From: Jan Davidson [biskenne@sierratel.com]
Sent: Friday, April 05, 2002 4:40 PM
To: FDADockets@oc.fda.gov
Subject: No Downers Docket Number 98P-0151/CP1


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

RE:  DOCKET NUMBER 98P-0151/CP1

We strongly urge you to consider granting the above petition, based on
several facts, e.g.,

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

* 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).

* 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.

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

* 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.

Jan Davidson
Chapter Manager
Southern Yosemite House Rabbit Society
Deerbrook Guinea Pig & Rabbit Haven
7610 Forest Drive, Fish Camp, CA 93623-0176

Donald L. Davidson, M.D.
7610 Forest Drive, Fish Camp, CA 936230-176