After reading FDA’s fact sheet for the proposed rule on preventive controls for human food, I was left scratching my head, not quite sure what impact, if any, the rule might have on U.S. egg producers. I asked Krista Eberle, director of food safety programs, United Egg Producers, if U.S. egg producers would be impacted by the new proposed rule, and she said, “It has been very confusing so far. There are a number of different ways that eggs are produced, inline, offline, or under contract. What this proposed rule does is it pertains to food facilities. Most of our egg producers fall under the category of a food facility. This is going to affect them in some way. The likelihood that they will fall under an exemption is pretty slim, because of the definition of a food facility, and if they are a food facility they have to reregister under the bioterrorism act then they will have to follow the rule when it is final.”

The proposed rule is over 700 pages long and it requires firms have written plans in place to identify potential hazards, put in place steps to address them, verify that the steps are working, and outline how to correct any problems that arise. In short, the rule calls for firms producing human food to have the key elements of a HACCP plan without saying they have to have a HACCP plan. Egg products plants are inspected by USDA FSIS and these facilities are already required to have a HACCP plan. Shell egg packing facilities that have a USDA grader also conduct specified food safety checks and document them, and these activities are verified by the grader. But what about egg farms that don’t produce egg products and don’t have a grader?

All egg farms with 3,000 or more layers that produce shell eggs for human consumption now fall under the Egg Safety Rule which requires each facility to have a plan in place for the prevention of Salmonella enteriditis contamination. The egg farm’s Salmonella enteriditis prevention plan functions like a HACCP plan that has one mandated hazard, Salmonella enteriditis, and a few dictated critical control points, e.g., rodent and fly indices, environmental sampling for Salmonella enteriditis, egg cooler temperature, etc. Eberle said that it is likely that egg producers are already doing some of the things that FDA’s final rule for preventative controls for human food will require. She did stress that egg producers might have to change the way they document these current activities.

To satisfy the requirements of the Egg Safety Rule, egg producers have developed programs for their farms which are like a mini-HACCP plan with one defined hazard, Salmonella enteriditis. Complying with the new rule will likely require egg producers to expand their egg safety programs and include other hazards besides Salmonella enteriditis. Many of the Salmonella enteriditis prevention steps, for instance pest control, are also beneficial in controlling other microbiological hazards, so some aspects of current Salmonella enteriditis prevention will serve double duty. But, it is possible that other hazards will require different tests for monitoring and other CCPs may be established. 

Many egg producers have already identified additional food safety hazards in their operations besides Salmonella enteriditis and are already taking steps to monitor processes and reduce the likelihood of the hazards. For instance, Eberle suggested that egg producers that are already participating in a third-party food safety system like SQF would probably have little difficulty adapting procedures and documentation for the new FDA rule. 

Comments on the proposed rule, which covers an incredible variety of food items, are due by May 16, 2013.