From: Deborah Naomi Black [dnblack@globalnetisp.net]
Sent: Monday, February 05, 2001 7:16 PM
To: FDA Dockets
Subject: Docket #98P-0151/CP1

U.S. Food and Drug Administration
Dockets Management Branch
5630 Fishers Lane, Room 1061
Rockville, MD 20852

February 5, 2001


RE:  Docket 98-0151/CP1


Dear Officials:

I am writing to support petition 98P-0151/CP1 to prohibit the slaughter of
downed animals.  As you know, slaughterhouses continue to use sick animals
for both human and animal food.

There are public health issues with the use of such animals; as you know,
the  U.S. Department of Agriculture recently prohibited the use of downed
cows  for  the National School Lunch Program.  In Europe, some of the
problems with  bovine spongiform encephalopathy could have been avoided had
sick animals  not  been introduced into the animal feed and human food
chains.

However, I have strong objections to the way sick animals are typically
treated in the meat industry.  Animals who are so ill they cannot even
stand  are subject to monstrous cruelty be being pushed around -- alive --
using  earth-moving equipment.  The creatures suffer terrible wounds during
their  processing before they are killed.

Given that by the mean industry's own figures, downed animals are a small
percentage of the total input into slaughterhouses, I do not see how
prohibiting their use can have a significant costs to the industry.

In summary, based on concerns for the health of human beings and of animals
who may consume meat and byproducts from animals who are sick, downed
animals  should not be included in slaughterhouse inputs.  In addition,
concern for  animals themselves dictates that in a humane society, they
should be put  out  of their misery using euthanasia, not left to die slowly
and in pain.


Very truly yours,


Deborah N. Black, M.D.
Neurologist