FDA Now Considers Cattle Feeding Operation Responsible for Contamination of Yuma, AZ. Lettuce


As reported widely in media, romaine lettuce was the vehicle of infection for at least 210 cases of E.coli O157:H7 (STEC) infection resulting in five fatalities and extending over 36 states. The outbreak was declared over on June 28th. This was mainly due to the fact that the harvest season in the Yuma Valley ceased a few weeks earlier and lettuce in the food chain had either been consumed or destroyed.

Concurrent with the declaration that the outbreak was over, the FDA isolated the outbreak pathogen from irrigation water sprayed on the fields. This revelation was months after the initial cases were detected and recognized as a discrete outbreak through the FoodNet database system.

The latest announcement implicates a large Concentrated Animal Feeding Operation (CAFO) located near the area where romaine lettuce was cultivated as the source of contaminated irrigation water. This should not come as a surprise since E.coli O157:H7 has adapted to the intestinal tract of ruminants, especially when fed diets low in roughage such as on zero-grazing dairy farms and feed lots. Previous outbreaks of STEC infection attributed to cattle include an outbreak with spinach as the vehicle of infection during 2006 in California. Aerosolized fecal material from cattle wafting into apple orchards was responsible for an extensive outbreak of E.coli O157 in children consuming non-pasteurized apple juice in 1999. Ground beef derived from culled dairy cattle may be contaminated with E.coli O157 requiring thorough cooking to inactivate the pathogen.

The FDA is continuing to investigate the outbreak. The slow pace of the study and failure to identify the epidemiologic factors relates to the lack of suitably trained investigators affiliated to the FDA. The Centers for Disease Control and Prevention is a suitably equipped agency to determine the source of food-borne disease outbreaks given their resources and the training of personnel. Split responsibilities among government agencies with fragmented jurisdiction over aspects of food production and processing is a justification for establishing a separate stand-alone food safety agency.


Potential for Shell Egg Exports to South Africa Limited


According to a GAIN Report dated July 26th 2018, South Africa imported 50 tons of shell eggs valued at $74,000 from Brazil during the first five months of this year.  Importation was necessitated by the loss of approximately 7 percent of the nation’s flock in mid- to late 2017 following exposure to H5N8 avian influenza.  The resulting decline in availability of eggs was responsible for an increase in retail prices which at present are in the region of $2.20 per dozen about 16 percent above 2017 prices prior to the HPAI outbreak. The RSA inflation rate is currently at five percent.

South Africa has declared the U.S. to be eligible to export shell eggs but the potential volume to be supplied will be understandably small and in competition with Brazil and the E.U.


As with South Korea, once flocks are repopulated, supply will match domestic demand. Based on previous experience availability will overshoot demand given the large number of younger flocks coming into production.


Quantum Foods a major egg producer in South Africa reported an increase in operating profit of 470 percent to $20 million for the first half of fiscal 2018 ending March 31.  Although the company lost 240,000 hens in the Western Cape the rise in egg prices more than compensated for reduced flock size.  The egg production component of the agribusiness company contributed 65 percent to total company profit amounting to $9 million.  A sharp reduction in the cost of ingredients following the severe drought in 2016 also contributed to improved margins enjoyed by both the broiler and egg segments of the poultry industry in the Republic of South Africa.



FDA Reviewing Standards of Food Identity


Based on the proliferation of vegetable-based milk substitutes, organizations representing the dairy industry have petitioned the FDA to establish standards restricting the “milk” designation to products derived from udders. Concern over nomenclature of plant-based foods involves accurate information for consumers.


Dr. Scott Gottlieb, Commissioner of the FDA commented, “The information provided through food labeling must be truthful and not be misleading. The consumer’s choice must be based on this information and can have important impacts on health.”


The FDA arranged a meeting on nutrition innovations strategy in mid-July to review the topic of food identity.  It is intended to initiate a public discussion on how consumers respond to product identity including animal and farm-derived foods.


Gottlieb noted, “We are actively looking at how we have been enforcing the Food, Drug & Cosmetic Act with respect to food names and our own standards of identity for milk and what it means when milk is qualified with words such as almond or soy.”  Apparently, there are 300 separate standards in FDA regulations.  Gottlieb commented that standards of identity can restrain industry in developing and marketing of products.  Accordingly, the FDA will solicit input from stakeholders to be incorporated in the eventual regulations relating to food identity.


Although dairy producer are most involved with milk substitutes, it is evident that the issue of egg identity will have to be addressed given the introduction of plant-based synthetic egg products.  Although formulated to demonstrate similar organoleptic attributes to eggs, the nutritional quality is obviously inferior to natural eggs. Consumers should be made aware of the deficiencies of “scrambles” made from mung beans.



CDC Implicates Backyard Flocks in Salmonella Outbreaks


CDC issued an outbreak advisory on July 23rd confirming ongoing outbreaks of salmonellosis attributed to contact with backyard chickens and ducks. The epidemiologic significance of backyard chickens has been clearly established with regard to salmonellosis acquired in the home setting other than from contaminated food. Effectively backyard chickens have replaced pet turtles as the major source of salmonellosis for children which pertained prior to the 1975 FDA ban on interstate shipment.


Since June 21st, database systems including FoodNet have recorded 112 cases of salmonellosis in 44 states requiring 34 hospitalizations.  Salmonella isolates included S. Seftenberg, S. Mondevideo, S. Infantis, S. Enteritidis, S. Indiana and S. Litchfield. There is obvious concern that whole genome sequencing demonstrated genes coding for drug resistance against a wide range of commonly used antibiotics in 22 isolates assayed.


One-hundred of 138 patients reported contact with chicks or ducklings in the week before onset of illness. It is significant that a quarter of the patients comprised children under 5 years of age Chicks and in a few instances ducklings are presumed to be the vehicles of infection and were purchased from feed supply stores, small hatcheries or were supplied by friends. 


 EGG-NEWS takes extreme exception to the fatuous comments by self-styled “chicken doctor” Rinder Myers of Tulsa, OK.  A comment that the “risks of backyard chickens are quite minimal” are refuted by data.  Myers is entitled to her opinions but not to her facts.  Denoting an absence of knowledge concerning basic microbiology and epidemiology Myers doubled down noting, “Lack of sunlight, lack of ventilation and cleanliness are huge risks for Salmonella and you have these things in the factory setting.”


The commercial U.S. egg-production industry operates in accordance with the National Poultry Improvement Program concerning prevention of vertically transmitted Salmonella infection.  In addition the industry conforms to the 2010 FDA Final Rule on Salmonella Prevention and operates in accordance with state egg quality assurance programs and UEP and company standard operating procedures where applicable. In most cases these requirements are stricter than federal and state regulations.


There has not been a case of Salmonella Enteritidis associated with commercially produced and processed eggs since 2010.  A recent outbreak of Salmonella Braenderup attributed to a specific egg complex involved 57 cases over six months notwithstanding the fact that the alleged source of infection distributed 2.4 million eggs daily to a population exceeding 25 million consumers. This represents an infinitesimally minute attack rate.  In contrast, outbreaks of salmonellosis have been attributed to small-scale farms operating under the FDA requirement which applies to flocks over 3,000 hens.


It is regrettable that media including station KTUL-TV offer a megaphone to people with a vested interest in promoting backyard chickens to disseminate misinformation.  KTUL and other mainstream media would be well advised to consult with state epidemiologists and local public health professionals for commentary on diseases transmitted from livestock to humans and on foodborne infections before allowing ill-informed or at worse venal spokespersons to air blatantly false opinions.


2018 Animal Rights National Conference


The annual gathering of opponents to intensive livestock production and dedicated to promoting a vegan lifestyle gathered in Los Angeles at the end of June. Expanding on previous years, the four-day event included 175 speaker on 80 panels bringing together diverse concepts including activism, animal rights, diversity, and social justice.

It would take a psychologist to understand the desperate motivations for the extreme views expressed by speaker and participants. While some aspects including environmental concerns may be valid, comparing reproductive rights of women with those of hens is blatantly outlandish. Expressions of zealotry included advocating illegal action to liberate animals. This was exemplified in the post-conference intrusion onto a poultry unit in Petaluma, CA which required intervention by peace officers.

Conference themes included:

  • Exploitation of animals for food, research and entertainment

  • Developing future leaders in the animal rights movement

  • Opportunities for cooperation and synergy among animal rights movements which tend to be fragmented

Quotes from the various panel discussions exemplify the sentiments of participants at the conference:

  • “Hens can never have reproductive freedom”

  • “They never stop loving their babies”

  • “A significant distinction between what may be regarded as extremists and the general public is the humanization of animals. Anthropomorphism is a consistent feature of adherent animal liberation.”

  • “There is no such things as humane slaughter” and “you cannot humanely kill someone that doesn’t want to die”

  • “Owning another human being is an act of violence and

  • “All animals are equal” (Obviously this speaker is not acquainted with George Orwell!)

  • “We need to take care of all of the victims of animal agriculture”

It is evident that a minority estimated to be less than three percent of the U.S. population is either vegan or pretending to eliminate animal products from their diets. Their motivation depends on a misplaced concept of self-health, environmental concerns and animal rights. The more militant members of the animal rights movement who perpetrate farm intrusions and disruption of agriculture with no regard to the law and the rights of property owners can only be restrained by farm security and a recourse to law.

A concern emanating from the conference is the proselytizing of youth and promoting anti-meat concepts in K-12 education. Unfortunately advocates of vegan diets appear to have the megaphone. Perhaps if the organizations representing the animal production industries really understood the disparate motivations of their opponents they could craft appropriate non-scientific but logical counter-arguments acceptable to receptive consumers. All of what is posted on websites by the NCC, UEP and NTF is factual, logical and informative. Unfortunately it lacks the emotional impact of the postings by organizations opposed to intensive livestock production. Images speak words—we need less appeal to the brain and more to the solar plexus.


Trade Wars Now a Reality


The U.S. farming community awoke on Friday morning July 7th to the reality of a trade war.  Threatened tariffs on imported Chinese equipment including auto parts and medical devices valued at $34 billion came into effect at midnight triggering retaliatory tariffs imposed by China.  These amount to 500 categories of U.S. products. Additional tariffs are proposed on as much as $500 billion in products shipped by China to the U.S. in an ongoing reciprocal series of countermeasures.


Soybean and hog producers will be the most affected in the short term.  China imported U.S. soybeans valued at $14 billion in 2017.  Imposition of a 25 percent duty following tariffs on steel and aluminum from China in April effectively eliminated trade in soybeans now dominated by Brazil.  Hog farmers will be excluded from their market in China based on a price differential represented by newly imposed tariffs, including VAT will represent an 81 percent ad valorem boost in price.  The implications for companies exporting hogs to China is self-evident.  It is estimated that currently one out of every four U.S. hogs is exported to China.  A prominent family-owned integrator in the Midwest estimates that the company will lose $100 million on 5.5 million hogs spread across ten states.


To add to the woes of the hog industry, Mexico has imposed a 10 percent retaliatory tariff on chilled and frozen pork with a 20 percent rate effective Friday July 6.


Secretary of Agriculture Dr. Sonny Perdue has commented on “a plan to help protect farmers and agriculture businesses.”  EGG-NEWS has previously noted that any compensatory payment to farmers will increase the national debt and will engender opposition from Congress.



It is hoped that the present situation is only extreme brinkmanship and that China and the U.S. will recognize the folly of “assured mutual destruction” and will negotiate a satisfactory resolution to the outstanding problems of an imbalance in trade and misappropriation of intellectual property.  Failure to restore free trade will have both social and political implications for the U.S. and especially for the agricultural sector of the economy.


Jury Rules Against Smithfield Farms in North Carolina Hog-Nuisance Case


In the second jury trial filed against Smithfield Foods, a jury in Raleigh, Wake County ruled in favor of plaintiffs on Friday June 29th. The case involved a bellwether couple living in the vicinity of a 4,700 hog unit contracted to Smithfield Foods.  At issue is the apparent odor, alleged contamination of ground water and deprivation of property rights as a result of operating a lagoon and pasture-spray system of manure disposal.  Although the jury awarded compensatory and punitive damages, state law will restrict compensation to $250,000 per plaintiff and the $25 million total award will probably be reduced to $650,000.


The current case in Duplin County follows a previous verdict against Smithfield in a U.S. District Court in which ten neighbors were awarded $51 million which was subsequently reduced to $3 million. This case was regarded as the best opportunity for Smithfield to mount a defense since the bellwether plaintiffs moved to the area after the hog farm commenced operation.


The Duke Environmental Law and Policy Clinic at Duke University has emerged as the champion of homeowners in their opposition to hog farms using lagoon storage and spray disposal of manure.  North Carolina has 9 million hogs concentrated in the eastern segment of the state located among 2,000 farms contracted to a few integrators.


Alternative technology including biodigestors which could displace lagoons and are considered to be too expensive to install and operate.  Smithfield Foods, a subsidiary of the WH Group of China has indicated that should hog production become uneconomical as a result of lawsuits they will withdraw from North Carolina. The North Carolina Pork Council commented that the two verdicts would have “unforeseen economic consequences for our farmers, the state’s pork industry and North Carolina agriculture.”


During the first week of June, the North Carolina legislature overrode a veto by Governor Roy Cooper allowing to stand a law limiting the ability of residents to join a class action lawsuit against farmers and integrators as a result of nuisance.


The National Pork Producers Council president, Jim Heimerl stated, “We are deeply troubled by the decision against a farm that has operated responsibly and in compliance with state law since 1985 and maintains the highest standards of environmental and community stewardship.”


The two cases have established precedents which will result in a spate of claims of doubtful validity against operators of CAFOs. These may well include egg producers especially in areas where suburban encroachment on farms occurs.


Administration Anticipates Agricultural Deal With Mexico – Realism or Optimism?


The USAPEEC MondayLine posted on June 29th quoted Ted McKinney USDA Undersecretary for Trade and Agriculture as opining “I think we’re very near with Mexico. There are some things we’ve got to work through, but I think we’re very near.” He was referring to an agreement to revise NAFTA, generally considered to be dead, given reciprocal retaliatory action by both Mexico and Canada following threatened and imposed U.S. tariffs on products emanating from both nations.

The president of the Mexican Association of Poultry Producers (UNA) has called for retaliatory tariffs on U.S. poultry products imported into Mexico. Cesar Quesada of UNA and also the Mexican Agricultural Council are soliciting support from the Government of Mexico to facilitate expansion requiring investment in the poultry industry. The UNA action is basically a request for protection.

As with all demands by producers over tariffs, the concern of any government is to balance the social, political and economic benefits of inexpensive imports relative to the contribution from protected poultry industries. The situation with respect to India, China and the Republic of South Africa is to favor local production to support employment. In contrast, governments tend to relax protection prior to elections or with prevailing high inflation or an economic downturn. Waivers are granted over import restrictions to support an inexpensive “chicken in every pot” policy, if only as a temporary expedient to placate supporters of the ruling party.

The optimism expressed by the USDA with regard to Mexico may be premature given attitudes expressed by the Administration and future intransigence in negotiations under an Obrador Presidency.


Citizens Petition To Require FDA to Designate Eggs as “Healthy”


Jesse Laflamme, CEO of Pete and Gerry’s Organics is to be complimented on his initiative to file a citizens petition with the FDA to amend the definition of “healthy”. The FDA considers that eggs are too high in total and saturated fat and cholesterol to be designated “healthy” by food processors. In contrast, the U.S. Department of Agriculture and the Department of Health and Human Services consider eggs to be a part of a “healthy diet”.

Current knowledge of nutrition has proven that dietary cholesterol does not raise serum cholesterol to any appreciable degree in consumers without a genetic predisposition to hypercholesterolemia. The petition filed by Jesse Laflamme emphasizes the nutritional value of eggs and the contribution of Vitamin D and choline. Nutritionally enriched eggs achieved through dietary supplementation have even higher nutrient values. This is the basis of the success of Eggland’s Best LLC, a producer cooperative which dominates the specialty egg segment.

The role of eggs in diets is now accepted with companies such as Weight Watchers International, Inc., adding eggs to the range of foods members can consume without the need for dietary tracking. This concession is based on the nutrient value of eggs and a contribution to satiety.

In a statement, the FDA stated that the definition of healthy is undergoing review and the Agency is considering “a large body of information and analyses”. The FDA may be out of step with current knowledge of nutrition and is apparently still under the influence of the studies conducted in the 1970s and 1980s which demonized fat. Subsequent investigations have revealed that many of the trials were directly supported by associations and companies marketing sugar and sugar-containing products introducing bias and distortion.

The difference in approach between the FDA and federal departments with respect to eggs is further evidence of incoordination and suggests that consumers would be better served by a single Food Agency staffed by experts with a commitment to safety, quality and nutrition.


ICE Raid On Plant Nursery In Ohio


The U.S. Immigration and Customs Enforcement Agency (ICE) recently carried out a raid on a large flower and garden center in Sandusky, OH. The current policy of strict enforcement of immigration regulations is justified in law and is politically acceptable to the Administration and supporters.

The problem of illegal immigration and the arrest-and-deport approach is analogous to trying to maintain the level in a leaky bucket by adding more water. All the time there is a demand for labor and a ready supply of willing workers, simple economics will perpetuate a system of illegal employment.

It is high time that the Government recognizes the realities including a disinclination by U.S. citizens with deficient skills and no prospects in cities to undertake agricultural employment. It is absolutely necessary for the proposed temporary H visas to be issued to foreign agricultural workers under the control of the Department of Agriculture.

Although many large egg producers have stabilized their labor by employing citizens and legal alien workers, there are many operations not in compliance and are vulnerable to raids and disruption. Employers must transition to the E-Verify system. This will preclude the problem of fraudulent documents in circulation.

The use of employment agents who round up illegal workers is strongly condemned and should cease. These coyotes function at the interface between a willing workforce and potential employers under pressure to fill labor complements.

In reviewing farm operations and in conversation with owners and managers, it is evident that there is a disinclination for native-born citizens to demonstrate required reliability, diligence and responsibility. Drug use and alcohol abuse are responsible for absences from work, failure to follow biosecurity procedures and operational procedures. The problem is especially evident when a farming operation is in proximity to a large industrial enterprise that can afford to pay higher wages for workers who are prepared to be productive, abstain from substance abuse and conform to work routines.

Building border walls, stricter enforcement of immigration laws and restricting social benefits for unemployed citizens are not practical solutions to a long-standing problem. U.S. agriculture, and specifically, the poultry industry require workers available and willing from our southern neighbor. The Administration and Congress should face reality and provide requisite visas to maintain the efficiency of operations. This implies that acceptable wage rates will be offered including appropriate housing, health and other benefits. In the short term, all producers should transition to legal compliance and conform to the DHS rules incorporating E-Verify.


South African Manufacturer Demanding Listeria Standard


The dust has not settled on the extensive outbreak of listeriosis in South Africa claiming close to 1,100 victims with 200 fatalities. The outbreak was traced back to a plant operated by leading food manufacturer Tiger Brands with a sausage product termed “polony” as the vehicle of infection.


Currently South Africa operates on a standard of 100 cfu per 100 grams in contrast to the U.S. and the E.U. which have imposed a zero tolerance for Listeria monocytogenes in food products and especially ready-to-eat items.


According to the CEO of Tiger Brands, Lawrence MacDougall, the Government of South Africa should be responsible for establishing a standard, in accordance with the formation of a food safety council. This self-exculpatory attempt has the apparent intent of absolving his Company of an independent and meaningful response. An apology would seem to be more in order. This will presumably be left to his successor.


Following outbreaks of listeriosis traced back to their plants, Maple Leaf Foods in Canada, Blue Bell Creamery and the Rocky Ford Cantaloupe Growers Association immediately announced conformity to the zero tolerance standard and established preventive measures based on HACCP principles.


MacDougall stated that, “Enterpise has not seen anything that would indicate negligence.”  Although conceding that the implicated Listeria monocytogenes ST6 strain was present in both the Polokwane plant and in Enterprise products. Lawyers will have no problem invoking the principle of res ipsa loquitor. Wake up Mr. MacDougall, take your head out of the sand or wherever it might be and acknowledge responsibility and commit to following world trends. 


Ready-to-eat meats especially when derived from off-cuts and low-value pork, beef and chicken ingredients are highly susceptible to contamination with Listeria. Plants producing deli cuts and ready-to-eat meats have comprehensive programs to ensure that machinery and work surfaces are thoroughly decontaminated with routine disassembly. HACCP programs incorporate a structured program of monitoring.  Anything less will result in a reoccurrence of infection.In the absence of effective control and detection programs, Tiger Brands operated the plant negligently and will be responsible for both criminal and civil penalties.


As with Chipotle Mexican Grill in the 2016 and 2017 multiple foodborne outbreaks, causation involves both incompetent top management and a lack of knowledge at the middle levels of the company involved in production and quality control.  Failure to run a food company in accordance with international standards and demonstrating willful unconcern for the operational procedures applied by companies in the E.U. and North America effectively represents negligence.


Tiger Brands does not have to conduct a “root cause analysis of the outbreak” as suggested by the GM. Enterprise should appoint knowledgeable QC personnel and the Company should just knuckle down and follow the example of successful companies producing ready-to-eat foods.


Rebuttal of the Food Safety News Posting on Salmonellosis


The May 26th edition of Food Safety News issued by the law firm of Attorney Bill Marler includes a commentary by Roy Costa.  A practicing sanitarian and professional expert witness, Costa is apparently out of his depth in commenting on the epidemiology of foodborne Salmonella infections. The topic is a lot more intellectually challenging than counting cockroaches and rodent droppings under the sinks of restaurants. His article denotes a non-objective bias against commercial egg production exemplified by his opening sentence, “The disgusting truth about industrial egg production is it stinks”.


The article contains numerous inaccuracies and misconceptions in relation to the recent case of Salmonella Braenderup infection among consumers involving 35 diagnosed cases over a three month period. The cluster of cases has been attributed by the FDA correctly or otherwise to a North Carolina complex holding three million hens. 


Costa should differentiate between vertically transmitted egg-borne infections such as SE and non-group D Salmonella serotypes which have an entirely different epidemiology. It is important at the outset to recognize that there is no epidemiologic commonality between the 2010 outbreak of Salmonella Enteritidis (SE) and the 2018 case involving Salmonella Braenderup. In the 2010 SE outbreak approximately 2,000 cases were diagnosed within a two month period and the incidence rate declined precipitously within a week of the mandatory recall. The Iowa flocks in question had at least a five-year history of infection with SE, a Group-D serotype known to be vertically transmitted from the reproductive tract of hens to their eggs.  The outbreak was probably amplified by improper handling of product including failure to maintain storage temperatures below 45F. A second possible contributory factor was extended storage suggested by evidence of illegal misstatement of use-by dates for both packed product and graded-egg and nest-run sales.  A combination of prolonged storage and thermal abuse will increase the quantum of infection transmitted vertically from the hen to the consumer. A proportion of eggs may have only 102 CFU per egg at the time of lay but proliferating to 108 CFU within ten days under suboptimal conditions of storage.


In the case of the Salmonella Braenderup trace-back study, there is some question as to the source of the pathogen among specific cases which were apparently related by whole genome sequence assays performed by the Food and Drug Administration.  Given the initial laboratory findings by the FDA, and a site visit by FDA inspectors, the company concerned elected to withdraw shell eggs from the market, initially dumping 2.4 million eggs each day in landfills. It is understood that more recently eggs are transported to a USDA-FSIS approved and inspected plant for breaking and pasteurization.


Costa apparently believes or implies that Salmonella infection originates from rodents and flies.  This is totally incorrect.  In the case of Salmonella Enteritidis, the infection is vertically transmitted from parent stock to commercial progeny.  Admittedly mice are susceptible to SE and the survivors become carriers and can disseminate SE infection among houses on a complex but they are not intrinsically responsible for introduction of infection.  Mice on a farm with flocks shown to be free of SE will not introduce infection and cannot influence the prevalence rate of the pathogen in eggs irrespective of the level of rodent infestation. If the flock is free of infection neither mice nor flies will have any role in dissemination of SE. In the case of the North Carolina complex the FDA has not released any data relating to the prevalence of Salmonella Braenderup in flocks, environmental samples from houses and the packing plant, presence of the pathogen in reproductive tracts of hens of various ages, egg pools or recovery from rodents, flies or manure or from workers on the farm.


Since the late 1990’s, breeder flocks at the Great-grandparent, Grandparent and Parent levels have been free of SE infection with primary breeders and multipliers conforming to the statutory  NPIP Salmonella Enteritidis prevention and detection program. Rarely “breaks” occur but these are detected in parent stock by repetitive and routine environmental drag-swab litter assays usually at three-week intervals preventing delivery of infected chicks. At the commercial level, consignments of day-old pullets are assayed by examination of chick-box papers collected at the time of delivery. 


There is little known about the epidemiology of Salmonella Braenderup in livestock and poultry.  This pathogen is not generally regarded as associated with eggs and previous limited outbreaks documented in the literature have been attributed to contaminated meat pies and fresh produce.  While investigations are in progress any comments as to the origin of Salmonella Braenderup and possible dissemination among flocks on the implicated complex are speculative.  It is possible that the infection could have been introduced through contaminated animal by-product meal if this ingredient was in fact incorporated into diets fed to the hens or it the pathogen may have been tracked on to the complex through deficiencies in structural or operational biosecurity involving defective decontamination of personnel, vehicles or equipment.


Costa is reminded of the ongoing FDA Final Rule on the Prevention of Salmonella and the numerous state EQAP programs and individual company initiatives to prevent and detect SE involving biosecurity, vaccination and monitoring which have proven to be decidedly effective.


There have been no documented cases of egg-borne SE attributed to a farm complying with the FDA program or an industry or state EQAP since the 2010 outbreak.


Including the implicated company alleged to be responsible for the 2018 Salmonella Braenderup cases and the extensive SE outbreak in 2010 in the same sentence is a disservice to breeders and commercial egg producers.  The limited outbreak of Salmonella Braenderup does not necessarily indicate a “failure of the food safety system”. In contradistinction the diagnoses among consumers serve as a confirmation of the sensitivity of data-based detection systems introduced by the CDC including FoodNet and PulseNet (now using whole genome sequencing). It is an achievement to detect an outbreak of 53 cases in a multi-state population of 100 million at risk over a period of three months.


 It is hoped that if Roy Costa is to serve as an expert witness in any action brought by his Client, Marler Clark, that he should at least become familiar with the epidemiology of vertically transmitted Salmonella Group D serotypes and the obvious distinction in transmission and detection of Group B and C Salmonella serotypes.  It would behoove him before submitting to a deposition to be more familiar with aspects of commercial production, industry standards and preventive practices employed. Above all if he is to serve as an expert in relation to a disease outbreak he should refrain from broad generalizations which demonize an industry and generate concern among consumers. The U.S. egg production industry with 315 million hens is responsible for producing a wholesome, nutritious and inexpensive food product.


Food Safety News is generally a factual and informational web-si

Transmission and Survival of Salmonella Oranienburg in Hens


Following an egg-borne outbreak of Salmonella Oranienburg (SO) in Midwest states in 2015, researchers at the U.S. FDA Center for Food Safety and Applied Nutrition conducted trials to ascertain whether the pathogen could be vertically transmitted through consuming table eggs.*


Twenty-eight week old laying hens were challenged with an oral dose of SO ranging from 107 to 109 CFU and were evaluated over the subsequent four weeks.


Although S. Oranienburg was isolated from spleen, liver and the reproductive tract, vertical transmission was a rare observation.  The immune system appeared to inactivate infection after four weeks.


The authors concluded that infection with Salmonella Oranienburg did not result in contamination of eggs by the vertical route and that colonization of the ovary and oviduct was of short duration.  Limited survival but not proliferation of the organism in eggs stored at 42F to 46F for weeks is expected.


As with studies conducted at the USDA-ARS laboratory in Athens, GA high levels of challenge were used.  Under practical conditions, hens acquiring infection from fomites including mouse droppings in feed would probably ingest 101 to 102 organisms.  Salmonella Oranienburg is a serotype C1 and it is doubtful whether S. Typhimurium mutant vaccine would provide protection.  It is presumed that the hens used in the FDA study were not vaccinated.


It can be expected that currently the FDA is repeating the evaluation with S. Braendrup isolated from a North Carolina farm and apparently responsible for 35 cases of salmonellosis associated with egg consumption.  Irrespective of the potential vertical transmission, there is no accepted eradication or NPIP Certification program at the breeder level as with Salmonella Enteritidis. 


Obviously effective biosecurity procedures, inclusion of acidifiers in feed where appropriate, feeding all-vegetable diets and rigorous suppression of flies and rodents are appropriate preventive measures. Given that the U.S. industry does not use antibiotics routinely in rearing or in laying flock, the possibility of inducing drug resistance is extremely remote.


It is presumed that primary breeders are actively monitoring for the presence of Salmonella, and feeding pasteurized diets to GGP and GP level breeders if not to parents. Breeders and multipliers apply strict preventive measures to interdict exposure to Salmonella which could result in intestinal colonization.


*Babu, U.S. et al.(2018) In vivo and in vitro Evaluation of Tissue Colonization and Survival Capacity of Salmonella Oranienburg in Laying Hens. Poultry Science May 25: 1-6 (doi.org/10.3382/ps/pey189)


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