National Egg Farmers Suggests Improvements in Egg Safety Rule

Dr. Scott Gottleib, Commissioner

U.S. Food and Drug Administration

10903 New Hampshire Avenue

Silver Spring, MD  20993


Dear Commissioner:


We read with interest the food safety concerns with eggs linked to Salmonella expressed on October 4th by Rep. Rosa DeLauro (D-CT). Of particular note was Rep. DeLauro question for FDA to suggest improvements to strengthen the food safety. The National Egg Farmers, comprised of approximately 200 egg farmers producing more than 10 billion eggs anuually, offers these suggestions to expand the areas for testing of Salmonella in the chain of eggs from breeders to pullets, to eggs for consumers. Every Salmonella outbreak linked to eggs publically harms the reputation all egg farmers in their programs of providing a safe, wholesome egg to their consumers.


On July 9, 2009 FDA published its final rule establishing the regulation (21 CFR part 118) entitled Prevention of Salmonella Enteritids in Shell Eggs During Production, Transportation, and Storage (74 FR 33030) [“the egg rule”].  This regulation in part 118 requires egg farmers to implement measures to prevent Salmonella from contaminating eggs on the farm and from further growth during storage and transportation, and requires these farmers to maintain records concerning their compliance with the rule and register with FDA.  The measures include standards to control risks associated with pests, rodents, and testing, cleaning, and refrigeration provisions to prevent Salmonella.


Expanding the Egg Rule: The Center for Disease Control and Prevention has repeatedly issued warnings of Salmonella associated with baby chicks. How did those baby chicks become infected? (https://www.cdc.gov/features/salmonellapoultry/index.html)

The Egg Rule acknowledges trans-ovarian transmission from the breeder to the chick, although the mechanism is still not well understood. Hens may have intermittent transmission of Salmonella throughout their life cycle.



The current regulation requires that chicks are procured from SE-monitored breeder flocks that meet the National Poultry Improvement Plan's standards for “U.S. S. Enteritidis Clean” status (9 CFR 145.23(d)) or an equivalent standard. This monitoring does not include testing the macerated male chicks destroyed at the hatchery. If hens intermittently shed SE virus, this added test of the maceration tanks may expose the trans-ovarian route. More and more, the trans-ovarian transmission of Salmonella paradigm appears to apply from the breeder hen to the commercial pullet chick as one possible route of SE transmission to commercial laying hens.


Streamlining the Egg Rule: Sec. 118.7 (a) requires environmental tests of each poultry house.  If any environmental sample tests positive, Sec. 118.8 requires four 1,000 egg samples tested at 2-week intervals for a total 4,000 eggs. When it comes to food safety, testing is important, but the Iowa State University VDL test results show that Salmonella- positive environmental samples do not necessarily translate into contaminated eggs. From 2011 to 2015, ISU VDL test results showed a dramatic drop (14% to 2.4%) in positive tests of SE from environmental samples taken at egg laying facilities. After testing over 685,000 shell eggs from the summer of 2010 until March of 2016, ISU VDL found only one positive egg pool, which was during the 2010 national recall.


Farmers are required to test the environments of their farms. The cost of environmental sampling for Salmonella these farms are borne by the farmers with single drag swabs being cultured throughout the farm. Pooling the samples will help reduce the cost to farmers without compromising safety. This is demonstrated in the 2015 research article (published in Avian Diseases 59:548-553) entitled “Validation of Single and Pooled Manure Drag Swabs for the Detection of Salmonella Serovar Enteritids in Commercial Poultry Houses” by Dr. H. Kinde et.al., California Animal Health and Food Safety Laboratory System, School of Veterinary Medicine, San Bernardino, CA. This study showed there is no significant difference between the sensitivity of environmental sampling of four-swab pooled together using the National Poultry Improvement Plan culture method compared to the single swabs analyzed by FDA’s method, but the costs are significantly less, while not compromising the efficacy of the tests.


These suggestions are offered to enhance the Egg Rule so that Salmonella outbreaks linked to eggs can be reduced while helping egg farmers become more efficient in adhering to the FDA requirements for its prevention.




Ken Klippen, President

National Association of Egg Farmers

PO Box 1065

Oaks, PA 19456-1065


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cc: John Sheehan, FDA,CFSAN

     Nancy Bufano, FDA, CFSAN

     Dr. Jerry Ramirez, FDA,CFSAN


National Egg Farmers Prepare for Environmental Challenges after New IPPC Report

Recently, the Intergovernmental Panel on Climate Change Special Report 15 claims the latest disaster  “tipping point” is just 12 years away. If governments around the world fail to make “rapid, far-reaching and unprecedented changes in all aspects of society, human civilization and our planet face cataclysm”, the IPCC asserts.   This gave rise to a number of inquiries for the National Egg Farmers, from non-farmers who want to see and end to the way we produce eggs, on the contribution from agriculture to the Greenhouse Gas emissions impacting the environment. We’ve addressed this before, but this new report called for us to update our supporting science showing GHG from agriculture at less than 8 percent. You can use this as a template if you get someone complaining, or let me know and I'll respond to them.


The IPCC insists that fossil fuel use must be slashed from over 80 percent of global energy today to zero by 2050 – and the world must spend $2.4 trillion per year for the next 17 years to subsidize the transition to renewable energy. That’s on top of the $2 trillion per year already being spent on Climate Crisis, Inc. research, consulting, carbon trading and renewable projects.  Now we are looking at $60-80 trillion by 2036! 


You may have seen accusations that animal agriculture is contributing 40 percent to the GHG emissions overall.  This is disingenuous as it is the worldwide contribution and some countries are involved in deforestation and planting crops which increases GHG.  The U.S. has not seen an increase in the total acreage of deforested land over the last several decades even while total agricultural production has increased. The GHG emissions in the U.S. from all of agriculture is less than 8%.  The report substantiating the claim of less than 8 percent is entitled "Inventory of U.S. Greenhouse Gas Emissions and Sinks 1990-2015" published by the EPA (430-P-17-001. It shows all of agriculture, not just animals was responsible for 7.9 percent of GHG. Here's the website with all 633 pages.



In the report it states that in 2015, agricultural activities were responsible for emissions of 522.3 MMT CO2 Eq., (this stands for million metric tons of CO2 equivalents) or 7.9 percent of total U.S. greenhouse gas emissions. Methane, nitrous oxide and carbon dioxide were the primary greenhouse gases emitted by agricultural activities. Methane emissions from enteric fermentation and manure management represented approximately 25.4 percent and 10.1 percent of total CH4 emissions from anthropogenic (caused by humans) activities, respectively, in 2015. Agricultural soil management activities, such as application of synthetic and organic fertilizers, deposition of livestock manure, and growing N-fixing plants, were the largest source of U.S. N2O emissions in 2015, accounting for 75.1 percent. Carbon dioxide emissions from the application of crushed limestone and dolomite (i.e., soil liming) and urea fertilization represented 0.2 percent of total CO2 emissions from anthropogenic activities. 


Now, consider what is great about the U.S. egg industry.  Its production has significantly decreased its environmental footprint in the past 50 years, according to A Comparative Assessment of the Environmental Footprint of the U.S. Egg Industry in 1960 and 2010.  Researchers at the Egg Industry Center in Ames, IA found that today’s hens are living longer due to better health, better nutrition and better living environments. These researchers studied U.S. egg production from 1960 to 2010. It’s noteworthy that today’s egg farmers are producing more eggs in 2010, yet the total environmental footprint in 2010 was 54% - 63% lower than the environmental footprint in 1960. Using 1960 technology to produce the 2010 egg supply would have required 78 million more hens, 1.3 million more acres of corn and 1.8 million more acres of soybeans. In comparison to 1960 technology, today’s egg farmers are able to feed 72% more people.  


New Trilateral Trade Deal Benefits U.S. Egg Farmers

October 1st in a Rose Garden address, President Donald Trump discussed the new trade deal with Canada and Mexico. He said the new United States–Mexico–Canada Agreement (USMCA) protects American workers, farmers, ranchers, and businesses. President Trump spoke of a number of issues from the new agreement. he stated "The USMCA scores a big win for American farmers by eliminating Canada’s “Class 7” program, which allowed others to undersell American dairy products. Canada will provide new access for U.S. dairy products, eggs, and poultry".

The National Egg Farmers brought to the President's attention the inequities of trade with Canada over eggs and egg products.  Our members, both shell egg and further processors, asked us to engage when the President first outlined his intentions to change NAFTA.  And we did! Please share this news with your non-member peers producing and processing eggs so they can appreciate we are not a one-issue association.

Many members of Congress and other organizations praising the new agreement.  These were collected by the Corn Refiners Association who spearheaded a coalition of farm groups, which included National Egg Farmers, to advocate for change in NAFTA. Of course, the Canadian Dairy Industry says they've been sold out, but the new agreement ends many of the barriers imposed on U.S. produced dairy and eggs. 

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