Patrice N. Klein, MS, VMD, DACPV, DACVPM
U.S. Food and Drug Administration, Center for Food Safety and Applied Nutrition, College Park, MD, USA
The game meat industry has seen rapid growth in recent years as consumer demand increases for alternate food products or foods reminiscent of home countries. Both domestically produced and imported game meats are subject to U.S. federal, state, and local regulations that address public health, animal health, and may include wildlife conservation issues. The illegal bush meat trade impacts these same health and conservation areas and presents concerns for potentially serious public health consequences associated with the consumption of these products. The FDA and other federal regulatory agencies having jurisdiction over laws protecting public health, animal health, and wildlife conservation each have some authority regulating game meats. This can present a challenge to providing cohesive implementation of these regulations and enforcing violations of illegal game meat (bush meat) trade.
Game meats are from non-domesticated, free-ranging and farm-raised wild animals and birds that either are legally hunted for personal consumption or reared, slaughtered, and commercially sold for food. Although individuals have hunted and eaten these species for years for personal consumption, animals killed in the wild that are processed to enter the U.S. commercial food supply must comply with applicable state and federal food safety regulations. The farmed game animal industry is diverse and has seen unprecedented growth since the 1970s. Its rapid growth in recent years is largely due to consumer demand for low-fat products and interest in alternative food products. In 2003, the North American Elk Breeders Association estimated that there were about 110,000 elk on 2,300 U.S. farms valued at more than $150 million dollars. The National Deer Farmer’s Association reported in 2003 that there were approximately 550,000 deer on 11,000 U.S. farms with an estimated value of $1 billion. The National Bison Association reported that there were more than 1,100 American bison farms by 1999.
The growth of these game meat industries highlights the importance of having regulations addressing disease control, interstate movement of animals, animal identification, slaughter inspection, and food processing practices which are similar to the regulations for traditional livestock production. However, the industry may be regulated either by the state agriculture department, the state wildlife agency, the state public health department, or by shared responsibilities between the state agencies, causing a lack of consistent regulations among states.
Also state agriculture departments generally have regulations or policies for importation into the state of game animals and their products but may not continue to regulate these products once they are in intra-state commerce. The federal agencies have regulations for inter-state commerce designed to ensure the health and welfare of these animals, as well as the safety of the food products derived from them.
Federal Regulatory Responsibility
There are four federal agencies that protect human and animal health, food safety, and wildlife conservation through their respective regulatory authorities of domestic and imported game meat. They are the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) and Food Safety Inspection Service (FSIS), the U.S. Fish & Wildlife Service (USFWS), the Centers for Disease Control and Prevention (CDC), and the U.S. Food and Drug Administration (FDA). APHIS has jurisdiction under the Animal Health Protection Act and animal quarantine laws, such as those listed in Title 9 in the Code of Federal Regulations (9 CFR 94), to inspect, detain, quarantine, seize, and destroy animals, meat, and meat products in interstate commerce or those being imported into the U.S. that pose a risk of introducing a pest or foreign animal disease to U.S. domestic livestock and poultry.
USFWS has regulatory authority under the Endangered Species Act (ESA), the Lacey Act, and the Wild Bird Conservation Act, and enforces the Convention on International Trade of Endangered Species (CITES) within the U.S. to prohibit the importation of wild animals and any wildlife products that may be injurious to native wildlife (by introduction of foreign disease, for example), that violate federal, state, or local wildlife laws, that threaten species conservation, or that violate the CITES treaty which is based on sustainable use and management of wildlife to prevent decline of wild animal populations.
CDC has authority under the Public Health Service Act (PHSA) to prohibit the importation of animals and animal products and to regulate foreign quarantine to prevent introduction of communicable diseases that threaten public health. Currently, CDC bans the importation of all non-human primates (NHP), African rodents, civets, and Asian birds and products from these animals to protect the public against Ebola, simian immunodeficiency virus, monkeypox, severe acute respiratory syndrome, and avian influenza.
FDA is responsible for protecting consumers against impure, unsafe, and fraudulently labeled food covered under the Federal Food, Drug, and Cosmetic Act (FFDCA). This includes products not covered by the USDA-FSIS’s Poultry Products Inspection Act (PPIA) and Federal Meat Inspection Act (FMIA). Meat from game animals and birds are not covered by those acts and are regulated by FDA under the FFDCA. Game meat produced domestically, as well as shipped from other countries, must meet the same safety standards applied to all foods domestically produced and offered for entry into U.S. interstate commerce. Additionally, if offered for sale as a consumer commodity, they also must meet the requirements of the Fair Packaging and Labeling Act (FPLA). Domestic and international food shipments found not to comply with the provisions of the FFDCA must be brought into compliance, destroyed, or if from other countries, may be re-exported. FDA also has authority under the PHSA to prohibit interstate commerce of animals and animal products to prevent transmission of communicable diseases affecting human health.
Smuggled Bush Meat Trade: An Emerging Problem
Bush meat is a term for game meat from wild animals that are hunted and slaughtered for personal consumption, traditionally in the bush of Africa and elsewhere in the world. Although this term was originally associated with the great apes and monkeys, it also includes many species of wild ruminants, carnivores, rodents, reptiles, and birds. Many of these animals are threatened or endangered species protected by international wildlife laws and treaties such as CITES, and may make commercial harvest and trade as food illegal and a violation of the treaty. Consumption of meat from these animals also may pose a public health risk because the health of these hunted animals is unknown and many species may harbor diseases that could infect people.
Unfortunately, the amount of illegal, smuggled bush meat entering commerce has increased markedly in recent years, coincident with the increased demand for farmed game meats. Historically, the consumption of bush meat was primarily confined to the poorer, rural communities in Africa, Asia, the Middle East, and South America that hunted local wildlife for personal consumption as an inexpensive source of protein in their diets. Now, however, consumption is substantially increasing in Europe and the United States. Much of this meat, which is being sold in street markets and ethnic restaurants, is illegally smuggled into countries such as the United States. Sometimes it is hidden in passenger’s suitcases and sometimes in commercial cargo shipments that are intentionally mislabeled. This practice is disconcerting as there are potentially serious health consequences associated with the consumption of these products. According to the USFWS and Department of Homeland Security-Customs Border Patrol (CBP), the amount of bush meat entering the United States each year is unknown; however, CBP estimates that they may be intercepting only a fraction of what is being illegally imported. Similarly, the Department of Food and Rural Affairs (DEFRA) in the United Kingdom (U.K.) estimates that nearly 12, 000 tons of smuggled bush meat enters the U.K. annually. DEFRA believes that some of this meat may be contaminated with FMD virus which would pose disease risks to U.K. livestock. According to reports from the Zoological Society of London and the Bush Meat Crisis Task Force, as much as 5 million tons of bush meat are extracted from the vast Congo basin and Central African Republic each year putting many wild animal populations at risk of extinction.
Public Health Concerns
While most game meats are produced from healthy animals, some game meats have raised public health concerns because the meat may harbor infectious agents that are not destroyed by smoking, salting, or brining preparations, and could cause human disease. There are also some public health concerns about chronic wasting disease (CWD), a transmissible spongiform encephalopathy (TSE), or prion disease, which has been identified in both wild and farm-raised mule deer, white-tailed deer, and Rocky Mountain elk. While consumption of beef contaminated with bovine spongiform encephalopathy (BSE) is thought to be responsible for the variant form of Creutzfelt-Jakob disease (vCJD) in people, consumption of CWD-contaminated cervid meats is not known to cause disease in people or domestic livestock. Nonetheless, research is ongoing to determine if interspecies transmission of CWD agent to humans and domestic livestock is possible.
Smuggled bush meat likely presents the greatest public health risk. Among the diseases that may be transmitted to humans from bush meat are those caused by viral agents of Ebola, HIV/SIV, monkeypox, Herpes B, Rift Valley fever, and rabies; bacterial agents of tuberculosis (Mycobacterium bovis, M. tuberculosis), anthrax, salmonellosis, shigellosis, brucellosis; and parasitic agents of trichinellosis, cysticercosis, and toxoplasmosis.
FDA’s mission is to ensure the safety of the foods it regulates, whether they are traditional products like milk, grain products, and eggs, or the more esoteric game meats and game meat products. FDA takes very seriously the risks to public health of illegally imported foods like bush meat harvested from wild animal populations that may harbor dangerous zoonotic diseases. Similarly, FDA and CDC are looking carefully at the potential public health risks that may be associated with CWD-contaminated meat and have recommended refraining from consuming meat and other products from CWD-positive deer and elk until more information is available to understand how CWD is transmitted within the same species of deer or elk and if it could be transmitted to people. The FDA will be working to identify manufacturers and processors involved in the importation and interstate commerce of game meats and game meat products in an effort to establish inspection plans to evaluate on-farm and slaughter facility sanitation practices. As well, the FDA will continue to work together with other federal agencies to develop better guidelines and procedures to facilitate interagency cooperation to prevent illegal bush meat from entering the United States.1
1. Klein, P.N. 2005. Game meat: a complex food safety and animal health issue. Food Safety Magazine. Vol 10 (6), pp 12–16.