The Errors in BSE Science

4th February 1999

Thank you for acknowledging receipt of my photo copies and earlier submissions. I am very grateful.

It was suggested to me that I should take the opportunity offered to comment on the Draft Factual Accounts and I must say that even I am surprised at the reported behaviour of government officials. It seems to me that the tragic story of BSE illustrates perfectly the danger of missing vital and seemingly insignificant clues and then dishonestly covering the trail.

Like the story of the horseshoe nail there follows a sequence of related catastrophes until eventually even the Nation itself can fall.

Like most children we were told that telling lies will lead to more lies and eventual discovery and I have discovered that life is rather like jig-saw puzzle. We find pieces of truth that seem to fit along the way and pieces that are made to appear to e the truth by those who have reason to confuse us. Sadly for them their pieces only fit where they are intended to fit but as the rest of the pieces fall into their correct places those false parts show themselves for all to see.

So it is with MAFF.

I sincerely hope that the BSE story does not indicate the sinister side of big business for the demise of the meat industry could be advantageous to the chemical companies by way of increased markets for artificial meat substitutes, seed crops, pesticide sales and fertiliser to replace the lost manure sources. I am sure that others more qualified than I will deal with the science but there are things the Inquiry should know that appear to destroy the credibility of MAFF entirely.

For some time now I have been in correspondence with the MAFF BSE correspondence unit. If the Inquiry wishes it would be possible to provide copies though it may take some time.

It has been reported that discussions took place regarding the use of offal from calves and that it was suggested that such material should not be included in the SBO ban "180.  Mr Meldrum set out in some detail the arguments for exempting calves under six months of age from the SBO ban and identified the following factors to be considered:
·the calves would not have been fed meat and bone meal containing any ruminant protein "
The Inquiry should know that the following was written by MAFF BSE Correspondence Division in respect of the selective cull in a letter to me dated 3 December 1998 - "You appear to doubt that the selective cull was based on science. The basis of the cull is that feed containing meat and bone meal has been the main source of BSE infection for cattle, and scientific evidence suggests that most cattle were infected whe eating such feeds when they were less than 6 months old."
This is clearly at odds with information given to the Inquiry. It is clear that this entire episode is not based on sound science.
The above exemption of their "infectious material" from the ban is probably the least serious.

The following indicates that if the MAFF theory of feed born transmission was correct then no part of meat animals could be considered risk free and I am surprised that even those who support the infectious feed theory did not recognise that if they were correct then there would also be a risk in meat from pigs and poultry.

"175.. the propose SBO ban would eliminate large concentrations of lymphoidal and nervous tissue but it had to be recognised that it was impossible to eliminate all such tissue "which includes peripheral nodes and nerves intimately associated with the main edible parts." 3. ... the spleen was the most infective organ in the pre-symptomatic stage of the disease, whilst the brain became the most infective once the disease had become manifest. He also drew attention to the infectivity of the reticulo-endothelial elements of the gut."

This appears to confirm that MAFF believes that even asymptomatic cattle carry the infective agent which in itself throws all their claims into disarray.

"82.     Mr Cockbill's submission to the Minister of 2 June 1989(93) contained an analysis of offals which might be banned.
He categorised them as follows, in decreasing order of infectivity.
·Category (i): Brain and spinal cord
·Category (ii): Spleen, lymph nodes, tonsils, intestines, nerves and thymus
·Category (iii): All remaining organs including the heart, liver, kidney and skeletal muscles
·Category (iv): Milk, serum, faeces" Urine is not mentioned and yet
"210. On 28 November 1990 Mr Wilesmith confirmed the first suspect cases of BSE from French cattle. The results were provided by a French scientist Dr H Brugčre-Picoux, of Paris, who had identified BSE by electrochemical analysis from urine samples. The results were presented at an EU sponsored meeting on BSE research on 14 & 15 September 1993.(278) Mr Wilesmith concluded that this electrochemical analysis could assist in the clinical diagnosis of BSE.(279)"

Despite claims that human health and sound science had priority excuses were made at every stage as to why their "infectious" materials should remain in the food chain. So much so that they attempted to persuade UKASTA not to introduce their voluntary ban.
Even the use of bones in Mechanically Recovered "Meat" was a process they wished to continue and yet the government later banned sales of meat on the bone.
"137. In relation to the issue of the use of cattle bones for MRM Mr Meldrum commented

"I trust that we will not become involved in mechanically recovered meat".

"104. Mr Taylor also noted that: Of all the offals which it is proposed to ban, tripe is likely to be the most contentious since there is a large trade in this product and the financial loss to the industry of a ban on its sale would be considerable.
(112)" "196.  The main recommendations of this submission were as follows:
(i) The banned offals should be brain, spinal cord, thymus, spleen, tonsils and intestines. However, none of the four stomachs (producing tripes or rennet) nor mesenteric fat would be banned.
(ii) Calves under six months old would be totally exempt from the ban. On this, the submission recognised a possibility that infective agent may be present in the LRS of calves, and recognised that there was a market in the UK for calves' thymus as human food, but stated that: "In all the circumstances, and having regard to the scientific evidence, such an exemption would not represent a measurable increase in any possible risk." Within the technical reasoning for (i) above, the submission recommended the exemption of MRM from the ban on the grounds that: ·In any pre-clinically infected cattle, the BSE agent was likely to be in the lymphoid tissue rather than in the CNS. ·Assuming that spinal cord were banned, it would have to be stripped out of the vertebral column prior to mechanical recovery of meat."

Given that the agent is said to be so virulent that sterilisation is impossible it is clear that slaughterers will have spread the agent from carcass to carcass as they use the same cutting implements for each animal. These workers would also have been more exposed to the "infectious agent" than any other section of the public but there does not appear to be a correspondingly high level of occupational nvCJD sufferers.

All this assumes that the cause of BSE was correctly identified by the individuals involved.

"181.    By March, an analysis of 189 herds had been carried out on the basis of the information provided in the questionnaires devised by Mr Wilesmith. As a result, a number of possible aetiological hypotheses had been ruled out, including contact with sheep, imports, treatments, artificial insemination, effluents and cattle movements.
(215) Mr Wilesmith told the BSE Inquiry that he reached his conclusion that BSE was caused by infectivity in meat and bonemeal by a process of elimination, having ruled out other possible sources of infection.(216) "

Strangely this process of elimination discounted the possible effects of glyphosate, pyrethroids and the OP residues from sheep dip, warblecides, and grain treatments which would also have been found in the MBM itself but even if he was right the measures they took would not have protected humans or animals.
"81.The attack rate experiments failed to identify the minimum infective dose, because they were conducted with a dose range that ensured infectivity in each category. Mr Wilesmith said he only had informal input into the attack rate experiment through discussions with Dr Kimberlin.(137) Mr Wilesmith, however, said he was not surprised when a one gram dosage was found to be infective because he expected before the experiment that 50 per cent of animals would succumb to the disease using a one gram dose. Despite this expectation they still allowed material they claimed to know was "infected" to be used in human feed and medicine.

If what they claimed was true every cow in the UK and every human eating beef, pork and chicken in the UK would have consumed their "proven" infective dose of 1 gram.

Perhaps it is fortunate that MAFF conducted their studies using material never available on farms in ways that are never inflicted on farm animals. No farm would have access to pure, raw brain material and they would certainly not inject that material into their animals unless of course it was returned to them by the pharmacists unknowingly as an undeclared ingredient in medicines which seems to have been possible.

If surgical instruments can transfer the agent it is most likely that their experiments would have given positive results even if no material other than that on sterilised instruments entered the healthy brain and I would suggest once again that this is not an "infection" but a cascade-like enzyme replication process.

Given that the dangers of contracting CJD from injected contaminated growth hormone were already known and that legal action was underway at the time I am surprised at the reported use of cattle brains in human medicine.

"120.    On 10 September 1987 Dr Watson sent a minute to Mr Rees which was copied to Mr John Suich of the Animal Health Division of MAFF. The minute stated:(144) DHSS are aware of the problem. Concern is being expressed about the possible human health risks due to products for human use which contain an emulsion of bovine brain.
This matter was discussed by Dr Little with DHSS colleagues attending the Committee of Safety of Medicines Sub-Committee on Biological Products ..."
121.Mr Rees told the Inquiry that what had occurred in the Committee of Safety of Medicines Sub-committ did not lead him to give any further consideration to whether he should approach anybody at the Department of Health. He considered that these were fairly senior people and would presumably pass this message up the line. Further, that if they wanted to now any more they would have come back to them, but they did not, and so they assumed that DHSS were content that it was basically an animal health problem.(145)"
126. Mr Rees sent a progress report to Mr Thompson on 16 September 1987. Paragraph 4 read DHSS are aware of the problem and have informally expressed some concern about any possible human health risks due to products for human use which contain an emulsion of bovine brain. However, there would be no risk provided the brains are from clinical healthy cattle."(148)

The above comments were made despite the fact that many cattle killed for human consumption and therefore also used in medicine may have been carriers of BSE in a sub-clinical condition.

As if the story on SBO was not bad enough it is apparent that MAFF was at a loss to explain the born after the ban BSE cases. They appear even now to have made no effort to explain the thousands of BSE negative cases which had symptoms sufficiently similar to BSE to be considered BSE suspects.

" 63. The first suspect BAB case was reported in December 1990 and was confirmed as being a case of BSE in March 1991.(102) Mr Wilesmith described the approach he took to BABs in his statement to the BSE Inquiry:(103) As epidemiological data accumulated on the BAB cases, early in 1992, it became apparent that the 1988 and early 1989 born BAB cases were most likely to have been infected from the feedborne source as a result of cattle feedstuffs containing ruminant derived MBM which had been manufactured before the 18th July, 1988 and was still in the feed supply chain or on farms.
Mr Wilesmith described the approach he took to BABs" "..This information was obtained for at least the first 100 BAB cases born in each calendar year after the feed ban. These ingredient lists were examined by me to determine:
(a) if there had been any erroneous inclusion of MBM after the ruminant feed ban;
(b) whether there were other ingredients being used which may have been derived from ruminants; and
(c) the possible risks of tallow as a vehicle of infection. The accumulated results of these examinations have indicated that two accidental inclusions of MBM in relatively small batches of cattle feedstuffs had occurred"

The ELISA test was developed to determine if any cross contamination of feeds had occurred but it showed false positives and despite the granting of a patent it was not considered accurate enough for use in any legal actions but MAFF had complete faith its results.

"24.voluntary routine sampling of feedingstuffs for ruminants and testing of samples for the presence of ruminant protein will commence on 8 June..Samples were to be taken by veterinary staff while carrying out routine examinations on cattle, with agreement from farmers, and without charge. All testing was to be carried out at Luddington VIC.(35) On-farm testing was carried out from 1994, with a break between 3 April 1995 and 8 August 1995. Between 1994 and 1996, 1,575 samples were tested, of which only three samples were potentially positive.
25. Positive results led to further investigations, which established low-level cross-contamination of ruminant feed by ruminant protein in pig and poultry feed.(36) Particular points of contamination were identified at reception points for raw materials in feed mills, on conveyor belts and augers transferring the raw materials to silos, and on trucks transporting raw materials and finished products.(37)
28. The problem of BABs and cross-contamination was discussed by SEAC at its meeting on 10 February 1995.(42) SEAC was very concerned that cross-contamination appeared to be the main reason for continuing cases of BABs."

I suggest that this was a self fulfilling prophesy because they saw the results they wanted and ignored the chance of false positives. There are no details as to how the test was improved and there is no evidence here to show that a failure rate of 1 in 500 was not simply an improvement on the 1 in 50 failure rate.
Despite this it was decided that all the BABS cases were the result of contaminated feed together with the unclear "evidence" that feeding even a single gram of "infected" MBM causes BSE.

Perhaps not surprisingly "The results were described as being "completely in line with what they had expected", and Dr McCaughey congratulated them on such an accurate result."
But UKASTA found that the test was unreliable.

MAFF is clearly on unsafe ground in respect to their "infective feed theory"

An interesting point is noted in the Early days paper. "94. Mr Wilesmith produced summary reports on the progress of his epidemiological investigations.

In the third such report dated 23 July 1987, he suggested that 'at present it appears unlikely that any component of the feedstuffs used in these herds is involved in aetiology'.

He commented that all nine farms had used synthetic pyrethroids, and that all affected cows were of the Friesian/ Holstein breed.(112) Mr Wilesmith stated that food was not considered likely at that stage because, as far as he was aware, nothing was new in the feeding regime.(113)"

Although the Inquiry apparently has not been given this information I helped Mr Purdey to raise the funds needed and survey the Dairy and Beef farms here (area given)by means of detailed questionnaires covering most aspects of feed and chemical use. I did not see the results but in conversation Mr Purdey informed me that the only noticeable trend found was that all herds with BSE had used pyrethroid fly tags and all those with no BSE had not used such controls.

I cannot help but wonder why Mr Wilesmith, who had already dismissed any pesticide involvement, was given responsibility for drafting the questionnaire used by MAFF. I suspect that pesticide use was omitted from the MAFF questionnaire? This may also explain why the possibility of organophosphate involvement was also dismissed.

It is clear that there is considerable pressure on government at the current time in respect of pesticides and the chemical companies have declared their intention to protect their OP molecules. Meanwhile MAFF have failed to acknowledged that the false formation provided on the two OPs most often used on food could present considerable risk to all our health. They have steadfastly ignored the international calls for an immediate ban made and well publicised over a year ago as mentioned in my earlier submissions.

I find it interesting that BSE can be detected in urine and yet so much emphasis has been given to tests made on brain tissue and the difficulty in obtaining samples from MAFF. Perhaps MAFF knows that if they were to approve tests on urine there would too many cases of BSE and that their theory would then be destroyed. As with chemical testing it seems that those with vested interests can always find a way to criticise the work of those who find errors in the accepted data.
In correspondence in 1997 Zeneca claimed that they could not comment on my test on their pesticide because they had no knowledge of the conditions. Even though I pointed out that those conditions were identical to to instructions they provided for general use they still discounted my comments. I see that MAFF have treated those who have devised experiments over which MAFF has no control in the same manner. They must also fear truly independent testing.
I wonder if the Attack Rate experiment set up in December 1991 has received any independent appraisals and if papers on the subject are available? It does seem crucial to the MAFF case and yet its results have not been mirrored outside of their experimental conditions especially since the MAFF BSE correspondence unit assures me that even in 1998 animals with BSE were still entering the food chain. Certainly imported meat frequently comes from animals fed MBM and from countries where BSE is still being reported.

No explanation appears to have been given as to why, given the MAFF claim that a single gram of infective material can induce BSE, there has not been an equivalent number of BSE cases in the countries to which our MBM was exported - even after the ban on its incorporation in the feeds produced in the UK. The dismissal by MAFF of possible pesticide link has resulted in the increasing involvement of all government departments in a damage limitation process which, if allowed to succeed, will result in an ever growing number of human victims and the loss of vital scientific evidence in such places as Kent and Utah.

The Utah incident has only just come to my attention but it is clear that once again an incident some 30 years ago involving the release of OPs and the subsequent death of sheep from a scrapie like illness has been followed by a cluster of nvCJD victims any years later.
If this information is correct it would appear that this whole BSE saga will be seen to be the most expensive and unnecessary disaster of all time.

Government seeks to assure us that we can trust the regulating authorities on the subject of BSE, pesticide and Genetic Modification but I would suggest that these draft factual accounts prove entirely the opposite.

4th October 1999

It would seem that we have all been given some misleading information on the causal factors of BSE and I am prompted to write to the Inquiry again by the recent publicity regarding vaccines and the French action in respect to lifting the beef export ban understandable with the continuing ban on UK beef on the bone.. You may recall that in earlier submissions I raised the subject of enzyme system involvement in both the cause of BSE and the spread of the disease and I questioned the idea that prion replication was a new an unexplained phenomenon thought to indicate new and improperly understood disease process.

Could I refer you to the ninth edition of the Penguin publication "Dictionary of Biology" by M.Thain and M Hickman, 1994 reprinted in 1995 and 1996. My interest was triggered by a chance article read by my wife who has been treated this year for a rapidly malignant breast cancer. The article referred to the role played in cancer by telomerase and the reference in the above book led me directly to prions and the discovery of fascinating biological links and processes.

"Telomerase is an enzyme composed of both RNA and protein, and as such it may be an evolutionary link between systems using ribozymes only and those using purely protein enzymes"
The reference links to prions and to heterochromatin.
The latter reference states that heterochromatin, as well as being linked with sister chromatids, can also cause the fascinating process of position effect variegation.

The reference for this states: Position effect variegation (PEV) produces mosaic phenotypes and can occur when a euchromatic gene finds itself close to a piece of heterochromatin or distal euchromatin. The heterochromatic condition may then ‘spread’ to adjacent euchromatin, inactivating nearby genes by repackaging their chromatin into heterochromatic domains. Other loci often act as modifiers of PEV, suppressing when in single and enhancing when in double dose. Oncogenes and transposons can have PEV-like effects, in the latter case especially when they insert in telomeric regions."

In the reference for oncogenes is the following phrase. "Most oncogenes encode protein kinases involved in the regulation of the cell cycle, and may exert their effects in mitotic cells, meiotic cells or both; others direct the transition out of the cell cycle and into the differentiation pathway." There are also viral links.

Differentiation is "usually associated with the selective expression of parts of the genome previously unexpressed, brought on e.g. by cell contact, cell density, the extracellular matrix and molecules diffusing in it (e.g. see growth factors)......."

There is no doubt then that this is not a "new" or "unknown" mechanism and it is clear that there are implied links with both recombination as employed in Genetic Engineering and the known and recognised dangers in respect to growth hormones.

I suspect that it is not possible to inject the pure hormone and that other enzymes and complex mechanisms would be injected with the sample.
It is likely that all the trials utilising injected BSE material would therefore be seriously flawed. There is however more evidence to question the reasons for the beef ban.

The Inquiry may recall that I raised the matter of enzyme corruption by organophosphates and that the oxygen and energy transfer system via ADP/ATP and cAMP, which is also essential for most of the previously mentioned biological processes, is known to corrupted by organophosphates.
Furthermore I raised the subject of how difficult it has been for poisoned individuals to achieve recognition from Government agencies and that the Government persistently refused to recognise evidence of danger.
That situation remains unresolved but has become far more important of late since the permitted levels of the suspected glyphosate organophosphate in our food has recently been raised by a factor of 200 times.
This is all the more worrying as the Government has been given evidence that glyphosate has, despite denials, the same anticholinesterase action as other organophosphates and, as reported to the BSE Inquiry in earlier submissions, it also kills insects quickly, if not quicker than, OP insecticides.
Despite every effort to draw the attention of Government to the known dangers from pirimiphos methyl in our food no action has been taken to restrict its use.
The samples reported earlier retain their toxicity even now despite having been diluted in water for over two years and stored in sunlight since 3rd July 1999.

Now I come to the other reason for this submission. I received a paper some weeks ago which adds further strength to the views expressed in my earlier submissions and which ties in well with the earlier factors in this submission. In fact I believe it indicates a complete view of BSE causation and transmission. The paper was published in Clinica Chemica Acta 262 pages 89 to 97 and was accepted for publication in February 1997, long before the Pesticide Safety Directorate produced its evaluation document on pirimiphos methyl with all the admitted mistakes and those it refuses to recognise.

Entitled "Effect of pirimiphos-methyl on proteolytic enzyme activities in rat heart, kidney, brain and liver tissues in vivo" it seems to provide evidence that this chemical presents a previously unrecognised toxicity hazard higher animals by way of protease inhibition.

I had hoped for action from the PSD but the danger is ignored.
It seems to me that this paper links all the problems quite nicely. The proteolytic enzymes also utilise the ATP/ADP energy process which OPs can disrupt and on which proteasomes depend. Returning to the references it is clear that the proteolytic enzymes are important in digestion and that proteolysis is essential in regulating cellular protein concentration and distribution. The sub-units of proteasomes, the ubiquitins, are involved with antigen presentation and therefore immune response, which raises he spectre of autoimmune diseases and the failure of the immune system to control viral and bacterial infections or even the failure to recognise cancer cells, host cells or the misformed prions of BSE.
Ubiquitins are also involved in the degradation of cellular proteins and any corruption of the system would presumably also involve ubiquitin kinases, of which Cdc34 is required for DNA replication, and Ubc9 for cell division which again links us with the cell cycle and cancers.
Some lysosomal enzymes were affected and they involve a large variety of hydrolytic enzymes involved in cell digestion and "undigested remains may persist in residual bodies for some time" which may explain the dormant period?

Another link to the hormonal system is found in the lysosome fusions which form the autophagosomes involved with hormone-related developmental reorganisation which links again to the growth hormones.

Perhaps most significant is the involvement of the peptidases which are involved in the formation of the proteins of which the prion protein is the prime suspect in BSE.

So it would appear that we have at least one organophosphate which has been shown to have the potential to cause the formation of a misformed protein which can then be replicated by known biological processes and yet our scientists tell us they do not understand the mechanism.

But the above paper studied only the purest form of the active ingredient and took no account of the solvents in the formulation which are known to enhance the action or the presence throughout the animal of the systemic OP warblecides, the OP glyphosate in the Soya, Maize, grass, grain and other fodder.

All these factors combined could explain why the ban on MBM has had little effect. I understand that BSE cases are still running at 50 per week despite claims that BSE would be "history" by 1991.

The official excuse for the ongoing cases was cross-contaminated feed but it is clear that the test they used was flawed by false positives and in any event time has disproved the theory.

I understand that even the 50 cases may not present a true picture as despite the notifiable disease status cases are hidden - not always by farmers.

We must make those who have hidden the truth accountable and control OPs before it is too late.

Dated 16/9/2000

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