From: Anil K. Subramani [aks_mail@yahoo.com]
Sent: Wednesday, December 27, 2000 9:09 PM
To: FDADockets@oc.fda.gov
Subject: Re: Docket Number 98P-0151/CP1

I am writing to urge you to grant petition 98P-0151/CP1, prohibiting
the slaughter of downed animals.  Here are three grounds you may want
to consider:

(1) I understand that the meat and dairy industries have a term for
animals diseased or injured so badly that they can barely walk --
"downers."  What I don't understand is, how animals so incapacitated
may still be seen as being fit (i.e., safe) for human consumption.

(2) Evidently, I am not alone in reasoning as I just did.  The U.S.
Department of Agriculture stated, last year, that it will not accept
(for federal programs) "ground beef that includes product from
non-ambulatory cattle."  Doubtless, the inclusion of even a small
fraction of downed animals poses increased health risks---through
disease and bacterial contamination---to the consumer.

(3) Prohibiting the slaughter of downed animals will cause no undue
economic hardship.  Not only that, industry experts have estimated that
most incidences (about 90%) of downed animals can be prevented through
better care and handling.  Removing the market for downed animals will
provide an incentive for minimizing the number of downers.

Please do something about this.  I look to you to protect the interests
of the average consumer.

Sincerely,

Anil K. Subramani, Ph.D.


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