Fighting Goliath

This letter from Creekstone to the USDA raises a few good points, especially at the end which I have here:

IMPORTANT QUESTIONS FOR USDA TO ANSWER

What legal grounds (policies/regulations) would prohibit a private industry from performing a Rapid Test method for BSE? If testing young cattle is not a food safety issue, does it fall under APHIS or FDA?

Why does the Federal Register prohibit saving of small intestine unless the animal is BSE tested?

You have stated that BSE does not occur in cattle under 30 months of age. Why have you prohibited all specified risk materials (SRMS) from all age groups of cattle processed? What is the science behind this decision?

How does USDA certify and approve domestic and international sales/production of natural or organic beef products? This would be an implied Consumer Safety Aspect that is not scientifically warranted. You have stated that BSE testing is an “Implied Food Safety Aspect that is not scientifically justified”. How does this differ from natural or organic products? If testing is approved, why can’t a label state “BSE tested”?

How can the USDA justify spending $72,000,000 in taxpayer funds to test 221,000 head of cattle in 12 months ($325/head), when a private company will use the same test method as APHIS to test 300,000 head for $5,400,000 paid for by consumers in 12 months ($18/head)? Also, this private company can fully implement testing in one week, why will it take APHIS five months to fully implement their program? Complete preparation and training took Creekstone Farms one month.

Why is the USDA not immediately allowing Canadian cattle under 30 months of age to be sold into the US? If there is any concern, could Creekstone test Canadian cattle?

Given the USDA position that BSE testing is not scientifically justified what exactly are the statistical odds and how do you rationalize not giving the people a choice? There have been young cattle (under 30 months) in Japan and England testing positive for BSE.

What will be the government’s position if a major domestic customer requires packers to do something BSE-related that is not scientifically justified? Will the packer be told he cannot do it?

What is the statistical rate of error determining cattle age using dentition?

All valid points but a couple questions stand out, especially the ones concerning money. I wasn't aware that the one-time testing of 221,000 cattle would cost so much money: 72 million. Terrible, considering a cheaper alternative is available.