Aug10

USDA Responds to Egg Farmers Request

On July 20th NAEF was in the office of the USDA General Counsel Stephen Vaden asking for better reporting and data collection by the State Veterinary Disease Laboratories.  In trying to evaluate how effective the Egg Rule has been [21 CFR part 118 Prevention of Salmonella Enteritidis in Shell Eggs During Production, Transportation, and Storage (74 FR 33030)] it was discovered that the labs do not report the egg pool samples as coming from eggs being tested. Instead the information is lumped into one general category "poultry".  How can the government assess the effectiveness of the testing being done and paid for by the individual egg farmer when the reporting is so vague?   That was the question posed to the USDA General Counsel, and he agreed and followed with a promise to consult with Kevin Shea, the Administrator of the Animal & Plant Health Inspection Service, that very day.  USDA's Chief Veterinarian Dr. Jack Shere telephoned days later to say adjustments would be made in the reporting forms to accurately reflect sample results. 

 

Furthermore, Sec. 118.7 (a) of the Egg Rule 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. NAEF showed the General Counsel the results from the Iowa State University VDL showing that Salmonella- positive environmental samples do not necessarily translate into contaminated eggs. After testing over 685,000 shell eggs from the summer of 2010 until March of 2016, ISU VDL has found only one positive egg pool, which was during the 2010 national recall. 

 

NAEF informed USDA that it had urged Congress in meetings on July 19-20 to test pooled samples from environmental drag swabs instead of the individual swabs currently required by FDA.   Pooled samples would reduce the financial burden on egg farmers. This is consistent with 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.  NAEF has not yet heard back from FDA on this suggested improvement and cost-reducing measure to save testing expenses for the nation’s egg farmers.On July 20th NAEF was in the office of the USDA General Counsel Stephen Vaden asking for better reporting and data collection by the State Veterinary Disease Laboratories.  In trying to evaluate how effective the Egg Rule has been [21 CFR part 118 Prevention of Salmonella Enteritidis in Shell Eggs During Production, Transportation, and Storage (74 FR 33030)] it was discovered that the labs do not report the egg pool samples as coming from eggs being tested. Instead the information is lumped into one general category "poultry".  How can the government assess the effectiveness of the testing being done and paid for by the individual egg farmer when the reporting is so vague?   That was the question posed to the USDA General Counsel, and he agreed and followed with a promise to consult with Kevin Shea, the Administrator of the Animal & Plant Health Inspection Service, that very day.  USDA's Chief Veterinarian Dr. Jack Shere telephoned days later to say adjustments would be made in the reporting forms to accurately reflect sample results. 

 

Furthermore, Sec. 118.7 (a) of the Egg Rule 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. NAEF showed the General Counsel the results from the Iowa State University VDL showing that Salmonella- positive environmental samples do not necessarily translate into contaminated eggs. After testing over 685,000 shell eggs from the summer of 2010 until March of 2016, ISU VDL has found only one positive egg pool, which was during the 2010 national recall. 

 

NAEF informed USDA that it had urged Congress in meetings on July 19-20 to test pooled samples from environmental drag swabs instead of the individual swabs currently required by FDA.   Pooled samples would reduce the financial burden on egg farmers. This is consistent with 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.  NAEF has not yet heard back from FDA on this suggested improvement and cost-reducing measure to save testing expenses for the nation’s egg farmers.