From: Dan Burbank & Dawn James [bub@wolfenet.com]
Sent: Wednesday, December 27, 2000 7:20 PM
To: FDADockets@oc.fda.gov
Subject: Re: Docket Number 98P-0151/CP1

Last year, the USDA announced a landmark policy to stop purchasing meat
from downed cows for federal programs, including the National School
Lunch Program. The agency stated, "USDA will no longer accept ground
beef that includes product from non-ambulatory cattle, commonly known as
'downers'." This development shows a growing consensus - even among
livestock industry and government officials - that the marketing and
slaughter of downed animals is unacceptable.
The time has come for this policy to be expamded to include all animals
and for all markets, the private sector and state & local governments.
A few points to consider:
* Animals who are too sick or injured to stand should not be allowed to
be slaughtered for human and even non human consumption.
* The use of downed animals in meat production poses an increased health
risk to the consumer from bacterial contamination and disease.
* Downed animals cannot be moved humanely, and they are typically pushed
with tractors or dragged with chains - resulting in further injuries
from bruises and abrasions, to broken bones and torn ligaments.
* Prohibiting the marketing of downed animals will cause no undue
economic hardship.
* Industry experts have estimated that 90% of downed animals can be
prevented with better care and handling. Removing the market for downed
animals will provide an incentive to industry to prevent downed animals
in the first place.
Please take steps to ensure that NO meat from ANY animal that is
non-ambulatory will be considered accepted as edible by anyone.
Thank you.

Dawn James
19223-48th Ave West
Lynnwodd, WA 98036
425-778-1914