level of three individuals each working on a part-time basis.
RESOLUTION: USAHA recommends that USDA-APHIS-VS appoint a full-timenational Johne's disease staff veterinarian solely dedicated to coordination of national programs and activities related to Johne's disease.
PARA'S COMMENTS: We support any attempts to further implement programs and have positions filled to meet those objectives. Again, we must take the position that since the responsible entitites have failed in addressing this problem previously, the problem is far worse than it would have been if it had been treated aggressively in the past. It seems rather inadequate to create one full-time position to oversee such a large task, given the fact that the government of the Netherlands is devoting 10 million U.S. dollars a year to get an eradication program up and running, a program which will begin in 1998. It should be noted that the Netherlands is a tiny country in relation to the U.S. They have a population of 16 to 18 million, while the population of the U.S. is 280 million. With that kind of commitment, no doubt "paraTB-free" products will be offered by other countries long before the U.S.


RESOLUTION 15

SUBJECT MATTER: Designate Johne's as a Program Disease
BACKGROUND: To reduce the spread of this infection and eventually bring Johne's under control, it is imperative that a concerted, coordinated effort by state, federal and industry groups be initiated. One step in this process is to elevate the level of importance of this disease for federal agencies by giving it official status.
RESOLUTION: USAHA recommends that USDA-APHIS-VS make Johne's disease a National Program Disease.
PARA'S COMMENTS: This would be a move towards giving Johne's disease the status to warrant more attention by federal entities, and we support that initiative.




RESOLUTION 23

SUBJECT MATTER: Evaluation of Johne's Programs
BACKGROUND INFORMATION: Paratuberculosis herd certification programs have been designed in the U.S. as well in other countries. In spite of the fact that some states have had herd paratuberculosis certification programs for over 10 years and in spite of the recent proliferation of national herd paratuberculosis certification programs, none of these programs have been evaluated for accuracy, reliability or cost effectiveness under field conditions.
RESOLUTION: USAHA requests that USDA, APHIS implement and evaluate pilot Johne's programs developed in concert with the National Johne's Working Group in states that have both Johne's certification and control programs. Such programs would be funded through a three-way partnership and cost sharing between USDA, the state and industry.
PARA'S COMMENTS: Unfortunately, since only 1% of dairy operations, according to the NAHMS study, are participating in a Johne's disease certification program, it appears that this attempt will be futile. The only way to seriously control this disease as soon as possible is through a MANDATORY certification program, to be implemented immediately.


Source: http://www.crohns.org/government/usaha/resolute.htm   Contact PARA: http://www.crohns.org/contact.htm