Showing posts with label Food and Drug Administration. Show all posts
Showing posts with label Food and Drug Administration. Show all posts

9/6/12

HSI/Canada Renews Calls for Prohibition on Horse Slaughter as Banned Substances Found in Canadian Horse Meat

HSI/Canada Renews Calls for Prohibition on Horse Slaughter as Banned Substances Found in Canadian Horse Meat : Humane Society International
August 9, 2012
HSI/Canada Renews Calls for Prohibition on Horse Slaughter as Banned Substances Found in Canadian Horse Meat

Humane Society International/Canada

Horses slaughtered for meat in Canada are generally not raised for human consumption.

MONTREAL— Following confirmation of prohibited substances in Canadian horse meat, Humane Society International/Canada is renewing calls for a federal prohibition on the slaughter, sale, transport and export of horses for human consumption. Belgian authorities recently notified the European Commission about the reported presence of two unauthorized substances, clenbuterol and phenylbutazone, in horse meat that was imported into the European Union from Canada. Horses slaughtered for meat in Canada are generally not raised for human consumption and are commonly administered substances that are banned in food-producing animals.

Additionally, the United States Food and Drug Administration recently released a warning letter that revealed the presence of the same two banned substances in an American horse sold to a Canadian slaughter establishment. The American establishment cited in this warning letter provided false information in the Equine Information Document, which Canadian authorities rely upon to determine whether American horses exported to Canada have been administered substances not permitted for use in horses in the last 180 days prior to purchase of the animal. Specifically, this establishment “filled out and signed the producer’s name” and failed to ask the horse’s producer about its medical treatment history. Like Canadian horses, American horses are not raised for human consumption and are frequently administered substances banned for use in food animals.

“Slaughtering horses for human consumption is inherently inhumane and the recent discovery of prohibited substances in Canadian horse meat proves it may also pose a human health risk,” said Ewa Demianowicz, campaigner for Humane Society International/Canada. “Clenbuterol and phenylbutazone can be toxic to humans and have been banned from our food supply for that reason. Clearly, the horse meat protocols imposed by the Canadian Food Inspection Agency are inadequate and fail to ensure food safety.”

Humane Society International/Canada urges the Canadian government to take immediate action by enacting Bill C-322, which would amend the Health of Animals Act and the Meat Inspection Act, prohibiting the import, export and inter-provincial transport of horses for slaughter for human consumption.

The two prohibited substances were found in chilled and frozen horse meat that was subsequently distributed to Belgium, France, Germany, Italy, Luxembourg and the Netherlands. EU member countries have strict food safety policies, which should prevent domestic horses that been administered with substances prohibited in food-producing animals from ever entering the food chain. In comparison, current CFIA standards are insufficient and could lead to human health threats for those consuming horse meat, the majority of which is exported.

FACTS:

In 2011, more than 90,000 horses were slaughtered in Canada.
Horses are an extreme example of a flight animal. The panic and instinctive desire to escape causes them to thrash their heads frantically in the kill chute, making it difficult to effectively stun them prior to slaughter. As a result, many horses receive several blows before they are rendered unconscious.
Horses can be transported for up to 36 hours without food, water or rest in Canada. Horses are often crammed in trailers (sometimes double-deckers) designed for shorter animals, and travel in uncomfortable positions over very long distances.
Because horses are generally not bred as food animals, they are often administered substances that are prohibited in our food supply.
In 2011, MP Alex Atamanenko introduced Bill C-322, an act to amend the Health of Animals Act and the Meat Inspection Act to end the import and export (and transfer between provinces) of horses for slaughter for human consumption.
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8/19/12

Secy. Vilsack - USDA Cannot Enforce Horse Slaughter Laws

Posted Aug 17, 2012 by lauraallen

USDA/FSIS Cannot Meet the Legal Requirements for the Return of Horse Slaughter to the U.S.

Dear Secretary of Agriculture Tom Vilsack:

The Food Safety Inspection Service (FSIS) Administrator, Alfred Almanza, has been quoted as saying that the agency is moving quickly to accommodate two pending applications to open horse slaughter plants in the U.S. Though as I understand since then, the applicant in New Mexico has withdrawn the application, and the Missouri applicant is beset with legal problems and was apparently not even the owner of the property proposed for the horse slaughter facility and cannot acquire any ownership interest.

Regardless, a horse slaughter proponent is circulating a "petition" to urge FSIS to move more quickly in approving applications and make inspectors available for horse slaughter for human consumption. The USDA has a number of legal obligations when it comes to slaughtering equines for human consumption; USDA cannot meet any of these obligations and for this and economic, environmental and other health and safety reasons, should not allow horse slaughter.

Substantial Taxpayer Costs with No Economic Benefit

As the U.S. struggles to climb out of the most devastating economic recession since the Great Depression, it is puzzling why FSIS would take funds from an already depleted budget to use for a program to inspect horses to be slaughtered for human consumption. Surely, the threats to food safety and humane treatment of animals are already significant with a reduced budget. Why would any funds be used for a program that results in no economic benefit to the U.S. and instead threatens the health and safety of our local communities and equines?

Prior to the closure of the 3 horse slaughter plants in 2007, FSIS spent approximately $5,000,000 annually for inspectors, basically subsidizing the three foreign-owned (Belgian and French) horse slaughterhouses. Americans don't eat equines so there were no sales of horsemeat domestically and thus no sales tax revenues from slaughter. Horse slaughter facilities pay virtually no income taxes. One facility operating in Texas prior to 2007 paid $5 in federal income tax one year on $12 million dollars in sales. In the preceding 5 years the federal income tax was .3% or 1/3 of 1% of gross revenues or sales. A forensic analysis of the tax returns revealed that the company avoided U.S. income taxes by selling the horsemeat at a loss to an entity it owned in another country and then that entity distributed the product overseas at substantial profit. With no sales or distribution in the U.S. and no tax revenue, there is simply no benefit to the U.S. economy from horse slaughter.

The property tax revenue to Kaufman, Texas where a horse slaughter facility operated until 2007 was generally less than $2,000 per year, a mere pittance when compared to the city's costs for pursuing the facility's continual violations of its wastewater permit and in working to address violations of regulations of Texas Dept. of Health and the Commission on Environmental Quality. The city's legal fees just to address issues related to the horse slaughter plant exceeded its entire budget for legal fees in one year. The city was even fined by the TCEQ for the plant's failure to comply with backflow regulations that meant horse blood and waste backed up into sinks, toilets and tubs. When the plant finally closed, the city was left with nearly $100,000 in unpaid fines for wastewater permit violations.

The situation was no different at the horse slaughter plant in Ft. Worth and the other in DeKalb, Illinois. In DeKalb, the horse slaughter facility had waste permits that allowed contamination levels for waste water that were eight times higher than usual. Yet, the facility was out of compliance hundreds of times. It was not a matter of having old facilities. The owner, Cavel International, built a state-of-the-art pre-treatment system that became operational in 2004. The facility remained out of compliance with its permit regularly until it finally closed in 2007. The blood and waste from slaughtered horses oozed from the state of the art tanks. There were also hundreds of FSIS violations.

The same was true of Canadian Natural Valley Farms where a 2008 investigation revealed the state of the art waste pre-treatment facility overflowed as well with blood and waste, and large amounts of waste and blood were dumped into nearby rivers. When the state of the art facility was shut down, the community was left with environmental contamination and a bankrupt company that claimed $42 million in losses.

None of this includes the plummeting property values, loss of new business, increased crime rates and a general stench and pall that hung over the communities. All courtesy of the horse slaughter plant. This is what President Obama's USDA wants for American communities?

If horse slaughterhouses are allowed to re-open, they would again be subsidized by American taxpayers. Estimates are that the U.S. government would spend at least $3,000,000-5,000,000 annually to subsidize private horse slaughter facilities.

On top of that, the USDA could give foreign owners of U.S. horse slaughter facilities, such as Bouvry, the Canadian company that has explored the possibility of opening a horse slaughter plant near Stanwood, Washington, or the Belgian company, Chevideco, which claims it may contribute to the building of a horse slaughter house in Oregon or Missouri, a subsidized loan of $750,000 through the RUS World Utilities Services.

Mr. Vilsack, it is outrageous that the American taxpayer should support wealthy investors in a business that profits from animal cruelty, benefits only foreign interests and wrecks the U.S. communities where the facilities are located. This money would surely be much better spent on American interests. It would seem more appropriate for USDA to focus on the live horse industry worth $112.1 billion of gross domestic product.

Few Low Wage Jobs

The argument that significant jobs would be created is specious. Horse slaughter plants operating until 2007 never created more than 178 low wage jobs -and many of these were held by illegal aliens. When horse slaughter plants operated in the U.S., this meant workers and their families overran local resources like the hospitals and government services. It meant low income housing and a decline in the overall standard of living.

Slaughter Contributes to Numbers of Horses in Need

Slaughter proponents have widely claimed that slaughter is somehow an alternative for "unwanted" horses. Nothing could be further from the truth. Slaughter actually creates a salvage or secondary market that enables overbreeding and poor breeding practices. Slaughter and a poor economy have resulted in horses in need. Slaughter is driven by a demand for horsemeat in some foreign countries; it is not a "service" for unwanted horses and that is why, as one of your department's own studies confirms, most horses, 92.3%, are healthy when they are sent to slaughter. Kill buyers are interested in buying the healthiest horses for horsemeat that is sold as a delicacy in some foreign countries.

The rise in numbers of horses in need and drop in horse prices is a result of the worst recession in memory. In fact, if slaughter controlled numbers of horses in need, there would be none as slaughter is still available and horses are sent to slaughter in the same numbers as before the 2007 closings of the slaughterhouses that were located in the U.S. It is the availability of slaughter that actually increases the numbers of excess horses and other equines on the market. Banning slaughter would reduce the number of excess horses and other equines.

Also, slaughter accounts for only about 3 cents for every $100 of the equine industry. It makes no sense for anyone to suggest a limited salvage market could influence prices in the entire horse industry.

The Live Horse Industry

Again, it is the live horse industry that USDA should support. Most horses end up at slaughter because they are purchased by kill buyers. Many horses could have easily been purchased by someone else other options include adoption programs, placing them as pasture mates/babysitters to a younger horse, donating them for use in horse therapy, or placing them in a retirement home.

Humane Euthanasia is Available and Affordable

Also, about 900,000 horses are humanely euthanized in the U.S. each year. The infrastructure could easily absorb those sent to slaughter. The average cost of humane euthanasia including the farm call and either burial, rendering or placement in a landfill can be as little as $50 depending on the method used, and at most $400.

Humane Methods of Slaughter Act Unenforceable for Equines

The USDA is responsible for enforcement of the Humane Methods of Slaughter Act, 7 USC Sec. 1902(a)("HMSA"). USDA/FSIS failed miserably at this when horse slaughter was legal. That is because the slaughter of horses and other equines simply cannot be made humane: Dr. Lester Friedlander, DVM & former Chief USDA Inspector, told Congress in 2008 that the captive bolt used to slaughter horses is simply not effective. Horses and other equines, in particular, are very sensitive about anything coming towards their heads and cannot be restrained as required for effective stunning. Dr. Friedlander stated, "These animals regain consciousness 30 seconds after being struck, they are fully aware they are being vivisected." The Government Accountability Office ("GAO") in 2004, GAO-04-247; and dozens of veterinarians and other witnesses have confirmed that ineffective stunning is common and animals are conscious during slaughter. It is simply not possible for USDA/FSIS to make equine slaughter humane and it is a myth to pretend otherwise. Also, the GAO in 3 subsequent reports in 2008, GAO-08-686T; and 2010, GAO-10-203 and GAO-10-487T, has continued to find disparities and inconsistencies in FSIS enforcement of HMSA, an abysmal record of tolerating cruelty at slaughter facilities.

Having to provide sufficient FSIS inspectors even to try to enforce HMSA means even more cost to the taxpayer. For a job that cannot be done when it comes to equines.

Commercial Transportation of Equines to Slaughter Act Unenforceable

GAO has also confirmed that USDA/APHIS has not - and cannot - enforce transport regulations for equines sent to slaughter. 9 CFR Sections 88.1-88.6. Changing a few words here and there in the regulations will not make transport of equines to slaughter humane. USDA/APHIS allows the kill buyers and haulers to fill out and provide the documentation - which is routinely missing, incomplete or inaccurate - relied on for enforcement. It is impossible to enforce regulations when the information to determine violations is supplied solely by the kill buyers and haulers, the very people USDA/APHIS is supposed to be regulating.

A 2010 Office of Inspector General report confirmed APHIS lacks the resources and controls to enforce regulations for humane transport of equines to slaughter. Not only is the information relied on for enforcement supplied by the kill buyers and haulers, APHIS continues to approve of new shipments to slaughter by kill buyers or haulers that have outstanding unpaid fines for violations of humane regulations. The current regulations do not give APHIS the authority to refuse approval.

OIG also found there is no adequate system for tracking the information, such as it is, that is supplied by the kill buyers and haulers about the horses. It is very difficult to track what happens to the horses, meaning enforcement is virtually non-existent. Also, APHIS often does not receive any information from kill buyers or haulers. OIG noted in 2011 that for the past year or more, APHIS had not received the required paperwork, owner/shipper certificates, from kill buyers or haulers for any horses sent from Texas to Mexico.

On top of that, APHIS only has two agents to try to enforce these regulations. Your agency is hamstrung by its own regulations and cannot assure humane transport of equines to slaughter. There is every reason to think your agency could not even begin to assure humane transport of horses within the U.S. to newly opened slaughter facilities.

Food Safety

The Food and Drug Administration ("FDA") does not regulate equines as food animals. Americans don't eat horses and other equines. American horses are not raised, fed and medicated within the FDA guidelines established for food animals, making them unfit and unsafe for human consumption. Equines are given all manner of drugs, steroids, de-wormers and ointments throughout their lives. Equines are not tracked and typically may have several owners. There is no way to know when they are sold for slaughter what these animals have ingested over their lives.

The danger of American horsemeat to consumers was confirmed in a study, "Association of Phenylbutazone (Bute) Usage with Horses Bought for Slaughter" that was published in Food and Chemical Toxicology and authored by Dr. Ann Marini, Department of Neurology, Uniformed University of the Health Sciences; Nicolas Dodman, DVM, Tufts University, and Dr. Nicolas Blondeau, The Institute of Molecular and Cellular Pharmacology.

A kill buyer has no idea of the veterinary or drug history of a horse or other equine taken to slaughter, and many of the most dangerous drugs have no or a very long withdrawal period. A typical drug given routinely to equines like aspirin, phenylbutazone or Bute, is a carcinogen and can also cause aplastic anemia in humans. It has no withdrawal period. The FDA bans bute in all food producing animals because of this serious danger to human health. The FDA and USDA would prohibit Americans from consuming horses because of this danger. Yet, neither the FDA nor the USDA prohibits the export of American horses for slaughter for human consumption. It is a grave risk to public health to continue to allow the export of American horses for slaughter for human consumption in other countries.

The European Union has recognized this and has initiated steps to try to stop the import into the EU of meat from American horses that may be contaminated. Kill buyers have been found to falsify veterinary and drug reports to avoid the restrictions. There is no enforcement at the borders, meaning the US continues to dump contaminated and deadly horsemeat on Europe and other countries. A petition has been filed with the USDA to stop the slaughter of many U.S. horses for this reason.

Conclusion

Mr. Vilsack, in view of all of this, why would the Obama administration allow, let alone facilitate as a priority, the opening of horse slaughter facilities in the U.S.? I would urge the administration to reconsider this and instead work with horse owners, animal welfare organizations, the 80% of Americans who want horse slaughter banned, and end this grisly practice once and for all. Equines are in danger and equine welfare is threatened as long as slaughter remains available.
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5/15/12

WSJ Serves Up Tainted Journalism On Horse Slaughter Plate






First the News Corp. phone-hacking scandal...now this?
Vickery Eckhoff Contributor
 
Wall Street Journal reporters Douglas Belkin and Nathan Koppel are in good company. On May 4, they published an article on horse slaughter so eerily similar to articles appearing in a variety of unrelated publications, even ol’ Rupert Murdoch himself might be left wondering.
How did they all end up using the same specific phrases and anecdotes? Twist so many of the same key facts? Quote the same people and ultimately, critically, leave out so much available data on the issue? Were journalists cribbing off a PR script prepared by the horse-slaughter lobby? Has anyone called Scotland Yard?
Origins of a Disinformation Campaign: Rebranding Slaughter

The horse-slaughter lobby represents a handful of powerful industries looking to bring horse slaughter back to the U.S.: meat packers and slaughter operators, for one thing. Cattle ranchers and the Farm Bureau. Then there’s the American Veterinary Medical Association (AVMA) and pharmaceutical companies (like the makers of  Read Premarin). Finally, there are the horse breeders and breed registries like the American Quarter Horse Association (AQHA) and American Paint Horse Association (APHA).
Naturally, they don’t like being identified as the “horse-slaughter lobby.” That sounds too mean. Instead, they call themselves “the horse industry.” This may sound like a generic classification for horse-related businesses and professionals, but it’s not.
You can own a racing stable, breed or show horses or run a veterinary practice, but if you’re among the 80% of Americans opposed to slaughtering horses, you’re not official “horse industry” according to “horse industry” people. They’ve appropriated that term to make their views seem mainstream, all while painting public opposition to slaughter as emotional and dangerous animal-rights driven extremism.
This is all a clever bit of disinformation, since 80% of the public is a very large group of Americans. It includes a long, bipartisan list of the members of Congress, business leaders and professionals both in and out of the horse world, entertainers and regular old Americans—all of them opposed to slaughtering horses in the U.S. or exporting them to slaughter.
Currently, horses are being exported to slaughterhouses in Canada and Mexico. This has been going on for years, even when U.S. slaughterhouses were open. What has changed is the provision for federal horse slaughter inspections ready to lunge forward thanks to a closed-door session that took place in November, 2011.
Essentially, three pro-slaughter U.S. Congressmen removed language banning inspections of horse-slaughter operations in an agricultural appropriations bill that was signed by Congress and President Obama.
The “horse industry” is doing all it can to seize the opportunity and push horse slaughter down the American public’s throat—with the right PR and the media’s help.
The distinctions—between the pro-and anti-slaughter sides and between foreign and domestic slaughter—are important for the public to know because key legislation is being pushed at the local, state and federal level.

Please read more about this great disinformation campaign here.

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5/4/12

An HSUS Report: Food Safety Risks Associated With U.S. Horse Slaughter



An HSUS Report: Food Safety Risks Associated With U.S. Horse Slaughter
April 2012
Abstract

Meat originating from U.S. horses may contain residues from substances banned by the U.S. Food and Drug Administration and the European Union for use in animals intended for consumption. Phenylbutazone, for example, is commonly administered to U.S. horses and has been associated with life- threatening reactions in humans. Requiring a thorough drug history for each U.S. horse intended for human consumption may help circumvent human health risks.

In t r o d u c t i o n

According to the Food and Agriculture Organization of United States, an estimated 9.5 million horses reside in the United States.1 The American Veterinary Medical Association defines the horse as a "companion animal," along with dogs and cats.2 Horses are utilized for service, recreation, and competition in the United States.3 Despite their multi-faceted views of the horse, the U.S. population largely considers the consumption of horse meat taboo.4 In the state of California, for instance, eating horse meat is restricted under the state's Criminal Code5 and horse slaughter is illegal in Florida6 and Illinois.7 Given the attitude towards equids and the lack of demand for horse meat in the United States, they are defined as non-food producing animals by the Food and Drug Administration (FDA).8

Despite the U.S. population's disinterest in horse meat, it remains a part of the diet of some consumers in other countries, such as France, Japan, and Italy.9 In 2007, a combination of state laws prohibiting horse slaughter and a simultaneous de-funding of United States Department of Agriculture (USDA) inspections by Congress10 lead to the closure of the few, mainly foreign-owned, horse slaughter plants that operated within the United States.11,12,13 In November 2011, this defunding of USDA horse slaughter inspections was omitted from a spending bill signed into law. While new funds are not being provided for the USDA's resumption of horse meat inspections, the ban on domestic horse slaughter has been lifted.14

The 2007 provisions did not end the slaughter of U.S. horses for human consumption. Rather, the closing of U.S. slaughterhouses almost doubled the production of horse meat in Canada in 2007, with approximately 40% of the horses being slaughtered imported from the U.S.15 In 2012, the European
Commission released their findings of a 2011 audit which noted that 85% of the horses slaughtered in a Canadian processing plant originated from the United States.16 The United States also exports its horses to plants in Mexico for local and foreign consumption.17

Since U.S. horses are primarily used for companionship and competition rather than consumption, drugs may be administered without taking food safety implications into account. This is especially pertinent in regards to the administration of the substance phenylbutazone (PBZ). The presence of PBZ - as well as many other FDA-banned substances - in U.S. horses destined for slaughter results in the high likelihood of contaminated horse meat, which poses a potentially serious risk to the health of human consumers.18,19

Phenylbutazone

In 1949 the potent non steroidal anti-inflammatory drug (NSAID) PBZ became available as a treatment in the United States for people suffering from both rheumatoid arthritis and gout. However, within three years of its availability, PBZ was linked to serious adverse reactions, including aplastic anemia, bone marrow depression, renal failure, and even death. After examining several case studies of PBZ use, the FDA banned PBZ for human use in the United States.20 According to the FDA:

“Phenylbutazone is known for its ulcerogenic, nephrotoxic, and hemotoxic effects in horses, dogs, rats, and humans. It is known to induce blood dyscrasias, including aplastic anemia, leucopenia, agranulocytosis, thrombocytopenia, and deaths. The reported adverse reactions were associated with the human clinical use of 200 to 800 milligrams phenylbutazone per day€¦.[I]t is unclear what level of exposure would be required to trigger such reactions in sensitive people. Moreover, phenylbutazone is a carcinogen, as determined by the National Toxicology Program (NTP) based on positive results in genotoxicity tests and some evidence of carcinogenicity seen in the rat and mouse in carcinogenicity bioassays NTP conducted.”21

For animals, the only FDA-approved phenylbutazone use is as an oral or injectable dose in dogs and horses.22,23 As it stands, PBZ use in humans and food-producing animals alike remains unapproved.24

Phenylbutazone in Thoroughbreds Bound for Slaughter: A Case Study

There can only be one winner at the end of each horse race, and many of the horses that do not place, show signs of injury, or are past their prime are sent to auction, and ultimately end up in slaughterhouses in Canada or Mexico.25 The European Union (EU) has found that horse meat originating from Mexican slaughterhouses contain harmful residues of several EU prohibited substances such as clenbuterol (bronchodilator), zilpaterol (used as a steroid substitute), and furanics (anabolic steroid).26,27 Due largely to over-breeding, the thoroughbred racing industry is one of the principal contributors to the estimated 133,241 U.S. horses slaughtered in 2011.28,29

Because of the intense training and racing endured by these horses, many develop musculoskeletal
injuries that trainers and owners treat with NSAIDs, of which PBZ is the common due to its legality in the racing industry. A study done by the Daily Racing Form found 99% of racehorses in California and 92% of horses at Suffolk Downs in Massachusetts are given PBZ on a regular basis.30 Certain racetracks allow only PBZ administration on race day, but all usage must be recorded on the horse's track record.31 This documentation requirement makes racing thoroughbreds convenient candidates for a case study of PBZ usage in U.S. horses bought for slaughter.

Nicholas Dodman of Tufts University Cummings School of Veterinary Medicine, Nicolas Blondeau of the Institut de Pharmacologie Moléculaire et Cellulaire, and Ann Marini of Uniformed Services
University of the Health Sciences conducted a study to investigate whether thoroughbred race horses were given PBZ prior to being bought for human consumption, and to see how widely the FDA ban on PBZ usage in horses that end up on consumers' plates is ignored. The study identified 50 thoroughbreds rescued from slaughter and 18 thoroughbreds that were sent to slaughter. Each horse's Jockey Club lip tattoo allowed the researchers to find the registered name of all 68 horses, and each horse's drug record was obtained from their race track records.32

Upon review of the records, one of the horses sent to slaughter was not documented as receiving PBZ but the drug was identified in his blood test results, and another thoroughbred was administered PBZ by a veterinarian in the same month he was sent to slaughter. The remaining 16 of the 18 horses slaughtered and all 16 of the rescued horses were recorded as receiving PBZ within 24 hours of a race. Data collected by the researchers determined that the time interval between horse's last known dose of PBZ and the date they were bought for slaughter varied from a week to four years. However, it is important to note that the FDA, the EU, the United Kingdom, and Canada do not allow any use of PBZ in horses intended for human consumption regardless of withdrawal time.33

Another important aspect in understanding the risk of PBZ contamination in horse meat is the circulation of PBZ in the bloodstream. Horses possess 1.76 times the amount of blood per pound of body weight compared to cattle. With this much blood, it is possible that high-volume slaughterhouses€”one Canadian slaughterhouse processed 100 horses a days€”do not allow sufficient time for the horse's blood to be completely drained from the muscle, increasing the risk of meat contamination.34

The findings of Dodman, et al., indicate a serious discontinuity between food safety regulations and practice. Horses with a history of PBZ use are making their way to slaughter plants despite the United States' and other countries' ban of the use of the drug in food producing animals.

The European Union's Evaluation of Imported Horse Meat

In 2010, The European Commission's Food and Veterinary Office (FVO) evaluated food safety standards of imported equine meat from third countries (non-members of the European Union).35 The FVO have found that many third countries - such as Mexico, Canada, and the United States - do not keep veterinary pharmaceutical treatment records for horses; and there are no systems in place to differentiate equines intended for human consumption from all other equines. The evaluations also reported that third countries tolerate the administration of substances that are prohibited or unauthorized in food-producing animals in the EU.36,37 The United States has no official controls in place to verify the authenticity or reliability of the medical records and equine documents now required for horses destined for slaughter, only records of physical identification are required.38 These discoveries prompted the European Commission to facilitate corrective measures to their own regulations regarding imported horse meat, and to require third countries to implement action plans addressing compliance with the EU's requirements regarding equine meat.39

Since 2000, the EU's regulations state that horse meat cannot contain residues of veterinary medicinal products exceeding previously set limits or residue from substances banned for use in food producing animals in the EU. These restrictions include phenylbutazone. If substances prohibited for use in food- producing animals are administered to equids, those animals must be excluded from the food chain.40 Finally, imported horse meat can only be authorized if equines are included in European Commission- approved residue control plans in third country slaughterhouses.41

Both Canada and Mexico have submitted action plans in order to comply with the EU's import requirements for equine meat, and both plans have been approved by the FVO.42

In Mexico, horses imported for slaughter are to be microchipped and border controls have been strengthened. A sworn statement on veterinary medical treatments is requested for all slaughter horses, no matter what their country of origin. United States providers of imported horses (holding facilities) have been targeted in samplings of the Mexican National Residue Monitoring Programme (NRMP). According to the NRMP nineteen samples of horse meat in 2008, nine in 2009, and six in 2010 tested positive for residues of banned substances. All of the horses who tested positive were covered by a declaration stating that no treatments were given to the horses, and all of these horses came from U.S. providers. 43

In Canada, the Canadian Food Inspection Agency (CFIA) has implemented the Equine Information Document (EID). The EID contains a physical description of the animal, record of the animal's medical treatment for the previous six months, and requires the signature of the animal's owner at the time of ownership transfer to verify that all information is accurate. Horses bought for intended slaughter must have their EIDs also signed by the transient agent responsible for the care of the equine from time of purchase for slaughter until arrival at the meat processing establishment. Each CFIA inspected facility engaged in equine slaughter must present an EID for all domestic and imported equines presented for slaughter. If the EID indicates a horse has been given a substance not permitted for use in equine slaughtered for food, such as phenylbutazone, the horse will not be eligible for slaughter.44 However, the 2011 FVO audit noted "for those horses imported from the United States of America for direct slaughter, the equine identification documents received were not reliable..." The audit further noted that 85% of the horses slaughtered in this Canadian processing plant originated from the U.S. and all of these horses were imported for direct slaughter.45 Considering cases such as the one above, as long as there is no identification system in place, U.S. horses will not meet the European Commission's new food safety regulations, which will become effective in July 2013.

The European Commission mandated a transitional period of three years in which third countries have to provide guarantees regarding medical and drug history for horses during their last six months before slaughter. After the three-year transition period - which ends in 2013 - guarantees must be provided for the lifetime of the horses.46 This policy would complement the EU's "horse passport" legislation, which requires records to be kept of certain medicinal products.47 This required lifetime guarantee that a horse be cleared of all EU prohibited substances for use in food-producing animals could eliminate virtually all U.S. horses from the food chain. The substances banned for use in food-producing animals routinely administered by U.S. horse owners render most American horses ineligible for foreign slaughter. 48

Conclusion

The slaughter of U.S. horses poses a potentially serious health risk to human consumers, yet thousands are still slaughtered and sold to consumers. New measures put in place in the European Union to address the human health risk associated with horse slaughter are vital steps to insure U.S. horses, who are regularly given phenylbutazone along with other EU-banned substances, are kept out of the slaughter pipeline.

Prevention needs to start within U.S. borders. The United States should look to the European Union's horse passport and Canada's Equine Identification Document (EID) benchmarks. Requiring accurate medical records and identification documents, regardless of the horse's intended use, would draw clear lines regarding each individual horse's eligibility for human consumption. Until such a system is in place, meat from American horses may pose a public health threat.
________________________________________________________________________

1 Food and Agriculture Organization of the United States. 2010. FAOSTAT Live Animals. faostat.fao.org/site/573/DesktopDefault.aspx?PageID=573#ancor. Accessed April 12, 2012.
2 American Veterinary Medical Association citing U.S. pet ownership & demographics sourcebook. 2007. www.avma.org/reference/marketstats/ownership.asp. Accessed April 12, 2012.
3 National Economic Impact of the US Horse Industry. 2005. Deloitte Consulting, LLP.
www.horsecouncil.org/national-economic-impact-us-horse-industry. Accessed April 12, 2012.
4 Whiting, T.L. 2007. The United States' prohibition of horse meat for human consumption: Is this a good law? Can Vet Journal 48(11):1173-1180, citing: Grudzen C.R., Kerndt P.R. 2007. The Adult Film Industry: Time to Regulate? PLoS Med 4(6): e126. doi:10.1371/journal.pmed.0040126
5 California Penal Code. Sec.598d. leginfo.ca.gov/cgi-bin/waisgate?WAISdocID=7456524612+8+0+0&WAISaction=retrieve Accessed April 12, 2012.
6 Regulation of Trade, Commerce, Investments, and Solicitations. Florida Statutes. 500.451.
www.flsenate.gov/Laws/Statutes/2011/500.451 Accessed April 12, 2012.
7 Illinois Horse Meat Act. Illinois Compiled Statutes 225 ILCS 635/1.5 www.ilga.gov/legislation/ilcs/ilcs3.asp?ActID=1381&ChapterID=24 Accessed April 12, 2012.
8 Food and Drug Administration. 2005. ANADA 200-334 Equizone 100 (phenylbutazone) Powder
Horses: For oral use in horses for the relief of inflammatory conditions associated with the musculoskeletal system. www.fda.gov/downloads/AnimalVeterinary/Products/ApprovedAnimalDrugProducts/FOIADrugSummaries/ucm061800.pdf. Accessed April 12, 2012.
9 Canadian Food Inspection Agency, Animal Health Division. 2009. Horse Meat Exports 2008.
www.agr.gc.ca/redmeat/rpt/08tbl39_eng.htm. Accessed April 12, 2012.
10 Federal Meat Inspection Act. 21 United States Code. §Â§ 601 et seq. uscodebeta.house.gov/view.xhtml?req=21+USC+601&fq=true&num=0&hl=true. Accessed April 9, 2012.
11 Empacadora De Carnes De Fresnillo De v. Curry. (United States Court of Appeals, Fifth Circuit) (No. 05-11499). January 19, 2007. http://asci.uvm.edu/equine/law/cases/cruel/slaughterhouse.htm. Accessed April 12, 2012.
12 Illinois General Assembly. 2007. HB1711, May 24. www.ilga.gov/legislation/publicacts/fulltext.asp?Name=095-0002. Accessed April 12, 2012.
13 Dodman, N.; Blondeau, N. & Marini, A.M. 2010. Association of phenylbutazone usage with horses bought for slaughter: a public health risk. Food Chem Toxicol 48(5):1270-1274.
14 Juozapavicius J. 2011. Horse Meat Inspection Ban Lifted in the U.S. Huffington Post, November 30. www.huffingtonpost.com/2011/11/30/horse-meat-consumption-us_n_1120623.html. Accessed April 10, 2012.
15 Alberta Farm Animal Care. 2008. The Alberta Horse Welfare Report: A report on horses as food producing animals aimed at addressing horse welfare and improving communication with the livestock industry and the public. http://equineenews.osu.edu/documents/HorseWelfareReport1-AFAC.pdf. Accessed April 11, 2012.
16 European Commission, 2011. Health and Consumers Directorate-General. Final Report of an Audit Carried Out in Canada from 13 to 23 September 2011 in Order to Evaluate the Monitoring of Residues and Contaminants in Live Animals and Animal Products, Including Controls on Veterinary Medicinal Products. ec.europa.eu/food/fvo/act_getPDF.cfm?PDF_ID=9456. Accessed April 12, 2012.
17 Wermund, B. 2011. Government study says more horses headed to Mexico for slaughter. Big Bend
Now July 14, 2011. www.bigbendnow.com/2011/07/government-study-says-more-horses-headed-to- mexico-for-slaughter. Accessed April 12, 2012.
18 Letter correspondance between Ann M. Marini, Department of Neurology and Program in
Neuroscience, Uniformed Services University of the Health Sciences, Bethseda, MD and Senator Jolie Justus, Missouri, May 3, 2010.
19 Dodman, N.; Blondeau, N. & Marini, A.M. 2010. Association of phenylbutazone usage with horses bought for slaughter: a public health risk. Food Chem Toxicol 48(5):1270-1274.
20 National Library of Medicine. 2010. Phenylbutazone. www.toxnet.nlm.nih.gov/cgi-
bin/sis/search/r?dbs+hsdb:@term+@rn+50-33-9. Accessed April 12, 2012.
21 U.S. Food and Drug Administration. 2003. New Animal Drugs; Phenylbutazone; Extralabel Animal Drug Use; Order of Prohibition. Docket No. 03N-0024. www.fda.gov/OHRMS/DOCKETS/98fr/03-4741.htm. Accessed April 12, 2012.
22 U.S. Food and Drug Administration. 2003. New Animal Drugs; Phenylbutazone; Extralabel Animal Drug Use; Order of Prohibition. Docket No. 03N-0024. www.fda.gov/OHRMS/DOCKETS/98fr/03-4741.htm. Accessed April 12, 2012.
23 U.S. Food and Drug Administration. FDA Approved Animal Drug Products: NADA Number: 010-987. www.accessdata.fda.gov/scripts/animaldrugsatfda/details.cfm?dn=010-987. Accessed April 12, 2012.
24 U.S. Food and Drug Administration. 2003. New Animal Drugs; Phenylbutazone; Extralabel Animal Drug Use; Order of Prohibition. Docket No. 03N-0024. www.fda.gov/OHRMS/DOCKETS/98fr/03-4741.htm. Accessed April 12, 2012.
25 Rhoden, W.C. 2011. Racing Should Care for Its Own. The New York Times, May 20, p. D5. www.nytimes.com/2011/05/21/sports/racing-industry-should-care-for-its-own.html?_r=1. Accessed April 12, 2012.
26 European Commission Health & Consumers Directorate-General. 2011. Final Report of a Mission Carried Out in Mexico From 22 November to 03 December 2010 in Order to Evaluate the Operation of Controls Over the Production of Fresh Horse Meat and Meat Products Intended for Export to the European Union as Well as Certification Procedures. ec.europa.eu/foodfvorep_details_en.cfm?rep_id=2639. Accessed April 12, 2012.
27 European Commission Health and Consumers Directorate-General. 2011. Imports of animals and their products from third countries. Sec 5.3.1.1. ec.europa.eu/food/food/chemicalsafety/residues/third_countries_en.htm#5.3.1.1. Accessed April 10, 2012.
28 Rhoden, W.C. 2011. Racing Should Care for Its Own. The New York Times, May 20, p. D5. www.nytimes.com/2011/05/21/sports/racing-industry-should-care-for-its-own.html?_r=1. Accessed April 12, 2012.
29 U.S. Horses Slaughtered Yearly. USDA Statistics courtesy of Darrell Charlton, Jr. www.equinewelfarealliance.org/uploads/00-Slaughter_Statistics.pdf. Accessed April 12, 2012.
30 Brown, A. 2010. Keeping Bute Out of the Food Chain. The Paulick Report, February 28. www.paulickreport.com/news/ray-s-paddock/keeping-bute-out-of-the-food-chain. Accessed April 12,
2012.
31 Dodman, N.; Blondeau, N. & Marini, A.M. 2010. Association of phenylbutazone usage with horses bought for slaughter: a public health risk. Food Chem Toxicol 48(5):1270-1274.
32 Dodman, N.; Blondeau, N. & Marini, A.M. 2010. Association of phenylbutazone usage with horses bought for slaughter: a public health risk. Food Chem Toxicol 48(5):1270-1274.
33 Canadian Food Inspection Agency. 2011. Ante and Post-mortem Procedures, Dispositions, Monitoring, and Controls-Red Meat Species, Ostriches, Rheas, and Emus. Meat Hygiene Manual of Procedures.
www.inspection.gc.ca/english/fssa/meavia/man/ch17/annexee.shtml. Accessed April 10, 2012.
34 Dodman, N.; Blondeau, N. & Marini, A.M. 2010. Association of phenylbutazone usage with horses bought for slaughter: a public health risk. Food Chem Toxicol 48(5):1270-1274.
35 European Commission Health & Consumers Directorate-General. 2009. Imports of equine meat from third countries. www.defendhorsescanada.org/residues.pdf. Accessed April 12, 2012.
36 European Commission Health & Consumers Directorate-General. 2009. Imports of equine meat from third countries. www.defendhorsescanada.org/residues.pdf. Accessed April 12, 2012.
37 European Commission Health & Consumers Directorate-General. 2008. Final Report of a Mission Carried Out in Mexico from 04 September to 11 September 2008 In Order to Evaluate Public Health Control Systems and Certification Procedures Over Production of Horse Meat Intended for Export to the EU. DG(SANCO)/2008-7979.
38 United States Department of Agriculture. 2011. Animal Disease Traceability: A Guide to Identifying Horses and other Equines for Interstate Movement. www.aphis.usda.gov/traceability/downloads/2011/FStrachorse.VS.pdf. Accessed April 10, 2012.
39 European Commission Health and Consumers Directorate-General. 2011. Imports of animals and their products from third countries. Sec 5.3.1.1. ec.europa.eu/food/food/chemicalsafety/residues/third_countries_en.htm#5.3.1.1. Accessed April 10, 2012.
40 European Commission Health and Consumers Directorate-General. 2011. Imports of animals and their products from third countries. Sec 5.3.1.1.
ec.europa.eu/food/food/chemicalsafety/residues/third_countries_en.htm#5.3.1.1. Accessed April 10,
2012.
41 Council Directive 96/23/EC On measures to monitor certain substances and residues thereof in live animals and animal products and repealing Directives 85/358/EEC and 86/469/EEC and Decisions
89/187/EEC and 91/664/EEC. European Parliament. April 1996. www.ec.europa.eu/food/food/chemicalsafety/residues/council_directive_96_23ec.pdf. Accessed April 12, 2012.
42 European Commission Health and Consumers Directorate-General. 2011. Imports of animals and their products from third countries. Sec 5.3.1.1.
ec.europa.eu/food/food/chemicalsafety/residues/third_countries_en.htm#5.3.1.1. Accessed April 10,
2012.
43 European Commission. 2010. Final Report of a Mission Carried Out in Mexico From 22 November to 03 December 2010 In Order to Evaluate the Operation of Controls Over the Production of Fresh Horse Meat and Meat Products Intended for Export to the European Union as Well as Certification Procedures. December 2010. ec.europa.eu/food/fvo/rep_details_en.cfm?rep_id=2639. Accessed April 12, 2012.
44 Canadian Food Inspection Agency. 2011. Ante and Post-mortem Procedures, Dispositions, Monitoring, and Controls-Red Meat Species, Ostriches, Rheas, and Emus. Chapter 17, E.2. June 2011. www.inspection.gc.ca/english/fssa/meavia/man/ch17/annexee.shtml#e2. Accessed April 12, 2012.
45 European Commission, 2011. Health and Consumers Directorate-General. Final Report of an Audit Carried Out in Canada from 13 to 23 September 2011 in Order to Evaluate the Monitoring of Residues and Contaminants in Live Animals and Animal Products, Including Controls on Veterinary Medicinal Products. www.ec.europa.eu/food/fvo/index_en.cfm?reptoshow=2. Accessed April 12, 2012.
46 Whitcomb R. 2010. EU standards could signal new challenges for veterinary records, horse transport, and slaughter. DVM Newsmagazine, August 1. veterinarynews.dvm360.com/dvm/Veterinary+Equine/EU-standards-could-signal-new-challenges-for- veter/ArticleStandard/Article/detail/682251. Accessed April 10, 2012.
47 European Commission. 2008. Commission adopts single passport and matching chip for horses and other equidae [Press release]. europa.eu/rapid/pressReleasesAction.do?reference=IP/08/905&format=HTML&aged=0&language=EN Accessed April 12, 2012.
48 European Commission Health & Consumers Directorate-General. 2009. Imports of equine meat from third countries. www.defendhorsescanada.org/residues.pdf. Accessed April 12, 2012.

The Humane Society of the United States is the nation's largest animal protection organization, backed by 10 million Americans, or one of every 30. For more than a half-century, The HSUS has been fighting for the protection of all animals through advocacy, education, and hands-on programs. Celebrating animals and confronting cruelty. On the Web at humanesociety.org. 
  
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4/16/12

State Officials, Humane Groups Oppose Proposed Horse Slaughter Plant in New Mexico

Reblogged from Horseback Magazine: http://horsebackmagazine.com/hb/archives/15151

State Officials, Humane Groups Oppose Proposed Horse Slaughter Plant in New Mexico

April 13, 2012
Governor and Attorney General Blast New Mexico Plant

WASHINGTON, (ASPCA —The Humane Society of the United States, the ASPCA (American Society for the Prevention of Cruelty to Animals), Front Range Equine Rescue and Animal Protection of New Mexico condemn plans to open a horse slaughter plant in Roswell, N.M.

The plans for the slaughterhouse were uncovered in an investigation by Front Range Equine Rescue, a Colorado-based equine rescue organization. The proposed facility would be operated by Valley Meat Co., LLC, a company in Roswell that has already applied with the U.S. Department of Agriculture Food Safety and Inspection Service for inspection of the slaughter of equines for human consumption. According to Front Range’s investigators, FSIS officials were scheduled to conduct a preliminary walk-through inspection of Valley Meat’s facility last month. USDA temporarily suspended inspections of cattle slaughter at Valley Meat Co. in February 2012 and November 2011 due to failure to comply with humane slaughter regulations.

“A horse slaughtering plant in Roswell is a terrible idea,” said New Mexico Attorney General Gary King. “Such a practice, while not illegal, is certainly abhorrent to public sentiment, and I strongly suggest it be abandoned. I come from a ranching family but processing horses for food was never part of the plan for raising livestock. Horses are different and should be treated differently.”

“As a veterinarian and someone who has had the great good fortune to grow up with and around horses, I am very saddened and angry about the recent revelations of mistreatment of horses in New Mexico,” said New Mexico State Land Commissioner Ray Powell. “If a horse is hurt, terminally ill, or has no chance to find a loving home, then humane euthanasia is a realistic alternative. I am told New Mexico is entertaining the idea of a horse slaughtering facility in our state. Since we do not have the horses in New Mexico to make this economically viable, it means horses would be trucked in from surrounding states. This is a bad idea on every level, and I strongly oppose it. New Mexico can do much better by these intelligent and gentle creatures.”

“Horse slaughter means tremendous suffering of horses, a proven history of environmental and waste violations, and allowing a toxic meat product to enter the human food chain,” said Hilary Wood, president and founder of Front Range Equine Rescue. “Solutions to horse slaughter include stopping irresponsible breeding practices, more gelding and euthanasia assistance programs, re-homing and re-training options, and short-term owner assistance programs. Horse slaughter has no place in the U.S. or across our borders.”

“American horses are our partners in sport, work and recreation—not dinner,” said Keith Dane, director of equine protection for The HSUS. “The entire process of horse slaughter is filled with nonstop terror, pain and misery for horses, and it is proven to have a severe negative impact on surrounding communities. It would be irresponsible for the federal government to sign off on a predatory industry that has no regard for animal or human welfare.”

“New Mexicans have a deep and enduring appreciation for horses, especially given their important role in our state’s rural way of life. It’s an affront to our citizens to suggest bringing the cruel, dangerous and polluting enterprise of horse slaughter to New Mexico as we celebrate our state’s centennial,” said Elisabeth Jennings, executive director of Animal Protection of New Mexico.
“The overwhelming majority of Americans are intensely opposed to this cruel practice, and as more people learn that we are allowing our horses to be shuttled off to gruesome deaths all for the sake of foreign gourmands, they are outraged, and opposition to this grisly practice is growing,” said Nancy Perry, senior vice president of ASPCA Government Relations. “Horse slaughter plants abuse more than just horses as they have proved economically and environmentally disastrous to communities in other states.”

In November 2011, Congress chose not to renew a ban on funding federal inspectors at horse slaughter plants in the United States, even though a similar provision has been part of the agriculture department’s spending bill for the past five years. That action opened the door for a return of horse slaughter to American soil, including taxpayer funded inspections of horse meat destined to be sent abroad, despite broad opposition in this country to the practice. A January 2012 poll commissioned by the ASPCA confirms that 80 percent of American voters oppose the slaughter of horses for human consumption.

When the last three horse slaughter plants in the U.S. closed, the surrounding communities cheered. These communities had endured water pollution, an unending stench of rotting blood and offal, and a negative stigma that caused other businesses to leave the community. The slaughter plants employed no more than a few dozen employees in low-paying, dangerous, high-stress jobs. In their quest for higher profits, the foreign-owned companies did their best to avoid paying property taxes and the fines levied against them for environmental violations.

Additionally, it is unclear how Valley Meat Co. or the USDA would address the medications, vaccines and other substances that are routinely given to American horses and are known to be poisonous if consumed by humans. Earlier this year, The HSUS announced its intention to pursue legal action if the federal government failed to follow required protocols to ensure that food safety and environmental review requirements were observed.

Last month, The HSUS joined Front Range Equine Rescue in filing a petition with the Food and Drug Administration to declare the meat of former companion, show, and working animals to be unfit for human consumption due to the risk of the meat containing toxic residues. Last week, the two groups filed a separate petition with the USDA to ban the slaughter for human consumption of such animals for the same reasons.

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4/10/12

Front Range Equine Rescue Discovers New Mexico Horse Slaughter Plant

Breaking News

FRONT RANGE EQUINE RESCUE DISCOVERS NEW MEXICO HORSE SLAUGHTER PLANT

April 10, 2012 (Larkspur, Colorado) -- Through its own investigation, Front Range Equine
Rescue (FRER) has discovered that Valley Meats Co., 3845 Cedarvale Rd., in Roswell, NM, has
applied for inspection of horses to be “custom slaughtered” and “processed” for human
consumption.  According to the facts uncovered, the facility has been involved in extended
discussions with the Denver office of the Food Safety and Inspection Service (FSIS).  The FSIS
inspects animals and meat in American slaughterhouses under the auspices of the U.S.
Department of Agriculture.

Horse slaughter for food is a national disgrace, given the iconic nature of American horses and
the especially brutal methods used to kill them.  FRER has mounted an extensive legal battle to
keep American horses from being slaughtered for food, in or out of the country, in light of last
November’s Congressional appropriation of funding for horse meat inspections.  In the last three
weeks, along with the Humane Society of the United States, FRER has filed two Petitions for
Rule-making [http://frontrangeequinerescue.org/front-range-equine-rescue-horse-slaughter.php],
asking the Food and Drug Administration (FDA) and the FSIS to enact rules and regulations
which would prevent American horses from being slaughtered.  The Petitions have gotten
significant attention, and FRER intends to continue to amplify its legal strategy for as long as it
takes to eliminate the possibility of horse slaughter in America.

If it is allowed to open, the Roswell plant would be the first U.S. horse slaughterhouse opened
since horse slaughter in the U.S. ended five years ago.  A recent poll shows at least 80% of
Americans oppose horse slaughter. Valley Meats and any other horse slaughterhouses must be
stopped, and the USDA and FDA must see the danger and illegality of producing horse meat
from American horses.  FRER calls on all concerned citizens and groups, in and out of New
Mexico, to support its efforts by contacting state, local and federal officials and voicing your
strong objection to the resumption of this horrific practice in America.  For more information on
how to help, contact info@frontrangeequinerescue.com.

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4/9/12

Why The Issue With Bute?

EATING HORSES

Int'l Fund for Horses

EU Drug Regulations, Phenylbutazone and the Disquieting Truth about Toxic Horse Meat

“BUTE” is by no means the only drug under scrutiny in the sport horse and racing industry however its metabolic activity and "decay life" in animal tissue is in direct contrast to many other legally permissible medications which are transient in nature and are biologically eliminated from the system over established intervals.

Of particular note however is the fact that “bute” is the most widespread anti-inflammatory in the global horse racing industry today. It is estimated that 98% of NA professional sport and pleasure horses have received phenylbutazone at some point in their lives and is widely used in other horse industry jurisdictions around the globe.

The kinetics and drug activity of phenylbutazone and its metabolites (e.g. oxyphenbutazone) are characteristic of a bi-exponential decay rate (the sum of two single exponential decays) meaning, in theory, that regardless of the elapsed time there will always be residuals present in blood plasma (i.e. the concept of infinite division). [1]

An exponential decay rate can be expressed in terms of "half-life" where one half-life represents the amount of time it takes for the substance undergoing "decay" to decrease by one half of the original concentration. Half-lives remain constant over the decay period and as the concentration approaches zero, the time to eliminate any residuals remaining in the system approaches infinity. In other words, there will always be some residuals present regardless of the passage of time.

Table 1 and Figure 1 together illustrate a simple model of exponential decay.
Of particular note is that regardless of the number of half-lives denoted by "n", the fraction or percentage of the original concentration of the substance under analysis will always be greater than zero.
Table 1: Exponential Decay Concept


Number of Half-Lives Elapsed


Fraction of Original Concentration Remaining


Percentage of Original Concentration Remaining


0


1


100


1


1/2


50


2


1/4


25


3


1/8


12.5


4


1/16


6.25


5


1/32


3.125


...


...


...


n


1/(2n)


100/(2n)
Where n = number of half-lives
Figure 1: Exponential Decay Curve Showing Persistence of Residues
Figure 1: Exponential Decay Curve Showing Persistence of Residues
Decades ago phenylbutazone, a compound originally used in Europe as a solubilizing agent for various analgesics given by intramuscular injection, was introduced to the drug compendium in the US for the treatment of rheumatoid arthritis and gout, nonetheless with fateful brevity.
Admitted in 1949, and shortly thereafter banned by the FDA for human use, by the year 2003 the ban extended to animals intended for human consumption given that investigation by FDA and State regulatory counterparts determined that phenylbutazone residues were discovered in culled dairy cattle. [2] [3]

At the time this did not include horses or dogs as in North America neither are considered food animals.

"Phenylbutazone (PBZ) was marketed in the United States for the treatment of rheumatoid arthritis and gout in 1952. Serious and often fatal adverse effects such as aplastic anemia and agranulocytosis appeared in the literature within three years of its use . . . . . The serious adverse effects of PBZ culminated in its unavailability for human use in the United States."
[4]
Apart from aplastic anemia (bone marrow suppression) and agranulocytosis (reduction in infection fighting white blood cells), phenylbutazone and its principal metabolite oxyphenbutazone have also been implicated in thrombocytopenia (low platelet count), leucopenia (decreased white blood cells), pancytopenia (reduced red and white blood cells and platelets), hemolytic anemia (abnormal breakdown of red blood cells) and can cause hypersensitivity reactions in the liver leading to death. [5]  Moreover, phenylbutazone is a carcinogen, as determined by the National Toxicology Program. [6]

Clearly there is apt rationale for banning phenylbutazone for human use as well as animals intended for human consumption both as a function of its toxicity and the causal certainty that residues will always be present to some extent in the blood and hence tissues of animals slaughtered for food.  Additionally, what is most disconcerting is that the lethal adverse effects in humans are not always dose-dependent and demonstrate unique outcomes contingent on a particular individual’s susceptibility. In essence what this implies is that even in small quantities phenylbutazone and its metabolites can have deleterious effects on human health. [7]

To this end, the FDA has banned the use of phenylbutazone in horses destined for slaughter.
Moreover, there are no farming associations that raise horses for food in North America (unless the AQHA can be considered eligible). And despite the fact that horse slaughter in the US has been outlawed since 2007, there is no pretense about what happens to more than 100,000 horses sold annually at auction who are shipped to Canada and Mexico. Once butchered, their meat is exported to European and Asian locales where it fetches top dollar and is considered a delicacy.

The fact is that the majority of these horses will be administered phenylbutazone during some point in their lives to relieve musculoskeletal pain and inflammation.
This in itself is not entirely inappropriate as there are valid reasons for its use in the treatment of lameness providing the recommended dosage is abided by, as there are also potential life-threatening side-effects to the horse (e.g. severe gastric ulceration).

Instead, the glaring inconsistency is the unmistakable fact that these horses enter the food chain; perhaps not in North America but elsewhere through export to foreign countries nonetheless. What’s more, since the residues of phenylbutazone and its metabolites reside primarily in the blood plasma of the tissues there is the complicating factor of the inherent differences between slaughtered cattle and horse carcasses.

"As stated above, almost all of the PBZ remains in the bloodstream. . . . To provide a point of comparison, a 1400 lb cow has 60 ml/kg body weight or almost 10 gallons or 0.71 gallons per 100 lbs of cow. The ratio is 1.25/.71 = 1.76:1. Thus, a horse has 1.76 times as much blood per pound of body weight compared to a cow." [8]

Potentially this means that there is a calculated measure of risk of the presence of higher concentrations of toxic residues in horse meat than in beef. In actual fact there is no "risk" of higher concentrations in horse meat in light of the fact that the drug has been banned in other animals, such as cattle for example, intended for human consumption since 2003:  the residues are undeniably higher in horse meat. Still the quandary exists.

"The FDA, like the EU and UK, specifically bans the use of PBZ in any horse destined for slaughter for human consumption. Yet, this ban is being circumvented because there is no pre-slaughter mechanism to determine and remove horses that receive PBZ during their lifetime. This is because horses are not regarded as or treated as food-producing animals in the United States and there are no USDA regulations to prevent them from being given banned substances like PBZ." [9]

Horses may not be perceived as food-producing animals in the US, but they are certainly treated as if they are in the same appalling manner.
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"From my earliest memories, I have loved horses with a longing beyond words." ~ Robert Vavra