Email from Richard Auwerda, NADC Animal Caretaker Supervisor to Robert Stoker, NADC Industrial Hygiene and Safety Manager - March 28, 2006
From: "Richard Auwerda" <rauwerda@nadc.ars.usda.gov>
To: "Robert Stoker" <rstoker@nadc.ars.usda.gov>
Cc: "Amirali Hamir"
<ahamir@nadc.ars.usda.gov>; "Carol Moran"<cmoran@nadc.ars.usda.gov>; "David Alt" <dalt@nadc.ars.usda.gov>; "Diana
Whipple" <dwhipple@nadc.ars.usda.gov>; "Justin Greenlee"
<jgreenlee@nadc.ars.usda.gov>; "Lawayne Nusz" <lnusz@nadc.ars.usda.gov>;
"Marcus Kehrli" <mkehrli@nadc.ars.usda.gov>; "Ronald Horst"<rhorst@nadc.ars.usda.gov>; "Terry Krausman" <tkrausma@nadc.ars.usda.gov>
Sent: Tuesday, March 28, 2006 2:40 PM
Subject: TSE Questions
Robert - As Industrial Hydrologic and Safety Manager for NADC, I feel you can answer some questions regarding information covered in the NADC, Animal Care and Use Handbook, under B. Institutional Policy On Occupational Health And Safety of Personnel At NADC; and the NCAH Environmental Systems Policy Statement (located on NADC intranet Safe Web Site), and other laws, regulations, policy and guidelines concerning safety and environmental concerns that arose when NADC caretakers began caring for 4 CWD Elk in B-2 at NVSL, as NVSL was done with their project
To give you a little background:
The NVSL, CWD (Chronic Wasting Disease) Elk project started in 2001. At irregular intervals (beginning in July of 2003, according to my documentation) the elk were euthanized as they succumbed to the TSE pathogen, and were transported by NADC staff to the B-5 Necropsy Facility at NADC, where Dr. Hamir and others performed the necropsy. This procedure continued up until Feb/March, 2006, when the four remaining elk, and NVSL B-2, were transferred from an NVSL protocol and animal care to an NADC protocol and animal care under my supervision.
In receiving information from NVSL in regards to questions I had concerning labor hours needed to properly care for the four elk, I learned that the elk were kept on bedding. Since using bedding in
bio-containment is very labor intensive, and NADC does not house large adult TSE animals on bedding except as a veterinary treatment and/or to reduce stress, I asked if we could remove the bedding and care for the animals as we do in our own TSE bio-containment barns (i.e. rubber comfort mats, and cleaning the animal space by hosing the feces and urine down the drain).
I was informed, in an email, by the NVSL Institutional Veterinarian, Dr Morgan, that keeping B-2 a dry barn was imperative, as that was requested by the State Veterinarian of Iowa, the NVSL/CVB Bio-safety Committee, and the NVSL ACUC to protect the environment. Dr. Morgan went on to explain that CWD is a known environmental contaminate, there is likely fecal contamination, and it is known that sewage treatment does not kill prions.
Needless to say this raised all sorts of bio-safety/environmental contamination questions with me, as it should have, in regards to our (NADC/VPDLRU) Protocols and SOP's with TSE animals. This would include care, from inoculation to necropsy of NADC's TSE (CWD, TME) animals, as well as the necropsy of the original NVSL CWD elk from B-2, since untreated blood, CNS fluids, feces, urine and other potentially prion infected materials run down and are washed down the drains in B-5, and animal barns, routinely using water. When I sent emails asking the Primary Investigators, the Chairman of our ACUC (and carbon copied to my Supervisor) for clarification of these concerns and questions. I
received little response until that afternoon, when I received an email from Diana Whipple, as well as Dr Kehrli, informing me that I needed to arrange my schedule the following day, March 1, 2006, in
such a way as to attend a meeting in which the NVSL elk, waste management and the science around CWD would be discussed. I attended the meeting, and appreciated their time and information. However, with the exception of how the NVSL elk should be cared for, none of my questions concerning the risk of NADC's practice of washing, non-disinfected blood, urine, other bodily fluids down the drains,
into our sewage treatment plant, then on to the City of Ames sewage treatment plant, from our TSE animal barns and B-5 during necropsy, were
answered.
The more I thought about this, and the more memos, policies, regulations and guidelines I've looked up, the less sense it has made. Especially in light of recent research (both here, at NADC, and else
where) that suggests CWD may be blood-borne. It is at this point I need your help.
The only document I could find concerning B-5 and TSE, is dated Feb. 22, 2000, it is titled: Necrropsy Facility Use, Animal Disposal and Incinerator Guidelines (B-5). On page 2 the agents approved for use in the necropsy facility are all listed; at the end of the list is Scrapie, followed in parenthesis by "(handled at BL-2 level, no other TSE's approved)". Yet on the on-line ACUC Handbook for NADC, under Institutional Policy on the Disposition of Animals, 2. Guidelines For
Necropsy of Animals, "Other TSE's" were approved for B-5 in August of 2002. I was on the ACUC at that time and do not remember anything about it being presented to the ACUC. Our own policies appear at odds with this.
According to our own NADC, Animal Care and Use Handbook, under B.Institutional Policy on Occupational Health and Safety of Personnel at NADC, Number 8. Guidelines for working safely with Transmissible Spongiform Encephalopathy, we (NADC) appear in non-compliance. I'm sure your familiar with these as you helped write them, in 2002 I believe.
Even the NCAH Environmental Systems Policy Statement appears to be at odds with my perception of what we are doing with potentially contaminated prion material, from barns and necropsy, that goes into our sewage treatment plant, then on to the city of Ames water treatment and supply.
Robert, this is really causing concern, and it is a question raised by some of the animal caretakers. What I would appreciate from you is: 1) The exact protocol for handling the material and contaminates in question. 2) An explanation as to the difference in our written policy and what we have been told to practice, and 3) A breakdown of how we monitor the level and/or the amount of prions that are washed down the drain, and if those prions are or are not inactivated by our sewage
treatment facility. If you could get me this information by Friday, April 7, 2006, it would be greatly appreciated. Thanks, Rich