Dear Editor,

Food Safety Website is a daily “must read” for me in representing the National Association of Egg Farms in producing eggs in conventional caged systems nationwide. I appreciate the insights into numerous food safety issues. A recent Letter to the Editor has a cage-free egg farmer claiming cage-free egg production improves on the safety of shell eggs sold to the consuming public.

The frustration of this cage-free egg farmer is readily apparent, but it does not allow his generalizations about commercial farmers as the source of Salmonella. The farmer was criticizing the Food Safety Website article on Salmonella coming from backyard poultry flocks. He failed to recognize the source of that information is the Centers for Disease Control & Prevention. Yet, the farmer criticizing Food Safety Website in his claims that “Large commercial poultry operations that have always used antibiotics inappropriately are the source of salmonella contamination so widespread that the eggs are now laid with the bacteria inside from infected hens. These and other commercial livestock operations that fed low levels of antibiotics because it increased growth rates are also the source of the antibiotic resistant bacteria like MRSA that plague us today. This is the reason the government now requires a warning on egg packages that eggs should be “thoroughly cooked before eating.”

Permit me to set the record straight. Commercial egg farmers with 3,000 or more laying hens whose shell eggs are not processed with a treatment, such as pasteurization, have their farm inspected by the U.S. Food and Drug Administration officials to ensure they have implemented an egg safety program to prevent Salmonella enteritidis. This regulation (21 CFR Parts 16 and 118) Prevention of Salmonella Enteritidis in Shell Eggs During Production, Storage, and Transportation was issued on July 9, 2009, and remains in force today. https://www.govinfo.gov/content/pkg/FR-2009-07-09/pdf/E9-16119.pdf. The regulation requires preventive measures during the production of eggs in poultry houses and requires subsequent refrigeration during storage and transportation.

As to the farmer’s claim that large commercial farms use antibiotics inappropriately, he should know that antibiotics provided egg-laying chickens are not given routinely, but only when the chickens become sick. Antibiotics are not used for growth promotion. The eggs cannot be sold when a flock is being administered with antibiotics until after a prescribed withdrawal period.

Other issues with cage-free egg production include the report from The U.S. Animal Health Association October 17, 2017, which stated: “Ascarids (round worms) are increasingly being found in cage-free operations with the concern being the possibility of a consumer finding an egg with a roundworm contained inside. Most all cage-free egg producers have had such an occurrence.” Chickens pick up roundworms when they come into contact with infected feces on the ground. The Journal Food Control published a study June 17, 2014, entitled “Microbiological Contamination of Shell Eggs Produced in Conventional and Free-Range Housing Systems.” The conclusions show why cages became the preferred method of producing safer eggs: “Battery caged hens (conventional cages) are standing on wire slats that allow feces to fall to a manure collection system beneath the hens. Conversely, free-range hens (cage-free) laid their eggs in nest boxes on shavings and the eggs remained in contact with hens, shavings and fecal material until they are collected. The longer contact time with free-range hens, shavings and feces would explain the higher enterobacteriaceae counts on free-range eggs as compared to battery caged eggs.”

Penn State researchers in September 2016 published their research findings that eggs from small flocks of chickens are more likely to be contaminated with Salmonella enteritidis as eggs sold in grocery stores, which typically come from larger flocks of caged layers. 

Now consider the benefits of producing eggs from caged layers. Researchers at the Egg Industry Center in Ames, IA, found that today’s hens are living longer due to better health, better nutrition and better living environments. These researchers studied U.S. egg production over a 50-year period, from 1960 to 2010. Today’s egg farmers are producing more eggs in 2010 than 50 years earlier. Using 1960 technology to produce the 2010 egg supply would have required 78 million more hens, 1.3 million more acres of corn and 1.8 million more acres of soybeans.

In comparison to 1960 technology, today’s commercial egg farmers are using conventional cages to be able to feed 72 percent more people.

Thank you.

— Ken Klippen, President
National Association of Egg Farmers

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Editor’s note: We want to hear from our readers. Letters to the Editor can be submitted via the Contact Us link on our website.

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Dear Editor,

I am writing in response to the STEC E. coli article related to the Purdue Study.

I am a board adviser for the Aquaponic Association and a commercial aquaponic grower. We believe that the Purdue study was very flawed and that they had poor handling procedures and created a cross-contamination issue between their other cattle, swing and livestock production and the aquaponic and hydroponic systems in the study. Furthermore they did not perform traceback as they mentioned it was outside the scope of work. In addition, they allowed a level 2 STEC E. coli contaminate to remain in their study systems and lab environments possibly endangering students, staff and potentially even cross contaminating their larger systems. This seems horribly negligent.

No other study has found fish feces to be the source of a pathogen. The only relationship is for fish that are reared in water that is already been contaminated with mammal or human feces.

Here is the Aquaponic Association response written by several university professors from U.S. and Canada as well as commercial members.

— Tawnya Sawyer

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Dear Editor:

Will your supermarket warn you about hazardous food? Absolutely.

Fortunately for the nation’s grocery shoppers, the food industry has honed its expertise over the years – their reputation and economic viability demand they get this right. What U.S. PIRG describes in its recent survey as a communication challenge regarding food recalls, is only the final step of a food safety management program to effectively and efficiently remove potentially harmful products from commerce.

And believe me, a lot of people have opinions about how this information should be delivered to consumers since supermarkets touch the lives of 100 million households, and 91% of adults are regular food shoppers.

In our recent comments to the U.S. Food and Drug Administration (FDA), we addressed how food retailers respond to recalls with their supply chain partners. Ultimately, the food supply chain works within the regulatory framework and acts quickly to remove recalled product from shelves and notify shoppers. This is the most fundamental service grocers provide to maintain the trust of their customers. How they communicate this information is largely based on feedback from shoppers. According to FMI U.S. Grocery Shopper Trends 2019, while television remains a top source during a crisis, digital communications methods in the form of email and text messages lead the way in how consumers prefer to hear about food recalls.

Still, we recognize that communication preferences vary generationally and regionally. Therefore, retailers utilize multiple methods of communication depending on the circumstances to communicate recalls to their customers.

While every recall is a response to risk mitigation, they are not always associated with a health danger. Undeclared allergens are actually the leading cause of U.S. food recalls. The FDA has stated that Reportable Food Registry reports of undeclared food allergens increased from 30 percent to 47 percent  during the five year period from 2009-2013. For example, a wheat-based food may erroneously be marked as gluten free. As a proactive measure to better understand root-cause labeling errors, FMI and its Foundation awarded the Food Allergy Research and Resource Program (FARRP) at the University of Nebraska – Lincoln’s Food Science and Technology Department a $20,000 grant in September 2017 to identify issues and to recommend best-practice procedures for manufacturers, suppliers and retailers in order to reduce undeclared allergen recalls. FMI Foundation is proud to support research which aims to improve public health efforts nationwide.

We will continue to participate in the comments process with government agencies, and our industry remains committed to communicating relevant recall information to customers wherever – and however – they shop.

— Hilary Thesmar, Ph D, RD, CFS, chief food and product safety officer and senior vice president for food safety at FMI.

About FMI: According to the organization’s website, the Food Marketing Institute was formed in 1977 through the merger of the National Association of Food Chains and Super Market Institute, two organizations that had served the industry since the 1930s. Robert Aders, former U.S. undersecretary of labor, became its first president and CEO and served from 1977 – 1993. Other presidents and CEOs of the organization have been Timothy M. Hammonds from 1993 – 2008, and Leslie G. Sarasin from 2008 – present.

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In relation to your recent story, ‘Microenterprise home kitchens’ look for food safety exemptions in Washington, I live in Missouri. In the St Louis area we have rentable fully equipped commercial kitchens so the entrepreneurs can work in an environment where they learn the right way to do things, are available to health inspections, and conform to all the food safety requirements. This is a far better option to keep public safety than allowing home kitchens.

Rates are affordable. Generally a minimum of four hours at $20 to $25 an hour.

An example is The Creative Cookery. They were the last one I used before retiring and selling my business to one of the chef’s who was also a user of the shared kitchen.

One thing a small emerging business needs is contact with others who are trying to do similar things. You can help each other and learn from each. Before I retired I was a presenter who often did presentations to other small business owners for the local SBA.

Anyway, I thought this option was missing from your article on home kitchens.

— Laura Bozzay

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Opinion

Interesting read on the decision of permanently banning horse slaughter in the US – and exports? Why are Canada and Mexico still receiving horses for slaughter?

The bill should also address the inhumane transport of horses in cattle liners – they are transferred near the border to larger trailers to give the appearance of humane transport before clearing the borders. These are “reject” horses from the race tracks and from people doing uncontrolled breeding of horses to get a cute foal; then they become a burden to care and train so they are starved or dumped and considered feral.

Have a proper strategy for the unwanted horses. Create a fee for racetracks that requires proper adoption of the losers from the track. Create a license for breeders – a fee high enough they have to have a plan for the foals.

Humane societies don’t go far enough in this issue.

Just plain banning for ethical reasons does not prevent unwanted horses. There are legal means of raising horses for meat and very successful – just like the other meat industries there are withdrawal periods for medications – so apply them the same to horses.

— Toni Allardyce-Harris

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Dear Editor,

As a former CFIA ( Canadian Food Inspection Agency) inspector, I have been following this story regarding the change in inspections on the hog plants with great interest. Change is hard but it doesn’t mean the job is eliminated. For the hog program to have the plant do the inspections is a good business move and it can free up the inspectors to focus more on other areas in the plant.

Canada has approved MPIP ( Modernized Poultry Inspection Program) and a recent hog modernized program. The plants had to go through a graduated process in order to enable full inspection by plant line workers. It still entails full inspection but hands off. An inspector shadows the workers and ensures all defects are detected.

The plant must maintain regular statiscally accurate sampling inspections for carcass defects using a coordinated statistical sample plan and the CFIA inspectors perform mirror inspections to verify the line is still operating with minimal defects.

I do not know if the USDA is tasked with approval and training for the independent plant inspections, but this method may be the best for both sides. Presence in the plants is still maintained and the inspectors can focus on other compliance verifications through the operations. The CFIA has CVS and SIP which is a structured program to inspect various prerequisites and critical areas based on the plants’ HACCP plans.

I do not know how the U.S. structures their inspections, but line efficiencies are needed in all types of slaughter facilities to minimize animal stress at slaughter and keep pathogen growth in check after product is processed

— Toni Allardyce-Harris

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Dear Editor,

I am submitting this letter in response to Dan Flynn’s earlier piece regarding pork inspection line speeds.

The federal government’s decision to put pork producers in charge of their own food safety inspections — while letting them set the line speeds that inspection workers must follow — is a recipe for disaster, despite what Flynn would have you believe.

Under a rule change that became final in December 2019, the U.S. Department of Agriculture will put pork producers largely in charge of their own food safety inspections. Instead of requiring federal employees to conduct comprehensive examinations of each animal carcass, those inspections now will be handled by workers hired by the pork companies themselves.

The pork companies will be able to adjust the inspection line speeds whenever they like — potentially putting workers at higher risk of injury as they have less and less time to inspect each animal.

Make no mistake, this rule change isn’t about meeting higher food safety standards. It’s about moving product faster and cutting cost for the meat companies. About 40 percent of federal inspector jobs in hog slaughter plants will be lost as the work is outsourced to lower paid, less skilled company workers.

The new pork rule follows similar changes made to the poultry inspection process a few years ago. It’s all part of a larger assault on the hardworking federal employees who help guarantee that the food you eat is safe.

As the head of the union that represents more than 6,500 food inspectors nationwide, I happen to believe that the USDA’s only concerns should be the safety of our food and the safety of its employees. On both those counts, the agency gets a Grade F performance.

— Paula Schelling
President, American Federation of Government Employees Council 45

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Dear Editor,

Editor Dan Flynn’s Jan. 12 letter supporting the USDA’s new swine slaughter rule perpetuates so many falsehoods, it merits a lengthy response. Among other things, the new rule removes all line speed limits in pig slaughter plants. Despite Flynn’s claims, which were based on his visit to a veal plant in the Netherlands that operates under an entirely different regulatory regime, the evidence in the United States shows that the New Swine Inspection System (NSIS) will significantly increase the risk of injury to the people who work the lines.

Meatpacking is already one of the most dangerous industries for workers in America. Every day, tens of thousands of hog slaughter workers make the same repetitive motions, thousands upon thousands of times a day, using saws, hooks, and knives to slaughter and break down hogs into the pork steaks that we all buy and eat.

The plants are loud, wet, and slippery from fat and grease. They are hot on the slaughter side and very cold on the fabrication side. The production pressure on all workers is unrelenting — keep the lines running at all costs. The result: overall injury and illness rates twice the national average; and illness rates, which include repetitive motion injuries, among the highest of all industries in the United States.

The scientific evidence in the record for the NSIS is clear: the faster hog slaughter workers must do their tasks, the higher the risk of injury. The record contains more than three decades of studies directly tying line speeds to the industry’s staggeringly high rate of work-related injuries and illnesses. In fact, 30 years ago, the Occupational Safety and Health Administration (OSHA) published guidelines to help meatpackers reduce the high rates of repetitive motion disorders in their plants, stating that one way to decrease these disorders is by “reducing the total number of repetitions per employee by such means as decreasing production rates.” OSHA, however, does not directly regulate line speeds. And despite its 30-year-old recommendation, line speeds have not decreased and injury rates remain shockingly high.

Worker safety is not a red herring. There are real negative consequences for workers, consumers, and animal welfare. Even USDA stated in its NSIS proposed rule that “evaluation of the effects of line speed on food safety should include the effects of line speed on establishment employee safety.” High rates of worker injury lead to high turnover rates, which studies have shown leads to decreases in food safety. In fact, the USDA did not allow chicken plants to increase their line speeds in the 2014 New Poultry Inspection System because of concerns about the impact on worker and consumer safety. But the current USDA completely failed to address this concern in finalizing the NSIS.

The USDA received thousands of comments requesting that it consider the impact of the proposed rule on worker safety — just like USDA would consider any other unintended consequences of its regulatory action, as agencies are required to do as a basic principle of governance. These commenters submitted detailed, credible evidence, but were given the brush-off.

When the USDA first proposed its rule removing line speed limits, it relied on a flawed data analysis—which it tried to hide from the public—that downplayed the dangers posed to workers. After being lambasted by statistical experts for its head-scratching findings, the USDA has since tried to wash its hands of any worker safety analysis, claiming it lacks the necessary expertise to even examine the evidence on the impact on worker safety. Readers should be aware that the USDA’s own Office of Inspector General has opened an investigation into the agency’s reliance on a disingenuous analysis in the proposed rule, the lack of transparency, and other irregularities.

Editor Flynn’s statement that the challenge to the NSIS was brought by “the U.S. union representing our friends the meat inspectors” is simply wrong. None of the three court cases challenging the NSIS were brought by any union representing meat inspectors. Rather, the pending Minnesota case was brought by unions representing the hog slaughter plant employees — the tens of thousands of workers who slaughter and break and box up the pork in processing plants nationwide, and whose physical health and safety are at stake.

It’s clear from the final rule that the USDA is fully aware that workers in pork slaughter houses will now work harder and faster because of this rule. When the agency conducted its cost-benefit analysis, the main benefits came from hog slaughter plants being allowed to crank up the chain speed and make all workers do their jobs faster. Assuming a line speed increase of 12.49 percent, USDA found that each plant that adopts the NSIS will see a profit increase of $2.04 million. That’s what this rule change is really about.

 — Debbie Berkowitz
program director of worker safety and health at the National Employment Law Project and previously chief of staff and senior adviser at the Occupational Safety and Health Administration

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