Shane Commentary


Extent of Illegality in the Food Industry of China Revealed

Jan 19, 2017


Bi Jingquan, Director of the equivalent of the Food and Drug Administration in China recently reported that more than 500,000 cases of illegal activity were disclosed following 15 million inspections of food facilities.

The activity to uncover deception, the use of illegal ingredients and counterfeit foods, follows a national program to uproot corruption and to conform to established legal standards.


EGG-CITE has frequently commented on the de facto standard of food-safety in China which reflects avarice and a callous disregard for public safety. A nation which is indifferent to the quality of products sold domestically will obviously have little concern for exports. 

The FDA is nominally responsible to ensure the wholesomeness of imported products but admits that it inspects less than two percent of imports. It is a matter of record that inspectors only  rarely apply sophisticated analytical screening to detect the presence of illegal residues, toxic adulterants and mislabeled products.

The Agency finds it far easier to address non-problems such as SE in large commercial farms which have been free of the infection for upwards of 10 years than to expend resources on addressing more significant and challenging situations represented by potentially harmful large-scale food imports from Asia.


Why do Chefs Exert Inordinate Influence on the Food Industry?

Jan 13, 2017


Over the past 20 years, celebrity chefs through their cookbooks, appearances on television and contributions to the social media appear to have exerted an inordinate influence on culinary trends and the food industry.  It must be remembered that many of the prominent members of the American Culinary Federation are self-taught or espouse a specific ethnic food.  A review of the course offerings for-profit culinary institute which claims status as a ‘university’ shows deficiencies in food science and public health which would be expected of their graduates.


The National Restaurant Association recently published a survey comprising 1,300 professional chefs affiliated to the American Culinary Federation.  The objective was to compile the “what’s hot” list to identify themes (fads?) which will find their way onto menus in 2017. The survey identified twenty food trends, many of which were duplications or were closely connected.

  • It would appear that “house-made” is a common theme involving six of the twenty trends.  These include house-made condiments, sausages, ice cream and cheeses.  Surely “house-made” which is not subject to the rigorous microbiological evaluation and HACCP systems in commercial food manufacturing or in commissaries is what created problems at Chipotle Mexican Grill during 2015.
  • Ethnic-inspired flavors and menu items represented four of the twenty trends for 2017.  Ethnic cuisines tends to be popular until the next iteration emerges. This is denoted by the failure of many restaurants within a year of establishment especially in our costal metropolitan areas.
  • The list of trends was rounded out by projections for “healthful” foods emphasizing vegetable-protein for both adults and children.

A recent example of an unfortunate combination of a lack of knowledge or concern for food-borne disease can be found in the financial performance of Chipotle Mexican Grill. The Company was established by an entrepreneur trained as a chef.  Conceptual and practical defects in the supply chain and in both the training and management of store-personnel directly contributed to outbreaks of at least four different food-borne infections in 2015. This resulted in consumer disaffection and the evaporation of billions from the market capitalization of the company

In many respects celebrity chefs are practitioners of their art. It probably does not matter if a sculptor is unaware of the crystalline structure of marble which is formed into a statue or if an artist is unaware of the organic chemistry of pigments used.  It is however important for an executive chef organizing a kitchen or an enterprise to be constantly aware of how food-borne pathogens are introduced into establishments and how disease can be prevented by appropriate handling and cooking.


Dairy Foods Associations Petition FDA for Enforcement of “Milk” Designation

Jan 13, 2017


The dairy industry represented by the Dairy Foods Association and the National Milk Producers’ Federation addressed a recent letter to the Food and Drug Administration to require the Agency to enforce label restrictions over the term “milk”. 

This is a response to the competition encountered by the dairy industry from vegetable-derived milk products.


Jim Mulhern, President and CEO of the National Milk Producers’ Federation said “in the many years since we first raised concerns about the misbranding of these products, we have seen an explosion of imitators attaching the word “milk” to everything from hemp to peas to algae. We don't need new regulations on this issue, we just need FDA to enforce those that we have on the books.”  It is generally conceded that milk can be defined as “the lacteal secretion obtained by the complete milking of healthy cows.”

A parallel situation, albeit not as critical, concerns egg substitutes to produce mayonnaise and alternatives with inferior functional properties promoted to replace eggs in baking and food preparation.

The claims made by Hampton Creek, producer of a non-egg mayonnaise-product were the subject of litigation with the FDA. The Agency allowed the trade name “Just Mayo™” despite the fact that the legal definition of mayonnaise requires incorporation of eggs in the formula.

The American Egg Board has generated extensive publicity to counter the use of alternatives in the baking industry.  The problem of substitution arose during the period of an unprecedented rise in the cost of pasteurized egg products following the 2015 outbreak of highly pathogenic avian influenza.  Now that flocks have been restocked and prices have declined to normal levels with adequate availability, the use of eggs by the baking industry has increased based on contribution to product quality.

The U.S egg-production industry must maintain vigilance over the integrity of eggs. Currently we are well served by the UEP, the U.S. Poultry and Egg Association and the American Egg Board who are concerned with the image of eggs. We should carefully monitor events relating to milk substitutes impacting the dairy industry which previously condoned the growth of milk substitutes.



Jan 6, 2017


It is possible that the USDA-AMS has run out of time to be able to publish a Final Rule which is a prerequisite to implementing new regulations governing organic livestock production.

At issue for the egg-production industry is the proposed minimum outside access requirement. Proposed area requirements of up to 3 foot2 per hen would have effectively disqualified commercial organic production from in-line aviary operations with sun-porches. This would have benefitted small-scale independent or contract family farms. 

EGG-CITE has noted previously that the previous National Organic Standards Board favored so-called “small family farms” to the detriment of commercial family-owned complexes which effectively provide the bulk of organic eggs to the U.S. market. 


Tom Vilsack

Faithful to his favored constituency to the very end and erudite as ever, outgoing Secretary of the USDA, Tom Vilsack stated, “I’m hopeful that we can get them (the regulations) done”.  He added, “I can’t guaranteed that they’ll get done before I leave but I’m hopeful that they’ll get done”. 

It is acknowledged that there is lack of definition in current regulations which allows for individual interpretation by organic certifiers with resulting inconsistency across the organic egg industry. 

Outside access by flocks is in any event unnecessary with regard to welfare and productivity.  In the context of catastrophic diseases such as highly pathogenic avian influenza carried by free- living and migratory birds, outside access represents an unacceptable risk.  It is noted that veterinary authorities in all EU countries have specifically embargoed outside access and free-range housing for at least thirty days with every expectation of an extension, given the extent and rising incidence rate of infection.

Many of the concepts promoted by traditional organic producers have no scientific basis including the need to have contact with earth.  Proposed regulations were no more than a thinly veiled attempt to exclude existing in-line aviary complexes from participating in the organic market.

The evident bias by outgoing Secretary Vilsack and his appointees is evident in his statement on the proposed rules and in the actions by his Department during his eight-year tenure.


Controversy over the Role of Sugar in Obesity and Health

Jan 6, 2017

Recent epidemiologic reviews of nutrition and health outcomes have shifted the focus from fats to sugar as a factor in causing obesity and cardiovascular disease.  The egg industry suffered for at least two decades from consumer rejection of shell eggs and egg products based on the presumption that cholesterol and unsaturated fats were responsible for adverse health issues. 

It now emerges that much of the research demonstrating a deleterious effect from consumption of fats was funded by associations and companies with a vested interest in promoting sugar.

For many years opponents of sugar were denigrated in the literature by reputable scientists with financial ties to trade associations representing the interests of the packaged food and sugar industries.

Fortunately “the cholesterol myth” has been effectively debunked, mainly due to the efforts of scientists funded by the American Egg Board.  The present controversy which focuses on Type II diabetes has serious implications for regulators who guide recommendations on nutrition and on legislators intent on placing punitive taxes on beverages with a high sugar content. 

A recent review published in The Annals of Internal Medicine questioning recent epidemiologic studies on the role of sugar in metabolic disease has been widely criticized by independent scientists.  The review was sponsored by the International Life Sciences Institute which is supported by multinational companies including Coca Cola, General Mills, Hershey’s, Kellogg’s and Monsanto.  The article questioned World Health Organization and USDA guidelines counseling restriction of sugar intake in beverages and candy.

There is a profound lack of impartiality among scientists both for and against restriction of sugar intake since both sides appear to have vested interests. Some specialists with involvement in establishing guidelines issued by the World Health Organization and the American Health Association point to epidemiologic associations among obesity, the incidence rate of Type II diabetes and intake of sugar. Some specialists also maintain that total caloric intake from both sugar and starch (and expenditure through exercise) should be taken into consideration in developing nutritional guidelines.

At the end of the day it appears that emphasis on fat intake has abated and that prevailing scientific opinion endorses consumption of an egg each day by consumers with no predisposition to rare familial hypercholesterolemia.


Food Waste Increased by “Sell By” Dates

Dec 30, 2016


The is a growing realization that post-harvest waste in the U.S. is a significant problem.  It is calculated that the cost of disposing of date-expired food amounts to almost $2,000 per average household.

The USDA will issue new guidance relating to “sell by” and “best if used by” dates on labels.


The USDA Deputy Undersecretary for Food Safety, Al Almanza, noted “in an effort to reduce food loss and waste these changes will give consumers clear and consistent information when it comes to date labeling on the food they buy.  This new guidance can help consumers save money and curb the amount of wholesome food going into trash.”

The Food Safety and Inspection Service will recommend “Best if Used By” to differentiate a specific label date from the concept of wholesomeness.

It is noted that various state regulations specify a “sell by” date imprinted on egg packs.  This requirement is now superfluous given the universal application of refrigeration from pack to point-of-sale together with more rapid delivery and rotation of stock.  Eliminating Salmonella Enteritidis from commercial flocks has reduced the risk to consumers to negligible levels. It is questioned whether shorter pre-sale allowances imposed by some states are in fact intended to enhance food safety or whether the objective is to discriminate against eggs transported into the states concerned.


Concern over HPAI in Asia

Dec 23, 2016


With a severe outbreak of H5N6 avian influenza raging in South Korea and reports of additional farms being affected with this virus on Kyushu Island, in Japan, producers in China are expressing concern over the possibility of introduction of this infection into their flocks.  An added concern is that China has experienced waves of H7N9 avian influenza infection in humans attributed to intimate contact with infected live chickens on farms and in wet markets. It is a matter of fact that wet markets are an important source of poultry meat in rural as well as urban areas despite the presence of supermarkets and QSRs in cities. 


A December 20th report in Reuters by Hallie Gu and Jane Chung indicates the extent of inappropriate responses in China to the imminence of HPAI entering flocks.  A spokesperson for a state-owned farm in Shandong Province noted “we feed chickens health-care products, vitamins and anti-virus medicine.”  He added “previously we fed them once every three months but starting from winter time we feed them once every week.”  The reference to ‘anti-virus medication’ is significant since China has consistently and inappropriately used antiviral drugs such as oseltamivir (Tamiflu®) indiscriminately in poultry as a prophylactic measure to the detriment of efficacy in treating humans with this class of drug. 

Intensifying vaccination is beneficial since various serotypes of avian influenza are endemic in China. Creating an immune population among commercial flocks will limit propagation of virus in the event of infection but will also complicate recognition of affected flocks unless DIVA vaccines are used. Immunized flocks will still excrete virus if infected but flocks may be spared catastrophic mortality. Effectively in China birds from flocks not showing obvious clinical signs will be consigned to market unless appropriate surveillance and quarantine restrictions are imposed as components of control programs.

A regional meeting was held in Beijing during the past week to consider measures to prevent and control avian influenza in East Asia.  Representatives from Japan and South Korea which are both affected reviewed the situation with the host Nation.

A typical reaction by Chinese authorities following outbreaks of controllable infections is to place blanket bans on importation from entire nations. Currently this extends to about sixty countries with respect to avian influenza. China, either through institutional ignorance or by design ignores the World Organization for Animal Health (OIE) principles of regionalization and compartmentalization.  Neglect of the latter provision has reduced the ability of the Nation to import grandparent-level  breeding stock from approved compartments in the EU and the U.S. Currently the country is experiencing shortages of commercial chicks of acceptable genetic potential as a result of bans imposed in 2014 and 2015 which have not been amended or relaxed.

In contrast to smaller-scale commercial producers in China who rely on a combination of traditional witchcraft, misuse of drugs and nominal biosecurity, the major suppliers of parent stock for meat and egg-producing strains have intensified biosecurity in recognition of the epidemiology of avian influenza. They have presumably adopted Western practices relating to both Structural and Operational biosecurity.

Japan has confirmed five outbreaks of H5N6 avian influenza since the end of November requiring depletion of 800,000 chickens in addition to flocks of waterfowl.  The position in South Korea is more serious with close to 20 million poultry, principally egg producing flocks, having been depleted since mid-November.  Events in South Korea are closely following previous recent outbreaks which resulted in destruction of as many as one-third of the poultry population. 

Given the extent of infection and its financial consequences it would appear justified for South Korea to introduce mass vaccination to gain time in controlling the spread of infection and to reduce losses associated with their current attempt at eradication. Even if this goal is achieved by early 2017 the Nation will invariably be faced with re-introduction of H5N6 or some other recombinant strain by migratory birds in 2018 or 2019.

Southeast Asia is moving to a “seasonal endemic status” requiring costly and ineffective attempts at long-term eradication. If re-introduction of H5 and H7 strains of highly pathogenic avian influenza become a semi-annual occurrence the Nations impacted to should review their policies on control.

In place of eradication authorities should consider suppression of clinical infection using live-vector vaccines for priming and for broilers followed by effective homologous inactivated emulsions for breeders and egg-producing flocks. 



Dec 23, 2016


It is possible that the USDA-AMS has run out of time to be able to publish a Final Rule which is a prerequisite to implementing new regulations governing organic livestock production.

At issue for the egg-production industry is the proposed minimum outside access requirement. Proposed area requirements of up to 3 foot2 per hen would have effectively disqualified commercial organic production from in-line aviary operations with sun-porches. This would have benefitted small-scale independent or contract family farms. 

EGG-CITE has noted previously that the previous National Organic Standards Board favored so-called “small family farms” to the detriment of commercial family-owned complexes which effectively provide the bulk of organic eggs to the U.S. market. 


Tom Vilsack

Faithful to his favored constituency to the very end and erudite as ever, outgoing Secretary of the USDA, Tom Vilsack stated, “I’m hopeful that we can get them (the regulations) done”.  He added, “I can’t guaranteed that they’ll get done before I leave but I’m hopeful that they’ll get done”. 

It is acknowledged that there is lack of definition in current regulations which allows for individual interpretation by organic certifiers with resulting inconsistency across the organic egg industry. 

Outside access by flocks is in any event unnecessary with regard to welfare and productivity.  In the context of catastrophic diseases such as highly pathogenic avian influenza carried by free- living and migratory birds, outside access represents an unacceptable risk.  It is noted that veterinary authorities in all EU countries have specifically embargoed outside access and free-range housing for at least thirty days with every expectation of an extension, given the extent and rising incidence rate of infection.

Many of the concepts promoted by traditional organic producers have no scientific basis including the need to have contact with earth.  Proposed regulations were no more than a thinly veiled attempt to exclude existing in-line aviary complexes from participating in the organic market.

The evident bias by outgoing Secretary Vilsack and his appointees is evident in his statement on the proposed rules and in the actions by his Department during his eight-year tenure.


AIV Isolated from Antarctic Penguins

Dec 16, 2016


Previously EGG-CITE reported on isolation of avian influenza virus from penguins.  The full report on the serotype and prevalence is included in an article in the December edition of Emerging Infectious Diseases*.

Wildlife biologists and virologists from Chile carried out surveys on penguins from nine locations in the Antarctic Peninsula.  Five serum samples from 138 birds demonstrated the presence of influenza antibody. 

A total of 21 positive AIV isolates were obtained from 513 cloacal swabs from Adelie penguins (Pygoscelis adeliae) and Chinstrap penguins (Pygoscelis antarcticus) on Aitcho Island located at a latitude approximately 64°South. 

The virus was identified as a recombinant H5N5 strain.  The hemagglutinin gene corresponded to a North American low-pathogenicity lineage associated with migratory ducks over the 2007-2014 period and blue-winged teals (Anas discors) from Guatemala in 2010.

The neuraminidase was derived from Eurasian N5 clade associated with wild ducks in South Korea during 2008.  Eurasian N5 genes have been demonstrated in ruddy turnstones (Arenaria interpris) and sandpipers (Bartramia sp.) in the Delaware Bay.


Evidently genes for the H5 component were introduced into the Antarctic indirectly from the Pacific or Mississippi flyways, possibly by migratory petrels, gulls or skuas which cohabit with penguins during the summer nesting season.  It was concluded that the H5N5 AI virus isolated from penguins was a contemporary reassortant introduced by migratory birds and may represent a threat to indigenous penguin populations.

The emergence of reassortant AIV at 64°South denotes the widespread distribution of AIV and the potential for emergence of new strains which threaten commercial poultry, justifying intensive biosecurity.

*Barriga et al Avian Influenza Virus H5 Strain with North American and Eurasian Lineage Genes in an Antarctic Penguin. Emerging Infectious Diseases 22: 2221-2223 (2016).



Dec 9, 2016


Faced with the inevitable spread of Zika virus infection and its consequences to the unborn, research and development of appropriate vaccines has received both funding and attention.  In a perspective article, Drs. Mark Lipsitch and Benjamin Cowling of the Harvard T.H. Chan School of Public Health and the University of Hong Kong respectively make a strong case for the development of Zika vaccines*. The researchers consider both practical and ethical considerations in testing vaccines which may or may not require administration of placebos and random selection of subjects.  In the case of evaluating prospective vaccines in 2015 against Ebola virus infection which has a high fatality rate, the ethics of administering a placebo vaccine were questioned.  In the case of Zika virus, which is a relatively mild infection, other than for pregnant women, double-blind studies are feasible.


Dr. Henry Miller of the Hoover Institute has raised important issues regarding widespread application of a Zika vaccine.  He raises the important question of safety and the ability to detect undesirable outcomes of vaccination with limited-scale trials.  Miller notes that Zika and Dengue fever are both caused by flaviviruses and that an immune responses to a second exposure to Dengue virus results in a severe reaction.  He suggests that Zika vaccination on a wide scale may result in an undesirable immune response if recipients are subsequently exposed to Dengue virus.  Zika virus is also associated with Guillain-Barre Syndrome, an autoimmune condition causing  transient paralysis of varying severity.  It will be necessary to confirm that Zika virus vaccines do not elicit an autoimmune response as occurred with the “Swine Flu” vaccine in 1976.

*Lipsitch, M. and Cowling, B. J. Zika Vaccine Trials. Science 353:1094-1095 (2015)



Chicken and Egg Initiative for Haiti

Dec 2, 2016


Recently the USPOULTRY website published a solicitation for donations for the “Chicken and Egg Initiative” organized by a faith-based 501(c) 3 charity 410 Bridge.  Their intent is commendable but the practicality and financial viability are questioned. 

Maintaining hens under free-range, subsistence conditions in rural Haiti will not result in any appreciable reproduction of stock or numbers of table eggs, especially without confinement, adequate nutrition and supplementary lighting during winter. 


The proposal notes that “410 Bridge will purchase and consolidate eggs produced by the families that will be sold to wholesalers in urban markets”. From personal experience and observation in Haiti, virtually all eggs sold on street markets are introduced from the Dominican Republic and distributed through a chain of middlemen and traders at prices far lower than could be produced under inefficient and primitive conditions in rural Haiti.

Given the realities of the island nation, the organizers of the project are challenged as to the practical and financial viability of the proposed enterprise. As far as the retail sale of eggs through supermarkets is concerned, packaged eggs are imported from the U.S. In addition, two local producers supply eggs at prices which approximate those of imported U.S. product. 

If the intent were to provide families with eggs to be consumed as a supplement to their meager nutrition, the project would be worthwhile but $35 for two chickens to be supplied to a family appears exorbitant. A far better approach would be to provide started pullets to village cooperatives housing hens in suspended cages in open sheds.

Eggs could be collected and shared within the community against payment for the pullets and feed. Balanced poultry feed is extremely expensive in Haiti since ingredients are imported. Distribution from Port-au-Prince to the interior will add to cost, placing a question mark on the viability of family farms operated as an income-generating project. Add to this, deficiencies in the transport infrastructure, institutional corruption and other restraints, the proposal appears to be a well-intentioned but impractical enterprise given the operating environment.


HSUS Attacking Checkoff Programs

Nov 25, 2016


In their efforts to oppose intensive livestock production, HSUS has recognized the importance of promotional activities arising from checkoff programs.  Recently the HSUS filed lawsuit against the Office of the Inspector General of the USDA seeking release of documents relating to audits of the beef checkoff including the relationship with the National Cattlemen’s Beef Association.


By creating a barrage of lawsuits, the HSUS is attempting to impede legal activities of Boards promoting animal-source products.  Discovery in the process of lawsuits provides the HSUS with information to be used against both commodity Boards and producers. The aggressive approach by the HSUS generates publicity encouraging support among donors.

It will be remembered that the HSUS successfully restrained the American Egg Board from expending checkoff funds to oppose Proposition #2 in California in late 2008 before the ballot.  The American Egg Board was further embarrassed by revelations obtained through Freedom of Information Act requests concerning attempts to restrain marketing of mayonnaise manufactured without eggs by Hampton Creek.

It can be expected that HSUS will continue to oppose checkoff programs which are recognized as being instrumental in promoting the image of livestock commodities to the benefit of both producers and consumers.


North Carolina State University Research on VSD

Nov 18, 2016


Ventilation shutdown (VSD) is regarded as a “last resort” method to depopulate flocks infected with a catastrophic disease such as HPAI or END.  The USDA-APHIS is committed to depopulation within 48 hours following a diagnosis.  Recent “pop-up” outbreaks of HPAI in turkey flocks in Indiana and Missouri demonstrated the effectiveness of early diagnosis but logistic problems were encountered with the application of foam at winter temperatures. 

These difficulties have now been largely resolved and depopulation of floor-housed flocks including breeding and growing broilers and turkeys should not be a problem if adequate foam generators are available and the process is subject to pre-emptive planning and training of personnel.


The larger problem concerns depopulation of caged flocks which requires either manual removal of hens from cages with transfer to either dumpsters or to carts flushed with carbon dioxide to achieve humane killing. The overriding objective in control of a catastrophic viral disease is to rapidly kill a flock to prevent dissemination of the pathogen. Accordingly application of carbon dioxide, heat and VSD have been evaluated under laboratory and field conditions to ascertain effectiveness, welfare and safety.

At the November 11th NC Poultry health Meeting, Dr. Ken Anderson of the Prestage Department of Poultry Science at North Carolina State University reviewed laboratory studies on the effectiveness of ventilation shutdown with or without application of heat and carbon dioxide. Trials were conducted in chambers approximately 3.4 cubic feet in volume, representing the approximate cubic capacity per hen of a multi-tier cage unit.  At the outset, Dr. Anderson noted that carbon dioxide can only be used in belt-battery cage installations to kill flocks.  Older-style high-rise houses are unsuitable since carbon dioxide sinks to the pit resulting in a high proportion of survivors especially in the upper tiers.

The studies conducted at NC State incorporated the use of an EEG instrument to determine brain activity during treatment, blood chemistry with an assay for corticosteroids to monitor levels of stress. Observations of behavior using standard evaluation of voluntary and involuntary activities was also used to assess the response of hens to heat and hypercapnia.

Studies included VSD alone; VSD with supplemental heat; VSD with a 30 percent carbon dioxide atmosphere and VSD with both heat and carbon dioxide.  Observations included time to death, core body temperature, air temperature and humidity within the chamber and bird behavior.

It was determined that all four treatments were effective within a 300-second timeframe.  VSD resulted in rapid cessation of brain function as determined by EEG analysis.  Hens subjected to VSD were effectively insensitive for 82 percent of the time between commencement of VSD and death.  Voluntary behaviors including pacing and head shaking were correlated to EEG readings.  There was no difference between the VSD plus heat and VSD plus carbon dioxide treatments.  It was concluded that the efficacy of VSD depends on ambient temperature which influences core body temperature. 

Extending the trials using chambers to a small room with 144 hens in two-tier cages confirmed the preliminary studies. This suggests that VSD with supplementary heat, with or without carbon dioxide will be a suitable method of killing caged flocks.

Suppling additional heat will be necessary if VSD is carried out during winter in Northern-tier states.  To achieve acceptable killing of the flock using carbon dioxide, a concentration of 30 percent is required.  This has been achieved under practical conditions with small flocks and specially designed equipment in an early 2016 demonstration in Canada. 

 Further investigations will be carried out, increasing the level of humidity in heated chambers and in small experimental units. Elevated humidity decreases the ability of a hen to lose heat by evaporative cooling from the respiratory tract. In conjunction with high ambient temperature this will increase core body temperature to a lethal level, thereby improving the efficiency of VSD.


“Question #3” on Massachusetts Ballot Passes by a Wide Margin

Nov 11, 2016


As expected, Question #3 on the Massachusetts ballot passed by more than a three to one margin on Tuesday. The wording of the Question was almost identical to Proposition #2 adopted in California in 2008.

The good citizens of the Bay State, both rich and poor will soon be paying the “Pacelle Tax” ranging from 50 cents to a dollar per dozen when the law takes effect. Since there is only one small farm with caged hens in the State the passage of the Question will not do much to improve welfare. Eggs introduced into Massachusetts will in all probability be sourced from cage-free flocks with a corresponding increase in wholesale cost plus retail markup to the consumer.


The HSUS was the major proponent of the ballot initiative and as in California, assumed the position that it could insert its fingers into the pockets of consumers to justify their purported interest in welfare while surreptitiously advocating a vegan agenda.

Appeals citing constitutional grounds to overturn the ballot decision will probably not be successful given court rulings relating to the California Proposition#2.


Minnesota Imposes Restrictions on Neonicotinoids

Nov 4, 2016


EGG-CITE has previously commented on the action taken in the EU to restrict the use of the neonicotinoid class of insecticides.  The justification for this action relates to the presumed impact on honeybee populations which are clearly declining or fluctuating in some areas of the world.

In an August 26th Executive Order, Governor May Dayton directed the Minnesota state Department of Agriculture to require pesticide applicators to specify and substantiate “verification of need.”


According to an article in September 5th 2016 edition of Chemical and Engineering News, environmental groups are pressing for legislation to severely restrict neonicotinoid insecticides applied as either a dust to crops or to coat seeds.

The justification for action against neonicotinoids lacks scientific rigor. This is evidenced by independent studies published in peer-reviewed journals confirming a lack of a direct cause and effect relationship between neonicotinoids and a decline in honeybee populations. At worst this class of insecticides may be synergistic with other etiologies of Colony Collapse Syndrome Potential causes of the problem include parasites, viral infections and management stress. In some areas where neonicotinoids are used extensively, honeybee populations have remained constant or have increased.

Banning compounds as a result of environmentalists agitating for their specific causes, has and will continue to be an ongoing issue. The intensity of lobbying may well be extended to existing compounds and drugs approved for specific application in agriculture and livestock production currently approved by regulatory agencies including the EPA and the FDA.


Do Trends in Agribusiness Favor GMO-Free Eggs?

Oct 28, 2016


During the past six months, the agricultural biotechnology industry has witnessed significant merger and acquisition activity.  DuPont and Dow Chemical Company are combining with a subsequent three-way split. Syngenta AG was purchased by China National Chemical Company earlier in the year. This past week the long-awaited purchase of Monsanto by Bayer was announced. 


These transactions will create fewer more powerful companies with complementary product lines comprising seeds and pesticides to provide synergy.  Against this presumed advancement, is the reality that there is an over-production of corn, soybeans, cotton and other agricultural commodities which has lowered prices both in the U.S. and in the international market. Effectively farmers have now become the victims of their increased efficiency and yields.

 The cost of seed has risen since the introduction of GMO cultivars.  Soybean seeds have doubled in price over a decade and corn has gained 63 percent during the same period. Increases in yield have not kept pace with escalation in seed costs. It is estimated that over the past ten years, soybean yield has increased by an average 4 percent and corn by 20 percent.

The disparity is due to a number of factors including the law of diminishing returns and climatic extremes including the drought of 2013. Resistance to glyphosate among significant species of weeds has also impacted cost of production using GMO seed, requiring alternative herbicides to sustain projected production in many areas. 

Farmers are questioning the costs required to combine GM seeds with compatible herbicides.  Depending on location including soil type and rainfall, some farmers have determined that it is more profitable to forgo yield but reduce the cost of production. They are sowing non-GMO seed and selectively applying fertilizer and herbicides especially in areas where pests are not a significant detractor from productivity. 

This trend may favor availability of non-GMO corn and soybeans at prices slightly above genetically modified ingredients but at a far lower price than USDA Certified Organic equivalents.

Providing that large-scale egg producers can contract with farmers to deliver certified non-GM corn and extruded non-GM soybeans it will be possible to produce non-GM fed, cage-free eggs which would sell at a premium to conventional cage-free eggs. This product category would certainly be cheaper than certified organic especially if proposed outside access rules are mandated, considered at this time to be an inevitability.

A new category of non-GM eggs could be produced from flocks housed in aviaries or on slatted floors but without outside access.  If the category were to be described as “non-GM grain fed”  synthetic methionine and lysine could be used to supplement diets.

What will be required is a concerted attempt by a producer group or consortium of large egg producing companies to promote the category as either a specialty egg or designated brand. The eggs from flocks fed non-GM grains would be even more competitive against current specialty eggs if other enrichments including DHA, lutein and vitamins are incorporated into diets, reflecting in enhanced nutrient value.

Clearly the U.S. egg industry should be aware of trends in row-crop agriculture and the reality that low prices for commodities may persist for as long as ten years, absent a major drought. Since more GM-free corn and soybeans will be available a category intermediate between certified organic and “specialty” could be created to the detriment of both lower and higher-priced products.

As Pasteur remarked “opportunity comes to the prepared mind.”



Oct 21, 2016

Bob Langert


Guest Commentary by Bob Langert

Bob Langert, retired from McDonald’s Corporation where he was a Vice President for Sustainability, involved in the supply chain and aspects of welfare and environmental issues reflecting on corporate responsibility, has established his consulting company “Mainstreaming Sustainability” and he edits “Green Biz”. Bob recently shared his perspective on our Industry at a national meeting. A summary of his talk is reproduced with his cooperation for the benefit of subscribers to EGG-CITE.  Bob can be contacted at

I am convinced that these tough times offer OPPORTUNITY, for those that get on their front foot, recognize and accept the Changing Consumer, the Mainstreaming of Sustainability, and want to change from defense to proactivity.

So based on my experience (the slings and arrows; the successes and mistakes), I offer a dozen tips to turn chaos into opportunity.

Of course, bred in speed at McDonald’s for 33 years, my tips are a dozen FAST ones.


1: Put into practice Anticipatory Issues Management

If you wait too long on an emerging issue, and let the media, politicians and lawyers get involved, you’ve lost. You are forced to do things that are costly and not scientifically based.

2:  Focus on the Smart Zone

There is plenty to work on that is in the “smart zone.”   You can’t just “comply” with laws anymore.  You need to do more.  Society expects it.

3:  Transform yourself into the mind of opposition, and respect them.

I was challenged early on by the animal rights movement. Was I apprehensive about how to handle the leaders of the animal rights movement? You bet.

You might find out you have more in common than you think. Why not meet? Why not learn from them? Whenever you get into a human relationship, the other side sees you as a human being, not as a cold corporate robot. Be sensitive to their side. You care about the same overarching issue. For example, I cared very much about good farm animal treatment.  Meeting the “enemy” does not meet you agree with them.  Show respect.

4.  Make NGOs your best friends.

I cut my teeth on sustainability pressure in the late 80s, when McDonald’s for the first time in its history was attacked and vilified — at the time, over packaging and waste.

Panic set in. McDonald’s was the lightning rod. We felt sorry for ourselves.

Sound familiar?

So, what’s the best way to deal with this kind of pressure, bullying and shaming campaigns? Sit back and take it? Hide? Play defense?

No! What I learned back has laid with me like concrete ever since:  Make best friends with the right partners.

Pick a credible partner, as McDonald’s did with the Environmental Defense Fund.  We went from villain to environmental leader. We even got an award from the White House.

5:  You HAVE to work with NGOS

NGOs are the sustainability thermometer for the consumer. It’s the NGOs that consumers trust, whether you like that or not. 

Fortunately, there are lots of good NGO choices.

I rated NGOs from 1-10, with 10 being extreme, and 1 being corporate friendly.  I wanted to work with the 5–7s — the NGOs that had credibility, integrity and independence but were open to market-based solutions and to helping companies succeed. 

6.  Your reputation is more about How vs. What you do

When a stakeholder judges your company, he or she will form an opinion of you as a leader, and your company overall, on your openness, honesty, and transparency.

Your reputation has much less to do with what you do than with how you do it.

It’s okay to make mistakes and show imperfections. The process of trying is what matters. It shows you care.

7:  Open up, and develop thick skin

Food and Ag companies are under a barrage of false and misleading views of where “sustainable food” should go.  It’s organic. Local.  Non-GMO.    It is so simplistic, SO WRONG.   But we sit back and let “them” dictate the agenda, and define what sustainable food is and isn’t.  

You can’t TELL your story anymore. I hear that phrase all the time:  “Tell our story more.”

No.  We need to SHARE our story.  We need to engage, get involved in the dialogue.  Accept the criticism, too.

8:  Transparency Builds Trust

Given the transparent world we live in, believe it or not, the idea of “getting caught doing good” is still prevalent.

Food companies need to do an about face.  Open up, radically.  Show them you have nothing to hide.   If you don’t like something on the front page of the NY Times, change it. 

We are only in the dawn of transparency.  Facebook, the IPhone, and Twitter are only 10 years old!


Cargill Takes Lead in Non-GMO Ingredients

Oct 14, 2016


Recognizing the growth rate for food products marketed as non-GMO content, Cargill has introduced three new items for food manufacturers. These include Clear Valley® high oleic sunflower oil, Clear Valley® expeller-press high oleic sunflower oil and IngraVita™ high oleic sunflower oil.  Packaged Facts estimates that in 2016, non-GMO foods will attain a sales value of $19 billion up from $350 million in 2010.


Mike Wagner, Managing Director for Cargill Starches and Sweeteners, North America said “Consumer demand for non-GMO food and beverages is growing, and Cargill is responding”.  He added “We’re delighted to work with Non-GMO Project, the leading verifier of non-GMO products in the United States.”

Megan Westgate, Executive Director and founder of Non-GMO Project stated “Our mission is to preserve and build sources of non-GMO products, educate consumers, and provide verified non-GMO choices.”

It is noted that USDA-AMS has been authorized to establish a Federal program to certify non-GMO products paralleling the commercial activities of the Non-GMO Project.

Scientific studies have shown that there is no difference in either nutrition or safety between non-GMO and GMO-derived ingredients.  This said, there is consumer resistance among high-income demographics against GM ingredients, generating a premium for non-GMO products.

It is a matter of record that 90 percent of corn and soybeans grown in the U.S. are of GM origin.  High costs for non-GMO ingredients are associated more with segregation and traceability than with cultivation.  Costs for GM crops are higher with respect to seed but offset by increased yields and lower use of pesticides and herbicides, depending on cultivar.


Conversion to Cage-Free – Time for a Reality Check

Oct 14, 2016


Now that the approximately 160 customers representing the membership of the FMI, NCCR, GMA, NRA and independents have committed to a transition to cage-free egg production, the U.S. egg production industry is faced with the practical and financial realities of replacing conventional cages over a ten-year period.

EGG-CITE has previously commented on the magnitude of the cost which may amount to more than $10 billion to rehouse more than 200  million hens.


Chad Gregory, president and CEO of United Egg Producers has taken the initiative to bring together the parties involved to review how the transition can be achieved with minimal disruption, wasted effort and expense.  We have already had a false start with preliminary evaluation and then rejection of enriched colony modules. The few U.S. adopters and virtually all EU producers who elected for the system to replace conventional cages soon found their investments were obsolete before their newly-purchased systems were depreciated.  Obviously we do not wish to be in the same position in terms of aviaries and alternative floor systems. Accordingly the industry needs guidance, standards and assurances from customers, many of whom have no idea of the practical or financial implications of their market-driven demands.

On September 21st a meeting took place with the Secretary of Agriculture, Tom Vilsack together with a range of stakeholders including producers, welfare organizations and customers represented by the GMA, FMI, and NRA to review the current situation and future action.

Decisions relating to welfare aspects of housing and equipment are reviewed by the UEP Scientific Committee and their recommendations are then referred to the Producer Committee concerned with welfare.  A series of exchanges have taken place extending from late June onwards. It is expected that by the end of October, there will be finality on the following considerations:-

  • Definition of descriptive terms: These include “cage-free”, “floor systems”, “outside access”, “pasture housed” and possibly other label descriptors.
  • The acceptance of “convertible aviary modules”:  It is generally accepted that it is necessary to confine replacement pullets to modules for a period of up to three weeks after transfer so that they can accommodate to the system, find feed and water and explore nest areas.  Thereafter flocks can be released to move around the entire house with access to litter and to transit among tiers using perches.  It is essential that all stakeholders including producers, customers and the two principal welfare organizations, the American Humane Association and Humane Farm Animal Care agree on standards for equipment and management procedures.

United Egg Producers representing over 95 percent of the egg production industry is taking the lead in motivating the various organizations and the USDA-Agriculture Marketing Service to achieve consistency and a common understanding of the issues. Obviously a solid foundation will be required if producers are to commit large sums of money to new facilities or to modify existing housing, representing an expenditure of up to $40 per hen on average, accepting 2016 values. 

Given the prospect of acceptable standards for design of housing and installations and their operation, the industry can progress to a rational program of planned conversion.  It goes without saying that reluctance to commit to expenditure is currently complicated by the price for all categories of eggs which have been sold below production cost for at least the past seven months and the situation is likely to continue through late fall.


Shortage of Agricultural Workers Impacting Seasonal Crop Production

Oct 7, 2016

A CNN Money article by Octavio Blanco posted on September 30th claims that 50 percent of U.S. farmworkers are undocumented immigrants.  From close involvement in the industry it is evident that workers employed by integrators in processing plant, company-owned poultry houses and packing facilities are invariably subject to appropriate scrutiny including E-Verify to determine that they are legally entitled to work. 

The problem highlighted relates to workers employed in migratory and seasonal agriculture including picking of strawberries, tomatoes and melons, especially in California.  Due to greater scrutiny by ICE, wages have increased for documented workers and are apparently in excess of the $10 per hour minimum wage in California.  To maintain productivity and to employ adequately staffed work crews, farmers frequently provide overtime which is now mandated, in addition to shade breaks every hour and other benefits.

Since labor is becoming a rate-limiting factor in production of fruit and vegetables, Departments of Agricultural Engineering at Land Grant colleges are developing machinery to relieve financial pressure on farmers who must compete with less expensive imported fruit and produce.

The poultry industry has advanced with mechanical feeding, egg collection and even harvesting of broilers applying advanced technology. Sophisticated installations in egg packing and meat plants ensure a high level of productivity, displacing manual labor.

The disinclination of unemployed U.S. citizens to undertake agricultural work is difficult to understand.  Perhaps social benefits and entitlements and a concentration of unemployed in urban areas are a disincentive. Should we revert to programs introduced during the Great Depression such as the NRA to reduce unemployment and contribute to national productivity at the farm level?  Are there alternatives to reliance on neighboring countries to provide workers to produce labor-intensive food?