To better understand my piece on Rose Acre Farms, let me further clarify a few things. I am a sanitarian by training, I am not per se an expert in all aspects of poultry or egg production. I have a bias toward sanitation (the maintenance of healthful conditions) as a primary, or even the most fundamental disease control practice. As an environmental health professional, I am focused on preventing routes of disease transmission through the environment. To do this, we must understand that the routes are complex and involve three fundamental interactive epidemiological principles; Agent-Host -Environment.

In my foodborne-communicable disease investigation work over the last 40 years, its notable that in almost all cases, gross contamination involving the food is evident. Most often, the disease agent is passed either directly from an infected source (human or animal) or indirectly via cross contamination through an environmental exposure to contaminated air, water, human, surface or food.

The nature of the 2018 Rose Acre Farms outbreak and recall is not typical in that we have vertical transmission of Salmonella from the ovary of the chicken to the egg. In this case the factors of Agent and Host are working somewhat independently from the Environmental source, but there must always be an environmental source somewhere in the chain of infection. Recognizing the potential sources of contamination is problematic of course, as the environmental conditions in poultry operations are highly conducive to the propagation of bacteria.

We know from the FDA investigations of both the 2018 Rose Acre and the Quality Egg outbreak 10 years ago that there were poor environmental sanitation conditions, especially the rodent vector problem that cannot be ignored. Some industry experts at Egg-News have publicly claimed that no matter how many rodents or flies are breeding in the manure beneath the cages, that if the chickens are not infected to begin with, they will not become infected. However, it cannot be denied that transmission to the layer-hens happened through some exposure of the chicken to salmonella in the layer-house. The potential sources there are water and chicken feed. Depending on the situation, rodents could spread the bacteria around an entire operation and contaminate storage areas and water sources, especially when the infestation is severe, as it was at Rose Acres. Flies are also capable of becoming vectors. There is also processing happening at both operations where eggs were washed and further handled, so we might have a situation where the shell is contaminated, leading to problems in further handling. The sanitation at Rose Acres is suspect based on FDA finding poor cleaning methods of the equipment, and I personally observed the same or similar problems at Quality Egg. I don’t believe all of this is coincidence.

Salmonella Braenderup is not a typical egg-associated Salmonellae strain, the same industry experts have also publicly claimed that a possible environmental route might exist through the environment, such as a structural defect in this case; I agree with that based on FDA findings.

Why I believe there is a bigger problem in the egg industry is that Quality Egg and Rose Acre farms, the bad actors I am referring to, are some of the biggest producers in the US, so it cannot be said that the issues are isolated to a small segment of the industry. It is simply not enough for industry spokespersons to claim most egg producers are safe when we have massive contamination of the food supply through eggs. If you look at some of the data from foodborne illness surveillance systems like CDC’s Foodnet, you will see Salmonella infections in the population are still almost at baseline after almost 20 years of hard work by the food industry as whole to put into place best management practices. So, its aggravating when we see major food operators flaunt the rules. I know Rose Acre said, “we have to do better”. That is a healthy response and a good starting place- if they mean it. The Netherlands eliminated salmonella from their egg supply many years ago; they accomplished this through meticulous hygiene in the entire operation.

The deeper problem I am alluding to is that while these egg industry bad actors are known to the buying community, the supply chain seems unwilling to make buying decision based on food safety. That is also egregious, since we now have laws in place through FSMA that are supposed to curb that mentality.

And what about FDA and USDA in all of this? They seem to be just standing by until something bad happens then they go into reactive mode. This should not be. In fact, egg-borne disease transmission is preventable…so why are we not doing it?

The disgusting truth about industrial egg production is “it stinks”. Sanitation in such environments stretches the imagination when you think of a million birds trapped in cages in huge shed type structures called  “laying houses” and the tons of fecal material produced daily.

Continue Reading Rose Acre Farms-Another Bad Actor, Or a Deeper Problem

The Foreign Supplier Verification Program (FSVP) under FDA, was enacted in 2015 to require that foreign suppliers of food provide the same level of food protection for their food as provided by our public health system. This is needed, as outbreaks of foodborne illness continue to occur both in foreign and domestically sourced foods. Under this law, importers (also known as “FSVP importers” for the purpose of the FSVP law, as explained below) must perform a verification that a foreign supplier of food has complied with at least two new major FDA-FSMA federal rules; Produce Safety, and the CGMP and Hazard Analysis and Risk-Based Preventive Controls for Human Food Rules.

Continue Reading The Role of the “FSVP Importer” in FSMA

In today’s world of food safety requirements, food producers large and small and at all levels of the supply chain are subject to increasingly rigorous industry-driven food safety standards and audits. Third party audit standards have been revitalized by the all too apparent ineffectiveness of the way external parties verify food safety programs as brought to light in several foodborne illness outbreaks. Following the Jensen Farms incident, auditing firms have tightened the process for certification, for example, by raising the minimum score required for certification from 85% to 90%. In addition, the administration bodies at the major third party audit firms are intensely scrutinizing audit results and the performance of auditors. The anticipation of the implementation of FDA’s FSMA, turns the pressure up even higher, and it is likely that the third party standards will incorporate large sections of the new federal rules.

Continue Reading Making Room for the Human Element in Food Safety Auditing

Widespread allergen exposures and the extent of the problem

A recent spat of food product recalls due to undeclared allergenic agents illustrates the problem the food industry has in preventing allergen exposures.

Continue Reading Is the Food Industry Doing Enough to Control Allergen’s?

In Response to: “Blue Bell and the Very Real Impact of the Food Safety Modernization Act” at Food Safety news

I appreciate Michael Taylor’s comments in the above article posted on Food Safety News and also believe that FSMA is a step in the right direction. The fact, however, is that companies around the globe have already adopted food safety systems! This article makes it sound like preventative controls are something new and that such programs will be brought about by new federal law. The fact is in most major operations the preventative controls are in place right now. There are firms that have not adopted such in their operations, and FSMA may help to address this, but by and large, the large food borne illness outbreaks we have seen are not the result not having a prevention program, but the failure of the program to prevent the hazard from occurring.

Continue Reading In Response to Michael Taylor

Listeria monocytogenes bacteria are very hardy infectious bacteria and widely distributed in nature, and very difficult to control. Listeria monocytogenes previously known to veterinary science as a pathogen of sheep, first came to light as a major foodborne agent when the largest and most deadly outbreaks in US history occurred in queso fresco cheese manufactured in Los Angeles, California. http://en.wikipedia.org/wiki/List_of_foodborne_illness_outbreaks_by_death_toll

Continue Reading Listeria monocytogenes Current Epidemic and Public Health Response

As the result of numerous national and international outbreaks of foodborne illness, food industries worldwide have come under increasing pressure to ensure that their products are safe, wholesome, and meet government standards. FDA and USDA have the primary authority for our food supply nationally, while individual states typically regulate local food operations through state and county departments of agriculture and health.

Continue Reading Process and Substance in Third Party Food Safety Audits