Shane Commentary


Unfair Criticism of Cage-Free Production

May 25, 2016


Egg Farmers of America represents a relative minority of U.S. egg producers intent on maintaining the status quo with respect to caged housing of hens. The Association has mounted a public relations initiative organized by their spokesperson Ken Klippen. 

Articles are popping up in agricultural magazines and newsletters the most recent of which was published in Ag Week on May 5th.


The National Association of Egg Farmers claims:-

  • The caged system is more humane than alternatives.  Given that virtually the entire egg distribution system comprising QSRs, restaurants, institutions, retailers and food service companies have committed to converting to cage-free housing by 2025, any unsubstantiated opinions on the relative welfare of caged or cage-free housing are moot.  The train has left the station and there is no stopping it.
  • Cage-free eggs are more likely to be contaminated with bacteria due to prolonged exposure from litter and manure in nest boxes. This is an unsubstantiated claim.  Approximately nine percent of U.S. eggs are produced in other than cages.  Since 2011 here have been no reports of SE associated with commercial organic or barn-housed flocks on slats or in aviaries.  Although there have been some cases of SE reported, these have been in small flocks under the 3,000 cut-off imposed by the Food and Drug Administration as designated under the Final Rule to Prevent Salmonella Infection.
  • Workers in cage-free barns will be hurt by dust which can transport pathogens.  This is a spurious claim since there is no data relating to environmental health problems among workers in barns with either conventional cages or alternative systems.
  • The cost of building cage-free farms will be too high for some existing producers especially ones with smaller operations. All business should set aside a depreciation provision to replace equipment.  Buildings and farms undergo both time-related and technical obsolescence and should be replaced at intervals.  The companies transiting to cage-free production have allowed a ten-year period although most concerns will require substantial progress towards conversion.  If some small family-operated farms find it impossible to market their product in ten years so be it.  Producers must always adapt and respond to market needs.  When cages that are now five to ten years old reache 2025they can be replaced by floor systems. Owners will benefit from increased unit revenue associated with a production of a non-confined egg.  They can either market directly to boutique stores producing either organic or cage-free product, contract to a larger producer or join a cooperative.

The consistent drumbeat of criticism of cage-free production from the National Association of Egg Farmers is disingenuous and self-serving. Promoting spurious objections to cage-free production represents some vain hope of a re-reset on policy of sourcing eggs over the next decade.  Simply disparaging cage-free production runs counter to the interest of the mainstream egg-production industry which has recognized the need to follow market demand and is responding accordingly.



May 20, 2016


Dole Food Company Inc. has confirmed that the U.S. Department of Justice is investigating the Listeria outbreak emanating from a Springfield, OH. plant preparing and distributing packaged salads. 

From May 2015 to February 2016, 33 patients who contracted listeriosis were all hospitalized and 4 fatalities were recorded.


At issue is the fact that the problem of Listeria contamination was of long-standing with documentation showing positive isolations of the pathogen on nine separate occasions in 2014 and 2015.  In January and February 2016, the FDA inspected the plant and isolated Listeria monocytogenes which was homologous with pathogens isolated from a number of the patients infected, thereby confirming the source.

It is apparent that if management is aware of the presence of  a serious pathogen such as Listeria, Salmonella or E.coli 0157 in plants or products and no action is taken, they will be held criminally liable. 

The situation at Dole closely parallels the ongoing Department of Justice investigation at Blue Bell Creamery since the company’s product precipitated an outbreak of listeriosis in 2015.

We are also reminded of the Peanut Corporation of America case in which management knowingly released product contaminated with Salmonella and even falsified documents, resulting in long prison sentences for the owners and subordinate managers.

The implication for officers and senior management of food and agricultural companies is self-evident.


Organic Certified Grain

May 13, 2016


A recent industry periodical noted an increase in imports of corn mostly as “organic certified” grain. The April 12th USDA-WASDE Report confirmed an increase in imports from 32 million bushels in the March projection for 2016 to 50 million bushels in the subsequent April report.  Although this percentage appears large, 50 million bushels only represents 0.3 percent of the total corn supply. This said the total value of imported specialty corn and soybeans in 2015 amounted to $350 million.  Corn is imported from Romania, the Ukraine and Turkey with extremely high increases in volume over the past two years.


There is concern regarding the use of imported ingredients which are available at a lower cost than domestic certified organic corn.  Over 94 percent of U.S. corn and soybeans are derived from GM seed based on superior yield, lower cost of production and superior sustainability. The higher costs for production of Certified Organic corn are associated with lower availability and the need for segregation in the supply chain. This more than doubles the price of the commodity compared to conventional product without any tangible or quantifiable benefits.

It is questioned whether a consignment of corn from the Ukraine, China or any third world country can be regarded as “organic” with any degree of confidence.  Countries supplying these ingredients are responding to the price differential which will always encourage falsification and deception.  Some exporting nations have a reputation for corruption and with the use of local certifiers, there is no assurance, absent rigid and consistent structured assays, that these products are truly “organic”. 

Since certified organic products must be cultivated without the use of pesticides or herbicides, the question arises whether there is any program administered by the USDA-AMS to collect samples and subject them to GLC assay. Without a structured program there is no deterrent to deception. Any corn kernel with a paper “pedigree” looks like any other kernel.  President Reagan was an exponent of “trust but verify” A program of surveillance and laboratory assay using available test kits is required to confirm that both domestic and imported ingredients are truly organic.

Relying on a paper trail is patently inadequate given the incentives for deception and the reputation of supplying countries.  Heaven forbid that a “foodie” inadvertently consume a GMO-containing ingredient at twice the price of a conventional product. Perhaps it is expedient to work on the “don’t look-don’t know” system.

Any spokesperson of the USDA-AMS or an Organic Certifying Agency is welcome to respond to this editorial to address the issue raised.


Two Decades of GE Technology

May 6, 2016


The International Service for the Acquisition of Agri-Biotech Applications (ISAAA) recently released an annual report on the advances in adoption of biotechnology crops entitled The 20th Anniversary of the Global Commercialization of Biotech Crops.  Since 1996, the land area sown to genetically engineered (GE) seeds has increased from 4.25 million acres to 450 million acres.

Over the same period collectively 5 billion acres of arable land have been planted to GE crops representing twice the land mass of China.  The benefit derived by farmers from GE technology has exceeded $150 billion since 1996 and GE crops have improved the diets of over 65 million people.


Approximately a third of all GE cultivars have multiple (“stacked”) traits with over 130 million acres planted.  These varieties have more than one improved attribute such as drought and insect resistance or the ability to withstand specific herbicides.

Clive James, Founder and Emeritus Chair of the ISAAA noted “more farmers are planting biotech crops in developing countries precisely because biotech crops are a rigorously tested option for improving crop yields.”  Developing nations now plant more GE crops than in industrialized nations with the proportion of 54 to 46 percent.

India and China have both benefited from GE cotton and in India alone, 29 million acres are planted to two GE varieties with benefits achieved by nearly 8 million farmers producing 95 percent of the Nation’s cotton crop in 2015.

Many new GE varieties are non-transgenic and are developed applying gene deletion. The United States has approved Innate™ Generation 1 potatoes with low levels of acrylamide and resistance to bruising.  Subsequent second generation Innate™ potatoes are resistant to blight.  The U.S. has also approved Arctic® apples refractory to bruising and browning.  SU Strain Canola™ has been planted for first time in the U.S. 

The ISAAA report indicated that more than 85 potential new GE products are undergoing field testing including a drought resistant corn for Africa, golden rice in Asia and fortified bananas in Africa both with high vitamin A content to prevent blindness.

It is expected that application of CRISPR technology which allows gene editing will accelerate advances in developing new strains and increased crop productivity on available land to feed burgeoning populations.


Wal-Mart to Discontinue Wild Oats Brand

Apr 29, 2016


Wal-Mart Stores Inc. has announced that it will discontinue marketing the Wild Oats range of organic product which was introduced in 2014.  With a much-heralded introduction, Wal-Mart claimed that it could provide center-of-the store staples including pasta sauce at prices equivalent to conventional products.  The Wild Oats Brand was licensed to Wal-Mart in 2012 by Yucaipa Companies controlled by entrepreneur Ron Burkle of Los Angeles.  The brand was acquired when the Wild Oats chain of stores was acquired by Whole Foods Market but was spun-off in terms of an antitrust settlement. 


It is anticipated that Wal-Mart will begin sourcing organic products from a range of suppliers marketed under their Great Value private label.  Currently the sales of organic food attained $13.4 billion for the year ending April 2nd compared to all food sales valued at $468 billion for the same period.  The rate of growth in organic label products was 16.7 percent compared to 1.6 percent for all products according to Nielsen data cited in an April 26th article by Sarah Nassauer in the Wall Street Journal.

Laura Kennedy an analyst at Kantar Retail, a consulting group noted “Wal-Mart’s move to drop Wild Oats is an odd step to take when we know that they are trying to increase private-label penetration and trying to target the higher-income consumer.”  She added “If Wal-Mart was losing money to a middle- man this is not a time Wal-Mart would want to be losing anything.”

The reference to a middle- man calls to mind the relationship between Wal-Mart Stores and CCF Brands which serves as an intermediate between egg producers and Wal-Mart Stores.  The specific advantages associated with the intermediary have yet to be explained to the industry.  Surely Wal-Mart is capable of drawing up specifications and negotiating with suppliers concerning pricing, quality parameters and delivery schedules?  Either Wal-Mart Stores or CCF Brands are welcome to respond and justify their respective positions in what would appear from the outside to represent an anomaly in the supply chain. As Alice would say, “curiouser and curiouser!”


USDA-AMS Reports on Organic Compliance and Enforcement

Apr 29, 2016


The published appeals summaries posted by USDA-AMS for the reporting period January 2016 to May 2016 yielded 97 complaints with 93 completed reviews and investigations. 

The National Organic Program issued 6 cease and desist orders, 32 warnings and 16 investigative referrals. 

Two settlement agreements were concluded and civil penalties were imposed in some cases.


For the period October 2015 through December 2015, civil penalties amounted to $929,750 with 8 cease and desist orders, 22 warnings, 7 investigative referrals and 5 settlement agreements.

The question arises as to whether the administrators of the NOP are zealous in pursuing the integrity of the “organic” brand or whether they are picking the easy cases. There did not appear to be any action against large Asian exporters who have both the incentive and opportunity to cheat. They function in the absence of a structured assay program for contaminants and freedom from GM adulteration. A paper trail from China might be valid or it may be creative fiction.


Senator Stabenow “Justifies” Position on GMO Labeling

Apr 29, 2016


U.S. Senator Deborah Stabenow (D-MI) recently addressed food policy during her keynote address to the 2016 National Food Policy Conference held in early April under the auspices of the Consumer Federation of America. 

Senator Stabenow believes the food industry should be transparent and accordingly supports GMO labeling however “not in a way that penalizing food and agriculture businesses”. Despite believing in science and her conviction that genetically modified foods are safe, Stabenow wants it both ways! Although she purports to adopt an advocacy position regarding GM ingredients she effectively scuttled the federal Biotechnology Labeling Solutions Act S.2609 which passed out of committee in mid-April but failed to gain sufficient votes in the Senate to avoid cloture.


This was possibly the last chance to impose a federal standard to override the Vermont Act mandating labeling as to GM-content. It is ironic that a state with a population of 600,000 representing less than 0.3 percent of the U.S. population can impose its Ben and Jerry-like philosophy on the entire Nation. One characteristic of socialists is that they are ever ready to spend other folks’ money to advance their environmental, welfare and lifestyle proclivities.  In this they are abetted by wishy-washy politicians like Senator Stabenow and activists like Bernie Sanders. 


UEP Issues Statement on Undercover Intrusion Videos

Apr 22, 2016


According to a press release from the United Egg Producers on April 13th, Chad Gregory, president and CEO noted “For America’s egg farmers, egg safety and hen care are the utmost importance at all times.  Egg farmers across the U.S. recognize and embrace the responsibility to produce safe, high-quality eggs while providing proper care for their flocks and ensuring hen health and well-being.”  He added “We are aware that the activists group Mercy for Animals has released an undercover video that they claim was taken at an egg farm in Pennsylvania.  While images in the video are troubling they do not reflect standard practices on U.S. egg farms.”


Gregory reiterated previous UEP statements that the organization which represents over 95 percent of shell egg producers supports all methods of hen housing for egg production which assure proper hen well-being and meets or exceeds food safety requirements.  The UEP Certified Program with standards for both conventional and cage-free housing in place for more than a decade provides comprehensive, science-based hen welfare guidelines developed by an independent Scientific Advisory Committee.

Your commentator regularly visits egg production units in about 30 states in the U.S. and the practices and images depicted in the Mercy for Animals video absolutely do not represent current practices in the industry.  Previously, independent veterinarians and scientists with experience in welfare have reviewed videos purporting to show unacceptable production practices. They have consistently determined that clandestine videos involved editing and an undue concentration on specific hens with abnormalities selected from among very large flocks. In some cases depictions may contain simulated footage intended to create deception in the interest of raising funds.



Apr 22, 2016


Environmental activists and those opposed to intensive livestock production are also congenitally resistant to any form of genetic modification.  There is no justification for their position since two decades of consuming GMO corn and soybeans has failed to show any deleterious effect on livestock or human health. It is ironic that the most vociferous antagonists of GM technology have no objection to using GM-derived insulin!


Purdue University recently published a study in AgBio Forum quantifying the effect of a reversion to non-GM cultivars.  Corn yield would decline by 11 percent and soybeans by 5 percent.  In addition there would be a 19 percent reduction in cotton production from the acreage currently planted to this crop. Collectively, the deficit would require planting an additional 255 thousand acres of land in the U.S. and approximately ten times this area on a global basis.

In the U.S. the price of corn would rise by 17 to 30 percent and soybeans by 11 to 23 percent.  Purdue economists predicted a 1 percent increase in annual food costs with an amount ranging between $7 to $14 billion per year or on average $45 per capita

Environmentalists opposed to GM might contemplate the fact that conventional cultivars are less “sustainable” then their GM counterparts.  Reversion to conventional crops would produce between 500 and 800 million tons of carbon dioxide annually.

The Purdue University study did not take into account the lower application of insecticides and herbicides following the introduction of GMO cultivars.  The fact that U.S. farmers have opted for GM for over 94 percent of corn and soybeans produced confirms the technical and economic benefits.  The grain storage and distribution infrastructure is now dedicated to GM products.  The small quantity of non-GM and specifically, organic corn and soybeans require segregation and specific handling with full traceability.  This adds materially to the costs of these ingredients which are approximately double the price of GM counterparts, without offering any tangible advantage.


SE Case in Denmark Raises Questions

Apr 15, 2016


EGG-CITE is indebted to Dr. Eric Gingerich for circulating a report on a case of Salmonella Enteritidis pt21 infection in a large flock (60,000 hens) in Denmark.

An interesting observation from this report relates to the fact that the flock was clinically affected, demonstrating elevated mortality with peritonitis on post-mortem examination.  Generally with the exception of pt4 strain SE, infection does not produce any obvious clinical signs or post mortem lesions especially in mature chickens.


The second observation is the high prevalence of SE antigen in eggs derived from the flock.  It is a regular observation in the U.S. that flocks which are positive on environmental sampling denoting intestinal colonization, fail to yield SE from 1,000-egg sample pools. This confirms the absence of infection of reproductive tissues which leads to vertical transmission of SE to eggs.

A possible explanation for both anomalies lies in the documented history of the flock.  According to the description, the flock successively demonstrated both coccidiosis and necrotic enteritis which is an unusual observation in replacement egg-strain pullets.  Experience has shown that replacement broiler breeder flocks demonstrating both NE and chronic coccidiosis are usually immunosuppressed due to early exposure to infectious bursa disease as the principal contributory factor.

In 1995 Dr.Michael Opitz and his then graduate student Dr. Rick Phillips demonstrated that infection of pullets with an intermediate strain IBD vaccine at day-old increased susceptibility to exposure to SE at the time of sexual maturity*.

Unfortunately there is no information relating to whether the pullets in Denmark were reared on litter or on wire and whether they were vaccinated (or actually immunized) against IBD and SE.  There was no attempt made to determine the serologic response to other vaccines including IB and ND which may have denoted immunosuppression.

In his covering memo to members of the AVEP Dr. Gingerich correctly noted that there is a fairly board differential diagnosis for peritonitis which is usually associated with E. coli (APEC) infection in the U.S.  Case reports describing low-pathogenicity avian influenza confirmed a fairly consistent finding of peritonitis in flocks exposed to LPAI H5N2 infection in Pennsylvania in mid-1983 and LPAI H6 in California during the early 2000’s.  Peritonitis is also encountered in floor-housed egg production flocks especially in converted broiler breeding units and also aviaries as a result of pasteurellosis.

*Phillips, R.A. and Opitz, H.M. Pathogenicity and persistence of Salmonella Enteritidis and egg contamination in normal and infectious bursal disease virus-infected Leghorn chicks. Avian Dis. 39:778-787 (1995) 



Apr 8, 2016


Noted for creating Dolly, the first cloned domestic animal in 1996, The Roslin Institute is currently investigating genetically engineered chickens.  As a research project, Roslin studies are commendable as they contribute to basic research.  A direct application of GM chickens including transgenesis could be acceptable only to derive specially tailored biopharmaceuticals from eggs. 


From the perspective of enhancing commercial performance, GE chickens are a non-starter.  The world’s leading broiler, turkey and egg primary breeders have agreed not to apply transgenesis or any form of GE technology since this would have an immediate adverse consumer reaction, affecting the entire poultry industry.  It is however acknowledge that the advanced molecular techniques including work with SNIPs can be used to select lines with specific traits and accelerate the rate of improvement applying conventional breeding using index selection.  Introducing new genes or deleting genes is considered to be unacceptable although offering potential benefits in terms of enhanced performance.

In justifying the GE work on chickens, Dr. Ian Dunn refers to vertically transmitted E.coli and Salmonella infection and osteoporosis as problems which may be solved applying GE technology.  He may be too introspective in ignoring consumer-acceptable alternatives including vaccination, enhanced housing and management, conventional breeding and nutrition.  Cobb-Vantress invested $1 million into a three- year research program at Roslin to investigate the possibility of producing a chicken resistant to avian influenza.  Since the company is a signatory to the industry agreement not to apply GE technology, Cobb-Vantress will not pursue commercialization of any developments which may have been derived from their funding.

AquaAdvantage®  salmon were modified by AquaBounty Technologies by insertion of genes for somatotrophic hormone from fast-growing fish species. The “brand” was approved by the FDA in late 2015  but have yet to be introduced into the U.S., awaiting changes to FDA regulations relating to GE animals. Notwithstanding the approval based on studies conducted over 15 years  failing to show any difference between the genetically engineered salmon and non- modified species, there is considerable opposition from activist groups which has resulted in rejection by the restaurant and supermarket industries.

 The entire question of GE/GM labeling has yet to be resolved in the U.S.  At present, Vermont has mandated labeling of any food product containing ingredients of GM origin but a Bill is before Congress to prevent states and local jurisdictions from imposing label regulations which would impede interstate commerce.

The Roslin studies on chicken GE may be scientifically productive but offer little if any prospects for commercialization.


Des Moines Register Draws on DeCoster 2010 Outbreak

Apr 1, 2016


Delving back five years, the Des Moines Register continues to dwell on the Salmonella Enteritidis outbreak (SE) emanating from farms in Iowa operated by Jack DeCoster and his son Peter. Their company, Quality Egg Farms (an oxymoron if there ever was one!) was identified as the principal source of the widespread infection resulting in about 2,000 confirmed cases. 


DeCoster was an aberration who did not reflect practices in the industry at any time during his multi-decade involvement in egg production. Perhaps the only failing of the U.S. egg industry was not to publicly disavow his methods and expose him as a scoff-law, exploiter of workers and architect of deceptive ownership, questionable ethics and illegal practices.

At issue is the complaint that state inspection of Iowa farms has not resumed after the 2015 HPAI outbreak. The Des Moines Register incorrectly claims that this omission places consumers in jeopardy.  The evidence belies this contention since there have been no documented outbreaks of SE by the CDC from any commercial egg farm functioning in accordance with the 2010 FDA Final Rule on Salmonella Prevention. 

One of the reforms proposed in the editorial was more stringent oversight of farms with fewer than 3,000 hens.  This is in fact the only part of the article supported by EGG-CITE.  The UK cut-off for flock size is in the region of 250 hens.  The value of 3,000 allowed by the FDA is far too high as noted in a previous posting.  The recent SE outbreak associated with a backyard farm in Ohio, responsible for approximately 50 cases of salmonellosis is a point in fact since this farm had between 150 and 250 hens.

The additional reforms noted in the Des Moines Register article included:

  • Accreditation and certification standards for laboratories.  These are in effect as any journalist should be able to determine.
  • State-mandated reporting by testing laboratories and egg producers.  Environmental assay of manure at specified flock ages has been required since 2010.  Effectively there have been no incident cases of SE in consumers due to the combination of vaccinating pullets, enhancing biosecurity, refrigeration of product from production through distribution and placing chicks free of SE in accordance with the National Poultry Improvement Plan.  Flocks which were infected with SE prior to 2005 and in a few cases up through 2010 have long been cycled out of production and their housing has been subjected to appropriate decontamination.  The FDA Final Rule clearly designates procedures required in the event of an environmental positive.  It is emphasized that colonization of the intestinal tract with SE will in all probability result in a positive environmental test but this does not necessarily mean that systemic infection has occurred, a precursor for SE to be transferred vertically from reproductive tissues to eggs.
  • Creation of a state mandated Salmonella Detection and Prevention Program. This may be a deficiency in Iowa but there are numerous Egg Quality Assurance Programs in egg-producing states in addition to surveillance by companies marketing branded eggs.
  • Creation of a new funding stream to support the implementation of a statewide egg-safety program.  This may in fact be a suitable initiative for Iowa which has 52 million hens of which less than one-third are maintained for shell production.  The remaining flocks produce egg liquid which is subject to pasteurization and would therefore not represent any potential problem.

The article cited a website posting on Food Control which is a medium for opinion and does not have the creditability or status of mainstream scientific journals with peer review.

The Des Moines Register is banging away at a nonexistent problem as evidenced by epidemiologic data.  If there were cases of egg-borne SE among U.S. consumers, FoodNet and PulseNet would detect outbreaks even if they involved a few cases spread over many states as with the Chipotle Mexican Grill situation.  The concern over SE expressed by The Des Moines Register might have been appropriate in the late 1990’s.  There is adequate scientific evidence to show that the incidence rate of egg-borne SE among consumers started to decline in the late 1990’s coincident with the introduction of state Egg Quality Assurance Programs and the UEP Egg Safety initiatives together with advances made by primary breeders and large producers.

  Perhaps suggestions to enhance surveillance of egg safety made by ex-governor Chet Culver in 2010 have not been implemented because there is in fact no reason to do so at this time. What is applicable in 2010 would now be an anachronism.  This view is shared by current legislators including Rep. John Wills (R-Spirit Lake) who is aware of the requirements of the FDA Final Rule and its implementation.

 The Editorial Board of the Des Moines Register should reassess their position based on a sound evaluation of the current epidemiology of SE. The opinions of ambulance-chasing lawyers and those congenitally opposed to intensive livestock production should have less impact on their depiction of food safety than the reasoned counsel of elected legislators, responsible scientists and administrators of state and federal agencies.


India Still a Difficult Market for QSRs

Mar 30, 2016


An article in the March 23rd edition of the The Wall Street Journal described the travails of multi-national QSRs in India.  Although the nation has a vast population, economic and cultural restraints limit the accessible and qualified market. 

After an initial acceptance of fast food, revenues are falling especially during the past two years.  McDonald’s dropped from a 21 percent same-store sales growth in 2012 to 5 percent in 2013 and for the past two years has experienced a negative 5 percent figure.  Yum! Brands has shown progressively declining same-store sales of -8 percent and -12 percent over the past two years.  Even Domino’s Pizza which showed a 30 percent growth rate in 2012 was in the low single digits for 2014 and will not grow at all in 2015.  Domino’s operates 1,000 stores in India with almost half of these erected during the past five years.


 It is evident that the market for QSR food in India is easily saturated.  This is due to rejection of menu offerings based on North American and EU taste together with competition from lower priced clones and traditional street vendors and store-front operations. Euromonitor International estimated fast food sales in India to be in the region of $120 billion in 2015 but with an 11 percent growth rate from 2014 to 2005 compared to 16 percent for the preceding year. 


In an attempt to reverse the situation, the major chains introduced new menu items tweaked to suit the Indian palate.  Since beef is not acceptable to the majority Hindu population, McDonald’s served chicken-patty burgers.  Recently their Maharaja Mac™ has been spiced up with jalapenos and other sauces and the company has introduced a vegetarian Big Mac™.  (Add The CEO Pizza Hut in India Unnat Varma commented “What used to be a playground for the five big local brands has now become a playground for ten big brands and hundreds of smaller players.”


Who Represents the U.S. Egg Industry?

Mar 25, 2016


During recent weeks, Ken Klippen has issued press reports and appeared on a program at the Midwest Poultry Federation Convention relating to the egg production industry. He serves as the principal for Klippen and Associates and is the designated spokesperson for the National Association of Egg Farmers (NAEF).  He claims that the organization represents 200 egg producers ranging in size from 8,000 hens to more than 5 million.  This total presumably includes contract growers.



When asked to identify the members of his Association, especially the complex or farms with“5-million hens” Ken declined to provide specifics, citing confidentiality and the need to protect his members from intimidation. The activities of the NAEF appear to be confined to lobbying and advocating for a mid-2000s status quo on retention of conventional cages. This is evidenced by the list of presentations, articles, blog postings and representations made by Ken Klippen over the past four years.

The acknowledged representative of the U.S. egg industry is the United Egg Producers, a Capper-Volstead Cooperative which claims to have a membership owning a capacity to house 303 million hens representing 95 percent of the commercial egg-producing flock. The organization was established in 1968, contrasted with the legal filing by NAEP in 2014 although in fairness the organization functioned for a few years prior to this date.  The UEP operates under a Board of Directors comprising 34 elected members who oversee the activities of working committees including Government Relations; Food Safety; Environment; Animal Welfare; Biosecurity; Public Relations; and Organic Production. There is no information available on the structure or composition of the Board or subsidiary committees of the NAEF.

The current major contention between the NAEF and the bulk of the organized industry relates to the transition to “cage-free” housing systems. The NAEF advocates consumer choice and is opposed to any Federal or voluntary mandate to transition from conventional cages to alternative systems as noted in an editorial in EGG-CITE posted on March 18th.

The position of the UEP on housing systems other than conventional cages is expressed in the following statement:-

The UEP will support customers who choose to transition their egg supplies from conventional housing to alternative housing methods.  UEP will develop strategies and implement initiatives that assist our farmer-members in meeting this changing demand in an environment that recognizes consumer choice and is conducive to a practical and effective transition.  We will do so while maintaining the highest standards for egg safety, food affordability, environmental responsibility and excellent care of our hens.

The requirements for both caged and non-caged hens are incorporated in guidelines issued by the UEP which form the basis of their welfare certification program.


Mechanization of QSR Kitchens

Mar 25, 2016


The move by food workers to demand salaries of up to $15.00 per hour will obviously generate evaluation of labor efficiency and will stimulate replacement of workers by mechanization.  Fortune magazine reported on March 18th on the efforts of Andy Puzder, CEO of OKE Restaurants to replace manual labor. 

OKE is the holding company of Carl’s Jr. and Hardee’s.  Puzder is of the opinion that millennials take readily to interaction with touch-screens and automation and are willing to place orders and to pay using kiosks.


Cynically Puzder commented “Machines are always polite, they always up-sell, they never take a vacation, they don’t show up late, are always ICE-compliant, there is never a slip-and-fall compensation claim or an age, sex or racial discrimination lawsuit.”


Identifying Cockerels Pre-Hatch

Mar 25, 2016


Researchers are proposing solutions to what constitutes a non-problem.  Scientists at the Australian Animal Health Laboratory located in Geelong have attached a fluorescent marker to the chromosomes which will be carried by developing male embryos to allow differentiation between males and females prior to hatch.

There is considerable agitation in Europe against destruction of cockerel chicks with activists in Germany and France advocating bans on day-old killing.  Essentially this is an attack on intensive livestock production since activists believe that they can force the egg industry to adopt the alternative of dual-purpose breeds. This anti-industry philosophy is also expressed in opposition to fast-growing efficient broiler breeds.


Using dual-purpose strains is emblematic of the desire to revert to agricultural practices of the 19th century. The Downton Abbey approach must appear eminently self-comforting to people in  Western Europe who enjoy subsidized university education, secured incomes, health care and other social benefits and an abundance of subsidized food.  This may suit15 percent of the World’s citizens but ignores the reality of starvation in parts of Latin America, Asia and Africa.

The chromosome marker approach will not satisfy the activists on two grounds. The first is that transgenesis and genetic engineering are involved.  The second objection will be philosophical, since if it is wrong to kill male chicks after hatch then it is equally wrong to destroy male embryos a few days before hatch.  The same objection would also be applied to technology developed in the U.S. in the 1990’s and now rediscovered in the EU which would differentiate between male and female-embryos by analyzing for the presence of sex hormones in amniotic fluid.

The level of enthusiasm expressed by an Australian producer “At last we got something that is tangible and can deliver real outcomes” is optimistically premature and even if adopted in Australia will be unacceptable to activists in Europe and North America.


National Ag Day

Mar 23, 2016


Although March 15th was National Ag Day, it was apparently overshadowed by primary elections in key states.  Despite the competition, the program to celebrate this momentous event was unlikely to inspire enthusiasm.  The festivities apparently commenced on Monday March 14th with a panel discussion and a reception. 

On Tuesday, members of Congress friendly to agriculture were featured in a special lunch meeting.  In the evening Dr. J. B. Penn the Chief Economist for John Deere spoke at the Celebration of Agriculture Dinner.  Ho hum, zzzzz.



Response to Editorial by Ken Klippen, NAEF

Mar 22, 2016


In the interests of free discourse the following rebuttal to the March 18th Editorial submitted by Ken Klippen, Executive Director of the National Association of Egg Farmers (NAEF) is reproduced with slight editing. EGG-CITE neither endorses nor supports the opinions expressed by Ken.


In rebuttal to your March 18th editorial, there were two speakers at the Midwest Poultry Federation Convention discussing the Simmering Issue of Cage-Free Eggs; John Brunnquell, Egg Innovations and myself representing the National Association of Egg Farmers. Both John and I were in agreement that the market should decide the availability of cage-free eggs.  My principal objection was the forced transition to cage-free claiming better quality eggs and more humane conditions.

In my presentation at the Midwest Poultry Federation Convention, Thursday March 18, I referenced the website article entitled "Cage-Free Eggs Present Food Safety Challenge in Missouri by Dan Flynn, Food Safety News. I also cited two scientific journals shown below and used quotations directly from the papers submitted.

The Journal Poultry Science in 2011 [90, pp. 1586-1593] published "Comparison of shell bacteria from unwashed and washed table eggs harvested from caged laying hens and cage-free floor-housed laying hens."  This study found that the numbers of bacteria on eggs was lower in housing systems that separated hens from manure and shavings. Conventional cages allow the feces to drop through the screen floor whereas in cage-free systems, the eggs are laid in the same general area for manure. 

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 state "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."

The National Association of Egg Farmers was incorporated in December 2014 under the state laws of Delaware. The pressures facing egg farmers to conform to cage-free systems is enormous with the costs approximating $40 per chicken.  The larger farmers likely have the ability to borrow the capital to add cage-free barns, but the smaller farmers will struggle with acquiring investment especially if they are still paying off their caged systems.  This movement to cage-free will lead to more consolidation in the industry with fewer and fewer suppliers of eggs.  These farmers have asked me to speak out in their behalf and I continue to do so.

Thank you for publishing my rebuttal.

Ken Klippen


Poetic Justice or Coincidence? West Virginia Raw Milk Outbreak

Mar 18, 2016


A March 10th posting on ProMED, reported that a number of West Virginia legislators became ill after consuming unpasteurized milk as a celebratory gesture following passage of a law allowing restricted sale and distribution of raw milk in the state.

No definitive diagnosis has been made but it is alleged that those affected demonstrated vomiting and diarrhea a short time after consuming the milk, effectively ruling out Salmonella or Campylobacter infection but symptoms could be attributed to a pre-formed Staphylococcus or other bacterial toxin. 


Another possibility is that consumption of the raw milk had nothing to do with the gastrointestinal condition which may have been due to norovirus infection.  The results of an investigation in progress will determine if raw milk was responsible for the occurrence.

The level of competence and knowledge of legislators supporting the relaxation of the pasteurization rule can be adjudged from the comment by Representative Scott Cadle “There’s nobody up there that got sick off that milk.”

The rule allowing consumption of raw milk from “shared animal ownership” was legalized this year.  The designated “responsible party” in a shared ownership agreement cannot sell or resell raw milk on the market. The new regulation enables citizens of West Virginia to drink raw milk despite the manifold health risks.

It is inexplicable why raw milk is in demand by consumers despite the well-publicized risks of foodborne infection.  The Centers of Disease Control have established that Campylobacter, Salmonella and pathogenic verocytotoxin-producing E. coli are associated with non-pasteurized milk.  In addition to these three major milk-borne pathogens, Brucella, Listeria and Shigella have also been documented in the U.S. in recent years.

Of 121 foodborne outbreaks involving 4,413 cases, attributed to dairy products, 73 percent were associated with unpasteurized milk or cheese prepared from raw milk.

Current literature fails to show any valid difference in nutritional quality between raw and pasteurized milk, effectively negating the claims of proponents of raw milk.  Providing unpasteurized milk to infants and pre-teens is effectively a form of child abuse.


Controversy over Honest Company Detergents

Mar 18, 2016


The Wall Street Journal reported on March 11th that two independent laboratory assays had demonstrated the presence of sodium lauryl sulfate in laundry detergent manufactured by the Honest Company which claims that its highly-priced products are free of the ingredient.


Honest Company was established by a partnership including actress Jessica Alba and is in the process of preparing for an IPO.  In February, the Wall Street Journal accused the Honest Company of “fraudulently labeling dozens of home and personal care products as natural, plant-based or chemical free.”  The Company has vigorously responded to the allegation raised by the Wall Street Journal in a defense currently limited to the social media. To date the Company has not instituted legal action which would have been expected but which would have exposed the Company to the process of discovery.

Should the allegations be substantiated, the future of the Company and the credibility of its founders and officers would be in jeopardy.

The example presented by the Honest Company is similar to the claims made by a number of “all natural” manufacturers of foods, which are sold at a high premium in supermarkets and boutique retail stores catering to an affluent demographic willing to pay for perceived health and safety attributes.