From: Ross Minett [ross.advocates@virgin.net]
Sent: Tuesday, January 23, 2001 4:43 AM
To: FDADockets@oc.fda.gov
Subject: USDA - Petition 98P-0151/CP1 - Stop the marketing of downed
animals.

U.S. Food and Drug Administration
Dockets Management Branch
5630 Fishers Lane, Room 1061
Rockville, MD 20852
FAX: 301-827-6870
E-mail: FDADockets@oc.fda.gov
RE: DOCKET NUMBER :   98P-0151/CP1
23/01/2001

To whom it may concern,

I write to you regarding petition 98P-0151/CP1 to prohibit the slaughter of
downed Animals.

Advocates for Animals have campaigned for improved conditions for farm
animals throughout the world for many years.

Last year, the USDA stated:

" The USDA will no longer accept ground beef that includes product from
non-ambulatory cattle, commonly known as "downers".

Advocates for Animals agree that the marketing of downed animals is
unacceptable.

1:  Animals who are too sick or injured even to stand should not be allowed
to enter the human food chain.

2: In addition to posing an increased risk for bacterial contamination,
there is evidence that some downed animals may be afflicted with a form of
BSE (Bovine Spongiform Encephalopathy or
"Mad Cow Disease"), a disease which has been linked to a fatal human illness
(CJD or Creutzfeldt-Jakob Disease).

3: It is impossible to move downed animals humanely, and they are typically
pushed with tractors or dragged with chains - inhumane processes which cause
injuries ranging from bruises and abrasions, to broken bones and torn
ligaments.

4: Downed animals comprise a very small percentage of animals slaughtered,
and prohibiting their marketing will cause no undue economic hardship.

5: Industry experts have estimated that 90% percent 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.

We urge the  Food and Drug Administration to grant  petition 98P-0151/CP1 to
prohibit the slaughter of downed animals.

Yours sincerely
ROSS MINETT
Campaigns/Information Officer
Advocates for Animals
10 Queensferry Street, Edinburgh, Scotland, EH2 4PG
Tel: +44 (0)131 225 6039   Fax: +44 (0)131 220 6377
www.advocatesforanimals.org.uk