It was considered prudent to refrain from commenting on the August recall following the SE traceback to Wright County Egg and Hillandale Farms of Iowa until more facts emerged. As a cynical observation, the HSUS was not as restrained since its publicity immediately implicated intensive cage housing with an unjustified and unsubstantiated epidemiological relationship between SE infection in consumers and commercial production systems — but I digress.
Let us return to what we do know from the FDA reports on its initial findings.
- The outbreak appears to be associated with a single source comprising what is essentially a contiguous biological unit of 5 to 6 million hens in Wright County in North Central Iowa. This complement of hens represents approximately 2% of the nation’s flock of 280 million laying birds. No other farms, cooperatives, integrations or companies with an aggregate of 275 million hens have been identified as producing contaminated product as of the end of August.
- Despite initial concerns, the incidence rate of egg-borne salmonellosis in consumers due to the specific strain of Salmonella enteritidis typed by PFGE has declined as the implicated eggs, dating back to June, have been either consumed or destroyed.
- This outbreak was detected by traceback, confirming the capabilities of FoodNet and PulseNet to identify foodborne disease in diverse populations in many states.
- The CDC and FDA clearly have the ability to determine the source of an infection based on diligent patient interviews, using data on carton labels, wholesale and retail invoices and documentation with coordination among metropolitan, county and state public health investigators.
- The extent of sale and transport of nest run eggs for packing and distribution can result in multistate outbreaks of SE. Traceback is obviously complicated by the profusion of brands and packs and packing plant imprints on cartons which do not necessarily relate to flock of origin.
- In contrast to previous SE episodes, the FDA as the principal federal agency has acted forcefully and expeditiously to investigate the source and to motivate the recall and diversion of eggs to pasteurization. The quantity involved probably exceeds 12,000 cases per day unless affected flocks, farms or in-line units are depleted.
Now that the FDA has identified the source of infection and knowing the past history of the ownership of the enterprise concerned, it would be productive to consider the following questions to ascertain what procedures and accepted industry standards were ignored and disregarded which otherwise may have averted the episode:
- What SE detection program was followed and for how long? Most of the industry has subscribed to the UEP's 5-Star Total Quality Assurance Food Safety Program, which only requires one environmental drag swab assay within two weeks of depletion with obvious implications for the duration of possible vertical transmission to consumers in the event of infection of a flock. In contrast the most stringent EQAP, applied in Pennsylvania since the mid-1980s, requires four assays during egg production extending over two cycles. Some producers satisfying customer requirements monitor all units on a complex, irrespective of flock age for environmental SE at quarterly intervals. A nationally distributed brand has required their franchisees to monitor flocks at four ages during production for the past five years.
- What vaccination programs were followed and for how long? Did management of the affected complexes commence vaccination only when environmental positives were detected when testing was initiated within months of promulgation of the FDA Final Rule? It is a matter of record that for many years prudent producers have carried out programs of administering two or three successive doses of live mutant Salmonella typhimurium vaccine to pullets. In addition many operations also have administered inactivated emulsion vaccines prior to onset of production. Vaccination may be regarded as a cornerstone of an SE prevention program and as such is basically an industry standard. The FDA erred in not mandating this effective modality in its Final Rule for reasons that are inexplicable.
- To what extent did the affected complexes apply appropriate biosecurity procedures with respect to parent flocks, their hatchery, rearing pullets and laying hens? Of obvious concern are precautions to prevent introduction and dissemination of SE during movement of flocks, equipment and personnel. Exclusion and baiting of rodents and especially mouse populations, which serve as reservoirs of SE, are critical components of an integrated control program.
- What role did contaminated feed ingredients, especially animal proteins, play in either the introduction of infection or subsequent propagation of SE? Did their common contaminated feed mill, delivery vehicles or personnel contribute to an ongoing cycle of infection? Was byproduct derived from ruminants and supplied by one or more rendering plants contaminated?
From the initial reports and comments by FDA officials and applying accepted knowledge within the industry we can immediately consider the following approaches to alleviation:
- Disabuse ourselves of the incorrect notion that “SE is everywhere; it’s just a matter of looking.” In fact all the complexes I have been associated with as an auditor and consultant are free of SE environmental contamination. The “universal infection” point of view is flat wrong, self-serving and anachronistic in the face of the FDA Final Rule.
- We have sufficient knowledge of the epidemiology of SE in commercial flocks to implement successful and effective programs of prevention and monitoring given commitment and resources, which will add only fractionally to the cost of eggs. Programs must include biosecurity, vaccination, rodent suppression, placement of SE-free chicks, all-vegetable diets and effective QC and monitoring at all levels of production. The legal implications and costs associated with persistent SE infection will be untenable in the future.
- Unless the industry commits to rigid and effective control, consumer confidence will be eroded and SE will become the “new cholesterol” as a restraint to consumption
- Purchase of nest run eggs should be supported by documentation of freedom from SE in all supply flocks. Did any of the companies taking advantage of the cheap price of the approximately 10,000 cases traded daily ever question the SE status of the implicated supplier?
- An attitude of “lowest-cost-whatever-it-takes” and disregard for the safety of product is intolerable. The “bad eggs” will have to adapt to acceptable practices or be “culled” by rejection of their products, lawsuits and regulatory action. Certainly condoning the deficiencies of irresponsible producers and receiving support from industry organizations is counterproductive and ultimately damaging to our image.
The final question arises as to how the industry will be affected by this outbreak and recall?
- If we experience a subsequent recall from another source there may well be a marked erosion of confidence in shell eggs, a decline in consumption and further reduction in margins. The present “UB windfall” may well be transitory as supply and demand attain equilibrium.
- The trend towards a lower proportion of breaking noted during the past three years will be reversed and more pasteurized further-processed consumer and food service products will become available in response to consumer demand.
- Supply of in-shell pasteurized product will increase at a slow pace unless innovative technology such as microwave processing is introduced or more effective thermal immersion units are developed.
- The need to counteract negative and distorted publicity from the opponents of intensive livestock production will be intensified. It will be critical to characterize the SE outbreak as a result of mismanagement if the facts support this contention. Complexes with cages demonstrated to be free of SE do not represent a risk to consumers. Intuitively, free-range and floor systems must have a greater potential for SE contamination than well-managed cage units with belt manure removal.
- The FDA will attempt to recover their tattered image by applying a zealous approach to otherwise compliant producers, citing technicalities and deficiencies in documentation. Ultimately a lack of understanding and resources will overwhelm the agency. The entire food industry will ultimately fall under the purview of a consolidated food safety agency paralleling changes in the UK and the EU where departments of agriculture have been discredited as protectors of consumer interests.