Mycobacteria pose the global public health problem

Tuberculosis and leprosy are not the only diseases caused by mycobacteria. Increasingly, the non-tuberculous mycobacterium that causes a worldwide spread animal disease, called paratuberculosis, is being associated with Crohn's disease in humans. This mycobacterium is shed via milk and meat of sick animals, and heavily contaminated faeces pollute surface waters. Mycobacterium avium, subspecies paratuberculosis can be an important source of triggers of immunological disorders. After ingestion or inhalation, degradation products of mycobacteria can affect immunity and can trigger not only Crohn's disease but also other chronic inflammatory and autoimmune diseases, e. g. type 1 diabetes, multiple sclerosis, psoriasis, arthrosis, asthma, sarcoidosis, etc. Various mycobacteria can be also in tap water, bottled water, swimming pools water, and river water from catchments, including pasture regions with large herds of cattle and sheep, and in sea water near the estuary of highly contaminated rivers. Mycobacteria can also be found in vegetables and strawberries grown on heavily contaminated soil or in contaminated hydroponic solutions. Mycobacteria, therefore, are increasingly recognized as a global problem in urgent need of recognition. The World Health Organization (WHO), the Food and Agriculture Organization of the United Nations (FAO), the World Organization for Animal Health (OIE), the European Union authorities, the US Department of Agriculture, the US Food and Drug Administration, and others, should start paying serious attention to this problem that has been in existence for more than 100 years. Obviously, the environment, food and water, cannot be completely free of mycobacteria. However, at this point it has become urgent, to widely disseminate the information on how to reduce their impact on public health. Perhaps most importantly, it should be urgently publicized that children that are not breastfed are at the highest risk, because of the presence of mycobacteria in infant formulas.
As the first step to prompting highly needed future world-wide coordinated action, the petition to the World Health Organization (already under circulation, see this link), should be signed not only by patients suffering from chronic inflammatory and autoimmune diseases and by their immediate family, but also by those scientists and medical professionals who are alarmed by the seriousness of the problem. Information in scientific publications has not been respected by the world professional community for more than 100 years. The first reports of paratuberculosis were published already at the end of the 19th century. The initial information about the similarity of the intestinal changes in cattle suffering from paratuberculosis and in humans with Crohn’s disease, was published in the British Medical Journal already in 1913. Since then, many findings and summary reports have been published by outstanding experts, however, without the desired effect on the necessary response by the health authorities. No doubt, one of the reasons for the lack of attention to this problem is the complicated and unconventional relationship between mycobacteria and the immune disorders mentioned. The important reports have been published: in 2004 a monograph Pathogenic mycobacteria in water on behalf of the WHO, in 2005 Microbial triggers of chronic human illness by the American Microbiological Academy, and in 2008 Mycobacterium avium paratuberculosis: Infrequent human pathogen or public health threat by the American Microbiological Academy, because the alarming information about the connection between the mycobacteria, Crohn’s disease, and other disorders, can no longer be ignored. The author of this note drew attention to the risk posed by mycobacteria already in 1998 (comment to ProMed-Mail in 1998, 19980815.1628).
Professor Karel Hruška
Former director, Veterinary Research Institute, Brno, Czech Republic
If the above hyperlinks were not usable, try to copy the following URL addresses to your browser:
Recognize Crohn’s disease as a global epidemic, the petition to the World Health Organization
Pathogenic mycobacteria in water (Editors: S. Pedley, J. Bartram, G. Rees, A. Dufour, J. A. Cotruvo, Emerging Issues in Water and Infectious Disease Series, World Health Organization titles with IWA Publishing, 2004, 237 pp.§
Microbial triggers of chronic human illness (K. M. Carbone, R. B. Luftig, M. R. Buckley, American Microbiological Academy, 2005, 14 pp.)
Mycobacterium avium paratuberculosis: Infrequent human pathogen or public health threat
(C. Nacy, M. Buckley, American Microbiological Academy, 2008, 37 pp.)
Mycobacterium paratuberculosis, milk survey - UK (03) A ProMED-mail post, Archive Number: 19980815.1628
Ask how to decrease a risk for yourself and for your family sending the e-mail to


A new series, aimed at stimulating discussion on published literature dealing with the threat to public health posed by mycobacteria. Although some information of global significance has been known for decades, the risk posed by mycobacteria remains underestimated.

Prepared by the Reference Laboratory for Paratuberculosis and Avian Tuberculosis World Organization for Animal Health (OIE) and Biomedical Technology, Epidemiology and Food Safety Global Network operating in the Veterinary Research Institute, Brno, Czech Republic. 

Minireview issues already published

(01) Do you know, that mycobacteria may trigger asthma
(02) Mycobacteria are present in milk and dairy products, including dried milk for formula feeding
(03) A risk, even hypothetical, has to be treated as a risk
(04) How to assess MAP in retail milk
(05) What can be expected from mycobacteria: Latent infection
(06) Mycobacteria in plants and vegetables
Mycobacteria in potable water

A call for action against a proposal to remove PTB from the Animal Health Code
The Iceland, 80 years ago
The New Paradigm for Crohn’s Disease: A call to action

Assessment of Paratuberculosis in the Food Chain (TAFS forum, March 2013)
(12) The significance of a negative USDA certified Map ELISA test

Is there any image processor for analyzing stained smears such as Gram, Acid Fast, etc.?
Can boiling or cooking destroy the components of MAP cell participating in  inflammatory pathways?



(12) The significance of a negative USDA certified Map ELISA test
Gilles R. G. Monif and J. Elliot Williams
Intern. J. Appl. Res. Vet. Med.  2013, 11 (2), 117-122
The significance of a negative USDA certified Map ELISA test was assessed in three separate study designs.
Part I: The sera of seven out of nine necropsied cows with documented Johne’s disease and whose feces was positive for mycobacterium DNA nested negative using the ParaChek® Map ELISA test system (Prionic, Switzerland).
Part II: Of the sera from 42 cows whose fecal specimens had been characterized by the Trek® Diagnostic System as having a significant amount of Map, 39 specimens tested negative in the ParaChek® test. When serological testing was extended for 14 additional months, 20 of the 21 animals remained sero-negative.
Part III: Comparative serological analysis done on the same serum samples from a dairy herd demonstrated that 42% of the cows test certified as having been Map-free had anti-Map antibodies.
Comment by the Editor:
There is no doubt that mycobacteria and some other bacteria are the source of bacterial triggers. The health risk of MAP, even after pasteurization or boiling, has to be officially accepted. The opinion that mycobacteria are not a risk food factor is now obsolete. Among mycobacteria, MAP plays the most important role. However, no other microorganism, which could be the source of the triggers, is allowed to be a contaminant in baby foods. The significance of a negative MAP ELISA test should be remembered, although it is well known that a positive test does not mean shedding of MAP and a negative test does not exclude shedding in the past, present or in the future. A good and permanent collaboration should be established between the herd owners, meat inspection at slaughterhouses and dairies which purchase milk from the herd. A combination of different diagnostic methods and appropriate interpretation of the results should be used to control paratuberculosis and to protect the consumers. Crohn’s disease is not a single human inflammatory or autoimmune disease connected with immunological pathways affected by bacterial triggers. How long will mycobacteria be legally present in foods and water?
Next minireviews

Mycobacteria ...
... are distributed in bottled water
... play a role in an Island story (ovine paratuberculosis and Crohn’s disease)
... in the Czech Republic (Crohn’s disease after the Iron Curtain had been rised)
... in Sardinia (T1D)
... in Cardiff (river Taff contaminated by MAP)
... in Mankanto (ill-fated swimming)
... can be found in every nook and cranny
... as secret agents (formula feeding, cold chain hypothesis, hygiene hypothesis)
... can, even after their death modulate inflammatory cytokines by means of their cell wall components
... were used for immunomodulation in Freund adjuvans already 65 years ago
... are pathogens as well as allergens or immunomodulators
... could be the missing environmental factor in many etiological hypotheses
... are considerably heat and chlorine resistant
... have unusual characteristics of food, water, and air borne pathogens or immunomodulators similar to allergens
See the introductory documents
Paratuberculosis and Crohn’s disease: Premises and open guestions
Infectious diseases incorporated FUIDI premises


Behr MA - 120822 - 120823
Falkinham JO -120821
Haghkhah M -  121007 - 130915
Hruska K - 120823 - 120902 - 130915
Lipton JE - 120923 - 121229
Klee W - 120923
Monif G - 120822 - 120823 - 121229
Mullin JM - 120924
Greenstein R. J. -  120823 - 121004
Sperling U - 120924

Masoud Haghkhah, DVM PhD, Iran
I have two questions. First, is it possible to diagnose and/or detect MAP bacilli on acid fast stained smears with any new methods such as PCR, etc.? Second, when we use acid fast staining for paraTB suspicious feces, sometimes we see some red bacilli in clusters such as MAP, BUT they are much larger, in both width and length. What are they? We see these organisms in both MAP negative and positive smears.
Any comments or information would be appreciated.
Best regards
Masoud Haghkhah, DVM PhD
Re by K. Hruska
(1) PCR and FISH with specific DNA or PNA probes can be used for typing mycobacteria.
(2) Ziehl-Neelsen staining is not a specific method for MAP so more species can be detected in one smear.
All methods have to be used by experienced personnel both for the methodological and interpretation reasons.
For more information see:
Acid Fast Bacilli
More general information on acid fast staining and interpretation of results”
Ziehl–Neelsen stain
Acid-fast Ziehl-Neelsen Stain Reaction
Acid-Fast Stain Protocols
UG practicals:  Ziehl-Neelsen staining
Frequently asked questions
See also the references


Masoud Haghkhah, DVM PhD, Iran

Is there any image processor for analyzing stained smears such as Gram, Acid Fast, etc.? Any comments or information would be appreciated.
Re by K. Hruska
 I guess your question is directed to estimation of mycobacteria. It's a good but difficult question and, unfortunately, it cannot be simply answered without a comprehensive analysis of many rather complicated factors, e.g. matrix to be investigated, sample preparation, reasons of investigation, sensitivity, specificity, time needed, price etc. The question is open for discussion. As soon as anybody would contribute the issue will be published.
At this moment a search for mycobacteria and image analysis retrieves 45 records, two of them on M. avium subsp. paratuberculosis.
See the references with abstracts.
General information:
Morphological Image Analysis: Principles and Applications
Image analysis for agricultural processes: a review of potential opportunities
Remote Bacteriology & Image Analysis Workstation


R. J. Greenstein, USA
Re.: (07) Mycobacteria in potable water
During the course of our experiments, we showed by both PCR primer analysis as well as DNA sequence analysis that a mycobacterium, simply labelled as M. avium is in fact the M. avium subspecies paratuberculosis. This specimen had originally been cultured from the municipal water supply of a major city in the United States. These data imply that M. paratuberculosis may well be as ubiquitous in the environment as M. avium (32). We speculate that Crohn’s disease may be the consequence when M. paratuberculosis is exposed to a susceptible individual.
Reference supplemented the minireview (07)
Mishina, D., Katsel, P.,  Brown, S.T., Gilberts, E.C., Greenstein, R.J. 1996)
On the etiology of Crohn disease
Proc.Natl.Acad.Sci.U.S A, 93, 9816-9820

Crohn disease (CD) is a chronic, panenteric intestinal inflammatory disease. Its etiology is unknown. Analogous to the tuberculoid and lepromatous forms of leprosy, CD may have two clinical manifestations. One is aggressive and fistulizing (perforating), and the other is contained, indolent, and obstructive (nonperforating) [Gi]-berts, E. C. A. M., Greenstein, A. J., Katsel, P., Harpaz, N. & Greenstein, R. J. (1994) Proc. Natl. Acad. Sci. USA 91, 12721-127241. The etiology, if infections, may be due to Mycobacterium paratuberculosis. We employed reverse transcription PCR using M. paratuberculosis subspecies-specific primers (IS 900) on total RNA from 12 ileal mucosal specimens (CD, n = 8; controls, n = 4, 2 with ulcerative colitis and 2 with colonic cancer). As a negative control, we used Myobacterium avium DNA, originally cultured from the drinking water of a major city in the United States. cDNA sequence analysis shows that all eight cases of Crohn's disease and both samples from the patients with ulcerative colitis contained M. paratuberculosis RNA. Additionally, the M. avium control has the DNA sequence of M. paratuberculosis. We demonstrate the DNA sequence of M. paratuberculosis from mucosal specimens from humans with CD. The potable water supply may be a reservoir of infection. Although M. paratuberculosis signal in CD has been previously reported, a cause and effect relationship has not been established. In part, this is due to conflicting data from studies with empirical antimycobacterial therapy. We conclude that clinical trials with anti-M. paratuberculosis therapy are indicated in patients with CD who have been stratified into the aggressive (perforating) and contained (nonperforating) forms.

Prof. James M. Mullin, USA

I am a researcher in the US who is new to the mycobacteria (MAP) field and I was wondering if I could be added to the CGNI mailing list. A colleague just sent me your recent posting ( A risk, even hypothetical, has to be treated as a risk (K. Hruska, Brno) ) which I found very valuable.


Dr. Ulrich Sperling, Switzerland

Thank you very much for (03) A risk, even hypothetical, has to be treated as a risk.

Judith Lipton MD, USA

I really like your minireview about mycobacteria as a health risk. I wonder if you are familiar with the Precautionary Principle, summarized on the wikipedia or here . We concluded the ASM review of MAP as a public health threat with an appeal to the Precautionary Principle. I think that there is no excuse for anybody to be eating meat from sick animals (downer cows, animals with palpable lesions in their GI tracts) or drinking fluids such as dirty water or unpasteurized milk, simply on the intuitive basis that we want to prevent illness, and there is no way that eating contaminated food can be healthy. One doesn't need 100% proof, to act as though MAP is a pathogen that might well cause serious diseases. Thanks for all your work.

RE by K. Hruska
The Precautionary Principle is a very important document. I’ll recommend it to the CGNI subscribers for their attention. However, your


Professor Dr. Wolfgang Klee, Germany
2012-09-23, Re the minireview 03

I would like to seize the opportunity to express my appreciation, and gratitude, for the effort you've put into all those mails.


J. O. Falkinham III, Balscksburg, USA

Thank you for sharing the link between mycobacteria and asthma. Great (testable) theory! It appeals to me, as the increased frequency of asthma and other atopic diseases may parallel the increased numbers of mycobacteria in water distribution systems and households

Another reference, here showing that the active agent from mycobacteria inducing hypersensitivity pneumonitis is the muramyl dipeptide (Chronic Hypersensitivity Pneumonitis Produced in the Rabbit by the Adjuvant EffIect of Inhaled Muramyl Dipeptide (MDP), Richerson et al., Am J Pathol 1982, 106:409-420).

This work by Kati was prompted by the respiratory problems in damp houses in Finland, evidently a major problem. (Inflammatory responses in RAW264.7 macrophages caused by mycobacteria isolated from moldy houses, Huttunen et al., Environmental Toxicology and Pharmacology 8 (2000) 237–244).


M. A. Behr, Montreal, Canada
2012-08-22 Re: IDI premises

MAP and genomic variants:
3. Map evolved from Mycobacterium avium subspecies avium (Ma). This is incorrect. Map evolved from M. avium subspecies hominissuis.
10. Infected animals are not the ultimate reservoir for Map - really? What is the reservoir? I believe there are solid data that Map diminishes in the environment when you remove the host?
12. Not all Map are detected by IS900 primers. really? where are the papers on IS900-negative strains of Map? I have never read about this.

MAP and JD:
1. MAP is A cause of JD. Can you name another cause of JD?
14. Milk is one of the primary vehicles which expose humans to Map in significant numbers. Is this proven or is this conjecture?

MAP and CD:
5. Human beings will be perpetually exposed to Map. Who says humans will be perpetually exposed?


G. Monif, IDI, USA

Dear Dr. Behr:

Thank you for your comments. What makes science great is that we agree to disagree.

Map evolved from Ma. This concept we assimilated from the literature. If Map arose from M. hominissuis, I would be excited. It fits better with the antigen array in one of our ELISA tests. I'd appreciate any reference relative to that fact effect beyond those embedded in your excellent paper written with C. Y. Turenne and R. Wallace Jr (Clin. Microbiol Reviews 2007; 20:205-229). That Ma, Mac, Map and M. hominissuis can be both MapO2 positive and negative speaks to their common linage.(Med. Hypothesis 1999; 52:95-99; Clin. Microbiol Reviews 2001); 

Infected animals are not the ultimate reservoirs for Map. Again the literature identifies both Ma and Map as being recoverable from soil. If one removes animals actively shedding Map into the environment, organism recovery decreases, but new serological documentation of infection continues. When one looks for Map in rodents, rabbits, etc., the organism is demonstrable, but without accompanying disease. One is obligated to explain Map infection in wild animals that have substantially not shared pasture with potentially infected domestic animals. Are actively shedding animals the prime disseminators of Map? Absolutely.

Not all Map isolates are detected by IS900 primers; Map is A cause of JD. What we should have stated as our premise is that not all pathogenic mycobacteria producing chronic enteritis in herbivores are detected by IS900 primers. A significant degree of polymorphism exists among Map isolates. The simplest confirmation can be derived from comparative IDEXX and Prionic Map ELISA positive tests results. One test will identify a strong positive that the other misses and visa versa. That some isolates are more Ma than Map has been cited in the literature. One has only to look at USDA's own 2009-2010 isolation data from cows to establish the fact that M. hominissuis, Ma, and Mac can be isolated from slaughter bovine specimens.

Milk is one of the primary vehicles by which humans are exposed to Map. Somewhere in the literature, there is a paper that did a comparison between the potential inoculum load in milk vs. portable water. The rise of Crohn's disease with wealth or consumption of milk and dairy products and the "protective effect" of breast feeding with respect to subsequent development of Crohn's disease are circumstantial observations that merit careful analysis. That milk is one of the primary vehicles through which humans are exposed to Map is an IDI premise that was incorporated into development of the FUID Herd Management Schema series whose objective is to reduce the amount of Map entering into the human food chain.

Human Beings will be perpetually exposed to Map.This is IDI's contention. Once Map is introduced into the production area , it is nearly impossible to eradicate (Vet. Microbiol. 2010; 143:284-292). Given the complexity of large herd dairy production in the United States, in IDI's opinion, the presence of Map in milk and related dairy products has a crude parallel to E. coli in selected meat preparations.

Sincerely, thank you.


K. Hruska, Brno, Czech Republic
2012-08-23 Re. M. Behr

Thank you for your comments. The premises and minireviews are open for discussion. All comments, questions, objections, supporting data and new perspectives are welcome. We are making an attempt to reach scientifically based conclusions that
• mycobacteria, dead or alive, pose a public health risk which cannot be ignored
• complete elimination of this risk cannot be achieved but certain partial steps are ready for implementation

The Biomedical Technology, Epidemiology and Food Safety web page is ready to record the discussion. I'll be happy if the number of participants in the discussion will rise from the two today, the first day after publication of two sets of premises and the first minireview, to a convincing number at the end.


M. A. Behr, Montreal, Canada

Thanks Karel, this is indeed a good initiative. I will send another email to Gilles with my replies to his queries.


M. A. Behr, Montreal, Canada

Dear Gilles
I agree, science is indeed wonderful because we can respectfully agree to disagree, or to reevaluate old data or old ideas. Here are some thoughts on the first three points below to answer your replies, below.

- here is the reference that MAP evolved from MAH, see Figure 1 for the phylogeny by MLSA of 450,000 bp of DNA.

- here is the reference that survival of MAP in the environment is finite.

if there is still serologic documentation of conversion I thought that indicates that there are infected animals in the herd. In Australia, I believe they use this data to determine when they can put new animals on an old pasture. do you have articles stating that animals that go onto a pasture that has been free of livestock for 2 years are able to acquire MAP from the environment?

- in human medicine, if someone has a cavitary lesion in the right upper lobe we may call that suspected TB. if the sputum grows M. kansasii, we do not call this TB due to M. kansasii. we call this NTM lung disease. same if the sputum grows M. avium - we call this pulmonary MAC. it was my understanding that JD is due to MAP. if you grow MAA from a slaughterhouse sample, the animal has JD-like MAA disease, but the animal does not have JD.


G. Monif, IDI, USA

Dear Marcel:

Thank you for the reference. For self-serving reasons, I can joyously accept this modification to IDI's premises; but I still have reservations. A well established Darwinian principle is that over time a pathogen by virtue of its virulence selects to perpetuate its less virulent strains. A prime example is Treponeum pallidum (syphilis). In the 1800's, secondary syphilis carried a 50% probability of death. A hundred years later, untreated secondary syphilis does not carry with it anything approximating close to the same probability of death. By USDA's own data, M. hominissuis is a significantly more frequent cause of JD or JD-like disease in cattle than Ma. Answers reside in nature. Our role as scientists is merely to find them.

I agree with you that nothing is finite. With respect to survival of Map being infinite, it is most probably not. The real question is how long? Well designed epidemiology studies are not to be found. A basic problem here is Map's re-adaptation to the environment that appears to alter its growth characteristic and sensitivity to detection using current culture technology. There is at least one paper that found the pasture free of Map after one year. The time line of Map survival is a function of where samples are taken, the technology utilized, and the number of samples taken. Map embeds itself in slim film and can persist there for a long time. The water source's potential for residual organisms needs to be carefully evaluated with better technology. If selected wild omnivores or herbivores have access to the pasture (rabbits, deer, etc.) and if the water sources cannot be completely replaced, the time line of survival is altered by reintroduction of Map. The other problem is air dissemination of Map from domestic or non-domestic distant sources. Rendering the pasture and production areas Map free is neither practical and nor cost effective.

With respect to Johne's disease being specific to Map and cattle, such a use may be correct, but it is not optimally constructive. Most individuals know to one degree or another what Johne's disease is. While scientifically correct, the term chronic granulomatous enteritis tends to have nearly everyone running for a dictionary. The same disease process caused by the same or related pathogenic mycobacterium affects dogs, cats, sheep, horses, pigs. buffalo, deer, etc. The literature has used JD to describe chronic granulomatous Map enteritis in a number of species. IDI is not alone in its apparent misuse of the term, Johne's disease as being specific only to cattle.

I am debating with you out of great respect. I'm truly indebted for the information concerning M. hominissuis.

With kindest personal regards,



M. A. Behr, Montreal, Canada


I agree that the answers lie in nature, not only because it is for scientists to find them, but also because natural experiments are infinitely more creative than anything we can dream up in the lab.

To be clear, I do not think that JD is specific to cattle. I just question whether the isolation of somethinig other than MAP still contitutes JD. Do you have a reference for the USDA data on MAH as a cause of JD-like disease in catte?


Robert, USA
I like these mini reviews. Once again my thanks for you efforts. They are mc appreciated.
Re.: Infectious diseases incorporated FUIDI premises
Specific citation(s) please, for „Since 2008, Map has been recognized as a zoonotic pathogen for man“.
G. Monif, IDI, USA
Not quite clear as to your request, On the medical side of the equation, Map and selected other mycobacterium had been recognized as having zoonotic potential dating back to the late1900s. The 2008 was used to capture the report from the American Academy of Microbiology in the references. The date is different for those in medical infectious diseases and those in veterinary pathology.
Please let me know if that was your question to Professor Hruska.
K. Hruska, Brno, Czech Republic
In my opinion a zoonotic potential should be a subject of several minireviews. Good observations and logical interpretation of the results are available in published papers since 1913 (Dalziel, MAP and human enteritis) through many papers, published by Chiodini, Collins and other authors from the sixties of the last century. I am a little hypersensitive to the pusillanimous evergreen „This association between Crohn's disease and paratuberculosis has been shown but a causal relationship remains to be demonstrated“, However, the following paper seems to be unique:
Golan, L., Livneh-Kol, A., Gonen, E., Yagel, S., Rosenshine, I., Shpigel, N.Y. (2009)
Mycobacterium avium paratuberculosis Invades Human Small-Intestinal Goblet Cells and Elicits Inflammation
Journal of Infectious Diseases, 199, 350-354
Crohn disease is a chronic inflammatory bowel disease of unknown etiology. Mycobacterium avium paratuberculosis (MAP) was found in the gut of patients with Crohn disease, but causality was not established. Fully developed, germ-free human small intestine and colon were established by subcutaneous transplantation of fetal gut into SCID (severe combined immunodeficiency) mice thereafter infected by direct intraluminal inoculation of MAP. We have found that MAP actively invades the human gut epithelial goblet cells of the small intestine, inducing severe tissue damage and inflammation. These observations indicate that MAP can specifically colonize the normal human small intestine and can elicit inflammation and severe mucosal damage (Full paper available)
It is hard to understand that this paper of key importance has been cited only 14 times. What kind of expectations represent calls for evidence of MAP links to the Crohn’s disease? The application of perfectly live MAP to a hundred experimental babies and to follow them 20 years if CD will develop? Will be a biopsy sufficient or will be the autopsy required?


G. Monif, IDI, USA

A call for action against a proposal to remove paratuberculosis from the Terrestrial Animal Health Code (A letter by Gilles R. G. Monif to Ramon A. Juste)
Re.: The World Association for Animal Health (OIE)’s proposal to remove paratuberculosis from the Terrestrial Animal Health Code
Attn.: The President of the International Association for Paratuberculosis
Ramon A. Juste, DVM, PhD, Dip.ECSRHM
Any decision by the World Organization for Animal Health OIE to remove paratuberculosis as a disease entity from the Terrestrial Animal Health Code lacks scientific merit. If enacted, the consequences will only exacerbate significant agricultural and societal public health issues that, if not addressed, will in time destroy the dairy industry.
To state that there is no satisfactory way to detect animals infected with Map is a distorted interpretation of the relevant scientific literature. The FUIDI #1 Map ELISA test specifically addresses the issue of whether detectable Map is present or not. What has adversely colored the diagnostic literature concerning Mycobacterium avium subspecies paratuberculosis (Map) is the fact that the current commercial Map ELISA tests certified by the United States Department of Agriculture (USDA) measure anti-Map antibodies, but the interpretation of a positive test is predicated on the identification of a level of antibody that predicts a high probability of a progression of Map infection to clinically overt enteritis (Johne’s disease) or confirms its presence. A negative commercial Map ELISA test does not address the issue of whether or not a given animal has ever been infected by Map.
The decision by USDA to have the Map ELISA tests represent a statement of probability rather than a valid measurement of the amount of antibody present has permitted infected cows to be transported across state lines and national borders. The net result was not only the introduction of infected animals into uninfected herds, but a dramatic increased prevalence of Map infection in the national herds. In 2002, 30-40% of U.S. dairy herds had animals with Map. In 2007, USDA acknowledged that an estimated 70% of U.S. dairy herds contained one or more infected animals (USDA-APHIS Johne’s Disease in U.S. Dairies 1991-2007. 2007-Johnes.pdf.2007). If a test is now used that truly measures the presence or absence of Map antibodies, the number of infected animals in a large, confined dairy operation may exceed the 2007 seventy per cent figure that identified merely one or more Map infected animals.
Central to the herd monitoring schema proposed by the 2008 National Johne’s Disease Control Program for Johne’s Disease was identification and removal of infected animals from the herd. Reducing the introduction of Map infection and potentially Johne’s disease into uninfected herds is largely contingent upon the buyer having the proper information to go along with eyeball analysis of the animal’s body condition score. Quality of merchandise is theoretically addressed through the animal’s health certificate. In the United States, revision to parts 71 and 80 of the Code of Federal Regulations (CFR) is supposed to restrict the interstate movement of Map-infected animals except to recognized slaughter establishments (United States Department of Agriculture Animal Plant Health Inspection Service. 9, Parts 71 and 80.2000. Johne’s disease in domestic animals: interstate movement. Federal register 65:18875-188879). With an artificially constituted threshold for a positive test, the pertinent CFR regulations do not truly address the quality of merchandise issue. By not stipulating on the animal’s certificate of health its Map status in a manner comparable to Mycobacterium bovis, animals with subclinical disease animal are and have been transported across state and national boundaries. The decision by USDA not to require a statement as to an animal’s Map status has been a prime factor that undermined its avowed intent to prevent dissemination of Map into uninfected herds. USDA’s decisions have effectively masked the presence of infection in dairy cows, and by so doing exported disease across state and national boundaries.
The Japanese perception that Map constitutes a potential public health hazard has engendered a different schema (Eiichi M.2012. Epidemiological situation and control strategies for paratuberculosis in Japan. Japanese J. Vrt. Res. 60:19s-29s). In accordance with the Act on Domestic Animal Infectious Disease Control, after 1998, every Japanese dairy farm is examined for Map every five years. Imported cattle are subjected to quarantine in which they are screened using Map ELISA, fecal bacterial culture, analysis of feces for Map DNA and Johnin skin test. If a new cow is to be introduced into a herd, the recommended procedure is that the cow should be negative in more than two ELISA tests within three-month intervals during the last six months, negative at least once in culture for Map, and kept in quarantine until proven non-infectious. Fifty-four percent of diseased animals detected by the Japanese Animal Quarantine Service came from the United States. Owing to the high antibody threshold for a positive test of the current Map ELISA tests, the real number of exported infected cows from the United States escaping detection is open to speculation.
The cost of USDA’s current policies has been the widespread dissemination of Map within the nation’s dairy and beef herds in the name of protecting agriculture. In trying to placate a threat to the dairy and related industries, USDA has dramatically magnified the threat. Once introduced into the production area, eradication of Map from that environment is nearly impossible. Map dissemination within a herd has been documented to be progressive with time
In its attempt to insulate dairy producers from incurring added production costs embedded in implementing an effective herd management plan, USDA has cost producers money. Multiple studies have demonstrated a reduction in milk volume and fat content as well as impaired reproductive outcomes occur long before clinical signs become manifested. Instead of having occult losses from a few cows, the producer now had occult losses in milk production, unsuccessful reproductive outcomes, and decreased slaughter weight occurring in the majority of his cows. Once unidentified Map infection becomes prevalent within a large herd, by itself, small occult milk production losses can become very substantial over time owing to the number of animals now infected.
The more immediate threat to the dairy industry is not whether Map is the direct (cytokine/tumor necrosis factor) or indirect (induction of an autoimmune response) cause of irritable bowel syndrome and Crohn’s disease; it is that milk and milk products may contain an element (the Map organism) that may be harmful to the public health. A statement to this effect is not on the labels of milk, of baby food made from milk, of products made from milk or powdered milk, etc. Knowledge that 1) Map is recognized as a zoonotic pathogen; 2) the organism has been identified significantly more frequently in disease tissue, milk, and blood from individuals with Crohn’s disease than from individuals without gastrointestinal diseases; 3) the majority of individuals who consume milk regularly are projected to be infected; and 4) even killed Map release muramyldipeptides that are potent immunomodulators that trigger inflammation. To falsify a product label by deleting the inclusion or potential inclusion of a potentially harmful ingredient is inviting civil, if not criminal proceeding.
Recognizing USDA’s administrative blunders, the World Organization for Animal Health (OIE) now seeks to whitewash the damage done on a global level using the rationale that because Map infection is so widespread, continued recognition of Map as an animal pathogen would only cause economic losses through the restrictions in international animal trade. Ethically, as well as scientifically, OIE has chosen to disregard the preponderance of scientific evidence incriminating Map in the pathogenesis of human diseases: in particular Crohn’s disease and childhood autism.
To do nothing is to do something (“In any moment of decision, the best thing you can do is the right thing, the next best thing is the wrong thing, and the worst thing you can do is nothing”: Theodore Roosevelt - former U.S. President). The cost of USDA doing nothing has been the widespread dissemination of Map within the nation’s dairy and beef herds in the name of protecting agriculture. OIE is to be congratulated for doing the next best thing to nothing, the wrong thing. Let the International Association for Paratuberculosis (IAP) do the best thing and speak out against a proposal that puts us and children’s children all at a greater risk.
With kindest regards,
Gilles R. G. Monif, M.D.
19 December 2012
A note by the CGNI Editor:
The OIE and IAP representatives were applied for their opinions. The replies will be published in CGNI , if available.

Dr. Judith Eve Lipton, MD, USA
I want to spread the word around to my own network in general support of Dr. Monif. Perhaps we can apply other kinds of pressure to reverse this decision.


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