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A Special Report compiled by MLT

"Food Safety" 

USDA Releases Final Organic Rule
  Starlink - Biotech Corn in Question
  Mad Cow: The BSE Crisis in Europe
Anti-Biotics on the Farm: NYTimes etc.

USDA Releases Final Organic Rule

(from Organic & Natural Online)

USDA Releases Final Organic Rule

After a decade in the works, on December 20th USDA released its final rule for implementation of the National Organic Program.

WASHINGTON--December 20th, The U.S. Department of Agriculture (USDA) released its final rule for implementation of the National Organic Program (NOP). A decade in the making, the rules are a prime example of a private-public partnership, said outgoing U.S. Secretary of Agriculture, Dan Glickman. "We said that we would deliver standards that could be embraced by farmers, industry and consumers alike, and we have done exactly that," he said. "Now it's time to take the next steps to fully embrace organic agriculture and give it a more prominent role in the farm policy of the 21st century."

Industry members were primarily positive on the final rule. "It's a bright day in Washington and for the organic industry," said Katherine DiMatteo, executive director of the Organic Trade Association (OTA). "The rule is a good, strong regulation and one that will move the organic industry forward." DiMatteo noted that the rule was not perfect, and that there are areas the OTA will hope to address, but that overall it is "quite acceptable."

USDA received almost 41,000 comments on the revised proposed rule, which it issued in March 2000, and incorporated those comments into the final rule. The final rule will become effective 60 days after its publication in the Federal Register (currently scheduled for Dec. 21) and will be fully implemented 18 months after the effective date. Not surprisingly, USDA stayed true to its word given when the proposed rule came out in March and will not allow use of irradiation, sewage sludge or genetically modified organisms (GMOs) in organic production; however, there were some changes made in the final rule, some of which are listed below.

* Products labeled as "made with organic ingredients" must have at least 70 percent organic ingredients, up from 50 percent in the March proposal. According to the final rule, the increased percentage brings the U.S. regs in line with those of Europe.

* Manufacturers may state the exact percentage of organic ingredients on the principal display panel.

* A "whole herd" clause now exists for transitioning organic dairy herds. The one-time allowance permits farmers to transition for nine months at less than 100% organic feed, with the final three months at 100% organic feed. "This one-time exception to using 100-percent organic feed is critical for conversion to organic given today's record low milk prices," said Amy Forgues, a member of the Organic Valley farmer cooperative, during the USDA press conference.

* Wine containing sulfites can be labeled as "made with organic grapes."

* The USDA seal to be used only on products containing 95% or more organic ingredients has been redesigned. The new seal is a green and white circle stating "USDA Organic." The change from a badge, which looked similar to that used for other USDA inspected grading programs, was in response to comments that the seal made organic products look "better" or "safer" than conventional items. "The organic label is a marketing tool," Glickman said. "It is not a statement about food safety. Nor is 'organic' a value judgment about nutrition or quality." The seal may not be used until the full 18-month implementation phase has passed.

* Products containing 95-percent organic ingredients must provide documentation that the remaining ingredients are not commercially available as organic. USDA will be taking comments for 90 days on this issue, including how to enforce it and the burden it will place on producers. "I think USDA made a wise decision to put 'commercial availability' in there even though it's a hard term to define," said Joe Smillie, senior vice president of Quality Assurance International (QAI). "It's much more safe to say 'you don't need to do it,' but USDA took the hard road, which is the correct road."

Some issues of concern that industry members commented on were not changed in the final rule. For example, products containing 70 percent or more organic ingredients still have the obligation to ensure that the conventional ingredients used were also not produced with excluded methods, such as GMOs or irradiation. Also, a transitional organic label, requested by many industry members, was not permitted in the final rule because "it is unclear what marketplace value such a label might have, and [USDA is] concerned that allowing such a label at this point might lead to greater consumer confusion rather than providing clarity." DiMatteo said that while the transitional label is something the industry was hoping for, it will likely not petition immediately for that label, but will assess the best way to proceed on that and other priorities to be addressed in the implementation.

USDA also decided that most issues brought up by commenters about GMOs are outside of the scope of the organic rule. While there is still no allowance for GMOs in organic production, the rule does not require buffer strips for conventional farmers or establish liability for genetic drift onto organic operations. In addition, the presence of genetically engineered material in an organic product would not necessarily violate organic certification or status.

Overall, the organic industry was celebrating in the initial hours after release of the final rule. "The national regulations will change the face of the organic industry," said Gene Kahn, founder and chief executive officer of Small Planet Foods, a division of General Mills. "We expect to see the organic industry blossom under the new USDA regulations." Added Smillie, "Kathleen Merrigan and Dan Glickman have done a really good job addressing our concerns, including some of the more delicate concerns like GMOs. They've been paying a lot of attention lately, and did a great job overall."

In Glickman's address, he also stated that USDA passed a cost-share program to help small producers in 15 states receive organic certification; this was seen as another spot of good news. "OFRF has insisted that the USDA adopt strict and transparent rules from the beginning and will continue to advocate for a fair share of our public agricultural research and education resources," said Bob Scowcroft, executive director of the Organic Farming Research Foundation (OFRF). "Organic farming is the brightest hope for a prosperous and sustainable future in our fields and on our tables."

For more information, or to view the final rule, visit www.ams.usda.gov/nop/.

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U.S. Sets 'Organic' Standard
USDA Seal to Debut On Foods in 2001

National Organic Program

By Marc Kaufman
Washington Post Staff Writer

Thursday, December 21, 2000

The federal government yesterday established the country's first official definition of "organic," giving consumers a reliable way to buy fruits, vegetables, meat and dairy products produced without the use of pesticides, genetic engineering, growth hormones or irradiation.

The Department of Agriculture unveiled the standards after a contentious decade-long debate between proponents of organic farming and the conventional food industry, which feared that an official government "organic" label would unfairly stigmatize their products.　The final version endorses many of the positions promoted by the organic food industry and acknowledges the growing popularity of organic foods, which are promoted as less damaging to the environment and perhaps of higher quality. The U.S. organic food industry sold $6 billion in products last year ? only 2 percent of the nation's food sales ? but is growing much faster than the conventional food industry.

The "USDA Organic" seal will begin showing up on products by next summer, replacing the hodgepodge of unofficial and state definitions of "organic." The next administration could challenge or try to modify the new rule, but that is considered unlikely because it has gone through an extensive, public rulemaking process.　An earlier version allowed conventional farming practices such as spreading sewage sludge as a fertilizer and using pesticides and biotechnology to control weeds and pests, but it was met with unprecedented protests from organic producers and consumers.

"I am proud to say these are the strictest, most comprehensive organic standards in the world," Agriculture Secretary Dan Glickman said.　Although Glickman embraced organic foods yesterday ? saying he sometimes buys organic frozen foods ? he made clear that the new organic seal does not imply that foods are either safer or more nutritious.　"The organic label is a marketing tool," he said. "USDA is not in the business of choosing sides, of stating preferences for one kind of food, one set of ingredients or one means of production over any other."

The conventional food industry has fought many provisions of the organic proposal since legislation mandating a national organic standard was passed by Congress in 1990. Just recently, the National Food Processors Association asked the USDA to require that the organic labels include a statement saying the products are no more safe or nutritious than conventional foods. In the end, the USDA did not require the disclaimer but did modify the label design by dropping the traditional USDA shield and eliminating "certified" from the seal.Yesterday, the Grocery Manufacturers of America said it still opposes many aspects of the organic rule and wants the department to monitor how consumers understand the new label.

"If there is evidence that consumers believe it means they are buying a safer product, then we want the USDA to pull the seal because the seal has nothing to do with food safety," said Susan Ferenc, the group's vice president for science and regulatory policy.　Katherine DiMatteo, executive director of the Organic Trade Association, agreed that an organic label does not promise a necessarily safer product, although consumers often believe that it does. But she said that because of the specific practices that organic farming employs, it can fairly claim to produce food in a way that is safer for the environment.

"There are no pesticides or low-level antibiotics in organic farming, and you don't see the vast fields of one single crop with organic, either," she said. "Organic farming does not harm the environment like some conventional farming, and we think there is a safety and health benefit to that."　To qualify for the organic seal, a farmer must follow a detailed blueprint for how crops are planted and grown, how animals are raised and how waste is treated. The approach emphasizes the raising of crops in a "sustainable" way that conserves soil and encourages biodiversity; and animals are to be raised outdoors as much as possible and with access to pastures to ensure their welfare.

The National Organic Program will not include inspectors to examine apples or cheeses to determine whether they are organic but will rely instead on certifying agencies that the USDA will accredit.　Most of the 12,200 organic farmers nationwide are small-scale producers. The new label is expected to be a particular boon to organic farmers who want to export their products. There is fast-growing demand for organic food in Europe, but the absence of a single national standard has kept the export level low.

Glickman announced the new standard at a recently opened Fresh Fields supermarket near 15th and P streets NW, the second Fresh Fields to open in the Washington area since summer. The stores are owned by Whole Foods Market Inc., which specializes in organic and health foods nationally. Despite its premium prices, the chain has grown dramatically in recent years, and its stock price has remained high despite the recent Wall Street downturn.

"A lot of boomer moms are willing to pay the extra for organic products, and so it's gaining market share," said Mark Husson, who analyzes the food industry for Merrill Lynch in New York. He said Whole Foods sales have grown 8 percent over the past year, "and no other food retailer is growing like that." He speculated, however, that consumers might be less likely to buy more costly organic foods if the economy weakens.

About 0.2 percent of U.S. cropland was certified as organic in 1997. (In Europe, where farmers can get government help converting to organic agriculture, 1.5 percent of farmland is organic.)　　DiMatteo said she expects that organic food sales will increase from their current 2 percent of sales to 5 percent within 10 years, especially now that many large food companies are buying organic producers and encouraging more organic farming.

"This whole movement is being driven by consumers, who like the way that we produce our foods," she said. "With this national standard, we're on a sound base to grow a lot more."

c 2000 The Washington Post Company

Starlink - Biotech Corn in Question

　

website November 28, 2000

press releases

PROTESTERS DEMAND EPA NOT ALLOW STARLINK ANIMAL FEED CORN IN HUMAN FOOD EPA to say if StarLink will be approved after massive contamination of U.S. food supply.

ARLINGTON, Va., - In the face of strident protests, the Environmental Protection Agency today met with scientists to help determine if a variety of animal feed corn should be approved for human food. Activists from Greenpeace, wearing chicken, cow and sheep masks, gathered outside the meeting around a feeding trough full of corn and displayed a banner reading, "EPA: Don't Test Gene-Altered Corn on Us." The genetically engineered corn, called StarLink, has been allowed to illegally contaminate the U.S. food supply, leading to the recall of hundreds of popular foods.

"EPA's process is fatally flawed," said Charles Margulis, Greenpeace genetic engineering specialist. "Instead of punishing Aventis for illegally contaminating our food, the agency is on the verge of orchestrating a corporate bail-out. Industry will never again take any EPA regulation seriously if the agency lets Aventis off the hook now." EPA originally allowed Aventis, the biotech firm that developed StarLink, to sell the seed on the promise that the company would insure that none of the harvested corn would be used for human food. Despite scientific concerns about the safety of StarLink, EPA is considering Aventis' request to retroactively approve the corn in food.

"EPA must hold Aventis responsible for contaminating our food, not reward them for it," added Margulis. "This corn must not be tested on our children simply for the convenience of the biotech industry." EPA has acknowledged that a year ago it found that Aventis could not account for all the StarLink corn grown by farmers - a sign that StarLink may have contaminated the food supply. Yet the agency took no action. When environmental watchdogs discovered Star-Link in supermarket foods, the agency still took no action. However, when it became clear that Aventis was facing losses that could approach $1 billion, EPA announced a rushed process by which StarLink could be retroactively approved.

StarLink corn produces an insecticidal protein called Cry9C that could cause dangerous allergic reactions in some people. The EPA's review of StarLink found that many of the allergenicity data submitted on StarLink were "either inconclusive or indicate that Cry9C exhibits some characteristics of known allergens." In October, an EPA advisory panel heard from scientists who warned that there is no known safe level of allergens in food.

Last week, Aventis admitted that a corn seed variety sold to farmers in 1998 was contaminated with Cry9C. Such contamination, which could have resulted from pollen flow from StarLink corn to other fields, casts serious doubts over Aventis' claims that it can now assess consumers' exposure to the potentially dangerous protein.

Please see our list of spokespeople for more information.

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Genetically altered corn mix-up 
results in huge mess for U.S. farmers

By MATT CRENSON - The Associated Press
(All content 2000 The Kansas City Star)

Date: 12/02/00　

Larry Bohlen had just one item on his shopping list when he went to the Silver Spring, Md., Safeway in the summer: corn. Everything Bohlen put in his cart had corn in it. He tossed in corn chips, corn meal, corn flakes. By the end of his shopping spree, he had collected 23 products containing corn. It was not a craving that motivated Bohlen; it was a hunch. He bet he could prove that a genetically engineered crop not approved for human consumption had reached supermarket shelves. He took the groceries to his office at the environmental group Friends of the Earth and packed them into six cardboard boxes. He then mailed them to Genetic ID, a laboratory in Fairfield, Iowa. At the lab, technicians methodically crumbled the groceries into powder and then performed genetic tests worth $7,000.

On Sept. 18, Bohlen released the findings at a news conference convened by Genetically Engineered Food Alert, a coalition of environmental and consumer groups: The tests had found traces of a genetically engineered variety called StarLink in taco shells made by Kraft Foods. StarLink is not approved for human consumption, because of concerns that eating it might cause allergic reactions, Bohlen said. Bohlen's stroll through the neighborhood Safeway has paralyzed a whole sector of American agriculture, diverting grain shipments from their destinations, jeopardizing exports of U.S. corn, and threatening consumer confidence in the safety of genetically modified foods. In some places it has become difficult to find a yellow corn tortilla.

III

By tracing the corn from the Silver Spring Safeway, Kraft determined that the troublesome crop had been grown in the 1999 season and milled at a plant in Plainview, Texas. Officials at the plant said they had no idea where the unapproved corn originated. A recall ensued. Grocers pulled Kraft taco shells and tortilla chips off the shelves, and then, as other companies discovered StarLink in their products, more recalls went out. Mission Foods, the country's largest manufacturer of tortilla products, recalled nearly 300 products. By Sept. 26, Aventis, the biotechnology company that developed StarLink, suspended sales of the technology to seed companies. By then, this year's StarLink crop, more than 300,000 acres' worth, stood waiting to be harvested. Some farmers were already hauling it to grain elevators.

Even though StarLink amounted to less than 1 percent of the corn grown in the United States this year, that tiny amount tainted billions of bushels. One expert estimated that half of Iowa's corn crop would end up mixed with StarLink. Giant food processors such as Archer Daniels Midland and ConAgra began testing incoming shipments for StarLink, turning away whole rail cars of corn. Larry Stayner, manager of the Farmers Co-op Exchange in Prairie City, Iowa, said an Archer Daniels Midland plant rejected 38 rail cars of his corn in September. The rejected corn later was used to feed chickens in Alabama.

By November, StarLink corn began showing up in grain shipments to Japan, where, surveys show, public suspicion of genetically engineered crops is greater than in the United States. Exports to Japan, the largest foreign market for U.S. corn, suddenly dropped more than 50 percent, according to federal figures. South Korea, the second largest consumer of U.S. corn, banned it outright. It was clear by then that procedures intended to keep StarLink out of the food supply had broken down. Things got even messier when the Garst Seed Co. announced that one of its corn hybrids contained the StarLink gene even though it was not supposed to. The company is still investigating how the mistake occurred.

III

When the Environmental Protection Agency approved StarLink for sale, the company that developed it swore that the variety would be kept out of the human food supply. Agrevo, which became part of Aventis about a year ago, first submitted StarLink for EPA approval in September 1997. Agrevo had genetically engineered the strain to synthesize its own natural pesticide, making the corn resistant to several destructive insects.

The agency had already approved several corn strains genetically modified to make the same type of chemical, but this time the agency balked. Tests showed that the StarLink insecticide was resistant to digestion in the human stomach. Indigestibility is common among food allergens. An EPA scientific advisory panel worried that after prolonged exposure, some people might become allergic to StarLink.

The scientists were being cautious. After all, there was no evidence that StarLink was allergenic, just the possibility that it might be. Nevertheless, without more tests, the panel hesitated to recommend that StarLink be approved for human consumption. Agrevo agreed to do more tests. Meanwhile, the company proposed approving the corn for animal feed and ethanol production. That would minimize health concerns and allow the company to sell StarLink for the 90 percent of the U.S. corn production that does not go into human food. The agency agreed, provided that the company took responsibility for keeping StarLink out of the human food supply. In January 1999, Agrevo submitted a detailed plan in a letter to the agency.

When farmers bought StarLink seed, they would be told that corn grown from it could not be sold for human consumption. They also would sign an agreement to that effect. The seeds would come with a "Grower Guide" repeating the restrictions, including the need for a 660-foot buffer strip between StarLink and any other corn varieties. Any corn grown within 660 feet of StarLink would also have to go to a feedlot or an ethanol plant.

III

That is not the way it happened, say several farmers. Many of them think Aventis and the EPA should have known that such an effort was destined to fail. For the plan to work, information about StarLink would have to be passed from Aventis to the seed companies; the seed companies then would communicate it to its dealers, who in turn would tell farmers who bought StarLink. Sometimes the message got through. Jeff Lacina, a spokesman for Garst Seed Co., said the company informed all 3,500 of its dealers about the rules governing StarLink. And Sharon Greif, a Garst dealer in Linn County, Iowa, says she received that information and would have passed it to any customers who purchased the seed.

In many other cases, however, the message about StarLink did not get through.

Ralph Klemme knew when he planted StarLink on his La Mars, Iowa, farm in the spring that it could be sold only for animal feed or ethanol production. He says, however, that nobody ever asked him to sign a grower agreement or said anything about a 660-foot buffer strip. Klemme, chairman of the Iowa House of Representatives Agriculture Committee, planted his StarLink corn right in the middle of fields he intended to sell for human consumption.

Klemme had not harvested those fields when an Aventis representative appeared on his farm Oct. 4. The man told Klemme not only would the 24 acres of StarLink have to go for animal feed, but also the 34 acres planted adjacent to it. He also offered Klemme a deal for his StarLink-tainted corn: 25 cents a bushel above the market price. Under pressure from the federal government, Aventis was trying to buy back corn it sold for planting in 2000. By late October the company had managed to account for 98.5 percent of this year's crop. Most of it was sitting in storage on the farms where it was grown.

Now farmers all over the Midwest have about 50 million bushels of StarLink corn sitting on their farms, and they have no idea what to do with it.

Mad Cow: The BSE Crisis in Europe

　　
A. BSE cases confirmed in cattle. Belgium, Denmark, France, Germany, Ireland, Luxembourg, the Netherlands, Portugal, Spain, Switzerland and the United Kingdom.

B. Likely to have BSE in domestic cattle, but no confirmed cases. Italy.

C. Unlikely to have BSE in domestic cattle, but it cannot be excluded. Austria, Canada, Finland, Sweden

D. Highly unlikely to have BSE in domestic cattle. Argentina, Australia, Chile, New Zealand, Norway and Paraguay. den and the United States.

　

　

Europe Takes Toughest Steps to Fight
MadCow Disease

New York Times December 5, 2000

By SUZANNE DALEY

ARIS, Dec. 4 Moving to calm growing fears over mad cow　disease, the European Union today voted its most drastic measures yet to try to control the spread of the fatal illness. In a special emergency session, the　union's agricultural ministers voted to ban the use of feed laced with animal products, not just for cattle but for all farm animals, for at least six months. In addition, all cattle over the age of　30 months are to be removed from the food chain tested to make sure they are disease free. As testing capacity is limited, this is likely to mean that two million head of cattle in the union's 15 member countries will be slaughtered.

Both measures are expected to be costly. Union officials estimate that the feed ban ?intended to prevent cattle from eating, even accidentally, infected animal parts that can transmit the disease ?will cost nearly $4 billion a year. The removal of older cattle from the food chain will cost another $800 million, officials said. Evidence of mad cow disease has never been found in young cattle.

"The crisis we have to come to grips with is an unusual one," said Franz Fischler, the European Union's agricultural minister, after emerging from the　nine-hour meeting. "It needs unusual measures." The measures come as most European countries have been struggling with a growing panic among consumers about the safety of beef. Wholesalers in several countries have reported a drop in sales of nearly 50 percent in the last few weeks.

The recent panic began in France, where the number of reported cases of mad cow has increased dramatically this year, in part due to increased testing. Last year, France counted 31 cases. This year, it already has more than 110. But the panic soon spread throughout Europe ?especially when Germany and Spain, which had never reported cases, said two weeks ago that they too had diseased cows.

Since then, health and agriculture officials have been scrambling to reassure consumers that everything is being done to protect them. Several countries　 have announced new measures of their own, including increased testing and new bans on beef from France. These bans are to be reviewed by the union's scientific steering committee to decide whether they are appropriate.

The European Union action tonight was devised to offer a Europe- wide approach to the problems. In many ways, it mirrors the actions that Britain took years ago to combat its own epidemic. Britain has recorded more than 170,000 cases of mad cow, far more than any other European country. Much about mad cow disease, also known as bovine spongiform encephalopathy, remains a mystery. But scientists believe that cattle originally contracted the disease by eating feed made with tissue from sheep infected with a related neurological ailment, scrapie. Experts believe that the fatal disease it is caused by aberrant proteins called infectious prions, which leave the brain with spongelike holes.

More than 80 people have died in Britain and two in France from the fatal human equivalent, new variant Creutzfeldt-Jakob Disease, which has been linked to the infected beef. The incubation period is believed to be up to 25 years, and so health officials have warned that the toll may rise sharply. European Union officials said tonight that the ban on animal parts in feed won easy approval from a majority of members, though some countries objected. Officials said Finland, for instance, did not want to apply the ban because it did not yet have any cases of the disease.

Much of the cost involved in banning the animal parts in the feed will be for storing and incinerating the three million tons of ground up bones and intestinal parts that are a natural waste product of Europe's meat industry and that have until now been used to enhance animal feed. Some of the feed is used as fuel in cement factories, and there is some hope that more will be used for that purpose. But much of it may simply have to be destroyed. Animal parts have been fed to cows and other farm animals as a source of protein since World War II. Banning them is likely to have have serious trade implications for the European Union as farmers will now have to find a way to replace it. One alternative would be to buy soy meal from the United States. But the ministers voted at the last minute to exclude fish meal from the ban, meaning farmers will still be able to feed those products to pigs and chickens, deflecting some of the potential need to import soy. The European Union as farmers will now have to find a way to replace it. One alternative would be to buy soy meal from the United States. But the ministers voted at the last minute to exclude fish meal from the ban, meaning farmers will still be able to feed those products to pigs and chickens, deflecting some of the potential need to import soy.

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Other news sources around the globe

From the newsroom of the BBC World Service

Saturday, 30 December, 2000, 22:33 GMT

China bans animal-feed to stop BSE

China is to ban all animal-based feed imports from European Union countries, in an attempt to prevent the spread of the cattle disease, BSE or Mad Cow Disease. Announcing the ban, the official Chinese news agency, Xinhua, warned that all government departments should take rigorous measures to stop the spread of epidemics like Mad Cow Disease.

Xinhua said any one who flouted the ban would be punished. BSE-contaminated meat can cause the fatal disease, CJD, in humans. Most BSE cases in cattle have been found in Britain, with other European countries also reporting cases. It is believed cattle contract BSE through eating contaminated animal-feed.

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Friday, 5 January, 2001, 08:29 GMT

Fresh ban on European beef

Dump your Euro sausages, consumers and retailers told

Australia and New Zealand

have announced a total ban on the import of beef products from 30 European countries because of fears of "mad cow" disease. A joint statement by the Australia-New Zealand Food Authority (ANZFA) said the ban followed confirmation that mad cow disease - or bovine spongiform encephalopathy (BSE) - had spread well beyond the UK. Australia and New Zealand have one of the safest food supplies in the world - and the current steps are intended to keep it that way.

Food Authority's Managing Director

The announcement comes as the German Government holds an emergency meeting to discuss its growing BSE crisis. ANZFA's managing director, Ian Lindenmayer, said that, although there was only a very small possibility that any of the European products were contaminated with BSE, the new measures would further reduce the risk. "Australia and New Zealand have one of the safest food supplies in the world - and the current steps are intended to keep it that way," he said.

Japan's ban

The ban applies to the 15 European Union countries and another 15 countries in Scandinavia and Eastern Europe. Australia does not import fresh beef, only beef products.

A ban on British beef has been in force since 1996, when scientists linked BSE to the fatal brain-wasting disease Creutzfeldt-Jakob Disease (CJD). Last month, Japan also decided to ban imports of EU beef, processed beef foodstuffs and cow sperm. China has also banned EU meat-based animal feeds. Agriculture Minister Warren Truss said the decision had been taken in order to protect Australia's status as a country free from mad cow disease.