HPAI Vaccination a Necessary Component of Control


The fault lines dividing protagonists of vaccination against highly pathogenic avian influenza (HPAI) and those against this modality were evident at the UEP Committee briefing on January 24th and in hallways and show booths during the IPPE. The overwhelming sentiment within the egg production and turkey segments of the U. S. poultry industry is in favor of some application of vaccination as a supplement to existing control measures.  The broiler industry is opposed to vaccination based on the perceived impact on trade, since close to sixteen percent of RTC voume produced in 2013 will be exported.


The epornitic of 2022/3 is not a repetition of 2015.  The realities are:-

  • The H5N1 strain with Eurasian genes is now a panornitic strain present in the E.U., Asia, and the Americas with Brazil, thus far, the only major poultry producing nation unaffected. Both Australia and New Zealand are at this time, free of infection due to remoteness from migratory flyways.
  •  Highly Pathogenic Avian Influenza strain H5N1 is considered by many poultry health professionals to be de facto endemic in the U. S.  This opinion is based on the infection having been diagnosed on commercial farms in more than 35 states, has required the depopulation of 56 million birds to date, is affecting both commercial and backyard flocks and has continued for twelve months. This scorecard is inconsistent with an exotic infection.  Currently, many species of both migratory waterfowl and domestic birds show clinical signs and high mortality unlike previous H5 and H7 strains affecting only domestic poultry. 
  • The infection is regularly isolated from free-living mammals, including foxes, skunks, mink, bears, seals and a walrus.  The limited surveillance of wildlife has provided inadequate confirmation of the extent of infection and the range of species involved.
  • There is adequate anecdotal evidence to suggest that the disease can be transmitted over relatively short distances by the aerogenous route, thereby reducing the ability of commercial poultry producers to prevent infection through conventional biosecurity procedures.


It is an axiom that Highly Pathogenic Avian Influenza is the Newcastle disease of the 2020s.  During the 1960s and 1970s, velogenic viscerotropic Newcastle disease (vvND) was a catastrophic infection limiting production in intensive poultry industries in the E.U., Asia and Africa.  This commentator observed the futile attempts of the Department of Agriculture to stamp-out what was evidently an endemic disease in the Republic of South Africa.  When the Government ran out of money, resources and patience, and allowed vaccination, the industry responded by effectively suppressing the infection and restoring both production and profitability.


From comments provided by Julian Madeley, CEO of International Egg Commission, it is obvious that E.U. nations have recognized that HPAI H5N1 is endemic and are moving forward with adoption of vaccination as a component of their control programs.  Stamping-out has proven to be ineffective, especially with free-range flocks as in France.  Cynically it can be stated that this nation has successfully eradicated HPAI but on a successive annual basis over a number of years.


Dr. David Swayne recently organized an international conference on the application of HPAI vaccine. He emphasized the advantages of vaccination as an additional “layer of protection”.  Establishing immunized populations in specific areas reduces the outbreak threshold for a given disease and reduces the financial impact when combined with traditional measures including depletion of affected flocks, quarantine and surveillance activities. Research conducted both at major universities and institutes worldwide and by the bio-pharmaceutics industry have provided a portfolio of vaccines that can be applied to specific types and ages of commercial poultry.


Dr. John Clifford, Veterinary Trade Policy Advisor to the USAPEEC and formerly Chief Veterinary Officer for the USDA, noted the difficulties associated with preventing infection applying current biosecurity practices.  He highlighted the administrative restraints to vaccination that are based on the false premise that HPAI H5N1 is exotic and therefore can be eradicated. It is obvious that USDA-APHIS is using a playbook based on the1984 Pennsylvania epornitic that was self-limiting.  In the absence of epidemiologic investigations that have been urged by state poultry associations and promoted by EGG-NEWS, APHIS continues to expend funds provided by their presumably bottomless piggybank, the Commodity Credit Corporation.


The contention expressed by a Senior Staff Veterinarian In The Poultry Health Strategy and Policy component of USDA-APHIS  that the cost of a surveillance program would be as expensive as the cost of depopulation is fallacious and intended to support business-as-usual. Not only have the private and the public sector experienced losses as a result of HPAI, consumers have had to pay considerably more for eggs and turkey meat. If as is inevitable, infection moves into the broiler segment, HPAI will represent an even greater liability to the economy.


The concerns expressed by the broiler industry regarding trade have current validity.   It would be possible, as Dr. Clifford noted, for changes to be effected in current U.S. policy to allow for limited and controlled vaccination.  Nations importing leg quarters from the U. S. have in large measure endemic HPAI in their own industries or subsistence flocks.  There is no specific ban on trade if a nation vaccinates according to World Organization for Animal Health regulations, providing that surveillance is maintained.  It would be possible for states to certify that a specific complexe or flocks are free of HPAI by applying PCR prior to export of a consignment.  The obstacles to introducing vaccination as an adjunct to limited depopulation are more institutional than scientific.  Administrators of the USDA-APHIS have pursued a policy of  “stamping out” a supposedly exotic disease without accepting the reality that HPAI is a panornitic infection and is de facto endemic in the U.S. After 50 million plus birds depopulated  over a year without achieving eradication, it is difficult for any government agency to admit that they were wrong and accept a change in the approach to control.

Once the attitudinal block is resolved, programs to introduce vaccination on the basis of priorities can proceed.  Breeder flocks and long-lived birds including egg-producing hens should be vaccinated.  Flocks raised in areas of high population density especially with a history of HPAI could then be considered for protection.  Some areas of the nation would remain susceptible based on a low probability of exposure.   At the end of the day, scientific fact and sound principles of epidemiology should prevail.  Effective vaccination will clearly reduce transmission between farms located in close proximity and will reduce replication of the virus both of which are, in fact, the justification for depopulation.


An unspoken component of the current debate over control of HPAI relates to the emergence of a strain of pandemic significance to human populations.  The fact that H5N1 appears to have adapted to mammals should serve as a warning.  Given enough susceptible birds or free-living mammals or for that matter, farmed mink in close association, over time, it is highly likely that a mutation may occur that not only results in infection of human contacts but may evolve to allow human-to-human transmission.  The quicker that HPAI can be suppressed, but not necessarily eradicated in the short term, the greater will be the benefits to the poultry industries of the world and humanity. Vaccination against HPAI must be adopted as a valid consideration in control programs otherwise we will stumble on destroying flocks at great expense with consequential losses to producers and consumers.


ProEgg a New Model for the U.S. Egg Industry


The ProEgg cooperative established less than two months ago represents a new model for the industry.  This entity is constituted under the Capper-Volstead Cooperative Marketing Association Act. Enacted in 1922 this legislation allows bona fide farmers to form an association for their mutual benefit to market their products.  The Capper-Volstead Act provides limited antitrust protection and is regarded as the “Magna Carta” for agricultural cooperatives.


According to Ric Herrera, CEO of the ProEgg cooperative, the enterprise came into being in response to supply chain disruption associated with state hen housing legislation and more recently, the extensive HPAI epidemic. Combining expertise and resources, while creating a stable, consistent volume through the “pooling” of eggs from cooperative members.


The initial eight members of the Cooperative include Cal-Maine Foods, Central Valley Eggs, Colorado Eggs, Hickman’s Egg Ranch, Oakdell Egg Farm, Opal Foods LLC, Ritewood Egg Farm and Willamette Egg Farms.


The Cooperative should represent a win-win for all participants, through rationalization of the supply chain and obvious contribution to sustainability. Customers will benefit from more extensive availability associated with a potential large supply flock with centralized marketing and distribution.  Producers will be able to have consignments consolidated, reducing transport and delivery costs. 


It is anticipated that additional producers will join the Cooperative and will attain the same benefits as the founding members of the Cooperative.


According to the Capper-Volstead Cooperative Act, there are restraints on the mode of operation.  A Cooperative must function for the benefit of producer members with no outside entities involved.  The Act specifically prohibits predatory pricing practices, pricing discrimination, attempts to raise prices by restricting output or collusion among members to the detriment of trade.  The Act was passed in 1922 as an exemption from existing antitrust legislation but was, vetoed by President Wilson.  The House overrode the veto in 1921 and the Senate in the following year.


It is evident that the management of ProEgg will have to tread a very narrow path since customer groups will complain to the Department of Justice as a result of any practice that deviates from the Act and established case law.  The Secretary of Agriculture has the right to intervene in the event of any questionable or overt practice that is either explicitly disallowed or is considered inappropriate.


Given the experience of the CEO and the composition of the membership, illegal practices are considered unlikely but the retail chains comprising the customers will be monitoring the operation of the Cooperative.


It would be beneficial for ProEgg to promote the Cooperative in social media and to generate a positive image among consumers.  It is understood that the Cooperative will emphasize benefits and will demonstrate the advantages of a rational and efficient supply chain.


The power and marketing leverage represented by the prevailing industry benchmark cost system will be minimized, given the spread of ProEgg across eleven western states, the population of consumers served and the availability of eggs from the flocks operated by membership. If the ProEgg model gives rise to similar cooperatives that are in turn successful in the Northeast and even the Midwest, it may be possible to develop a CME Midwest Large quotation that could serve as a more effective benchmark, avoiding the extreme fluctuations that are evident following any disruption in the supply chain.


EGG-NEWS welcomes the emergence of ProEgg as an innovative advance in rationalization of marketing eggs under the umbrella of the Capper-Volstead Cooperative Marketing Association Act.


China Faces COVID Haixiao – Implications for the U. S.


Both international public health authorities and economists are closely observing the response to the abrupt change in official policy regarding control of COVID in China.  Official statistics, always questionable, now admit to over 100,000 fatalities since late December.  Social media in China characterize the escalating incidence rate as a haixiao or tsunami.  International epidemiologists suggest that as many as 40 million new cases are occurring daily. In high-density mega-cities, such as Beijing and Shanghai, as many as 70 percent of the population may already have been exposed.


The Government of China describes the abrupt change in policy from zero COVID to laissez faire (or “let it rip”) as “optimization of prevention and control measures”.  It is evident that China wasted three years in an attempt at containment requiring shutdowns. The Government failed to prepare for eventual restoration to pre-COVID social and economic activity by immunizing the population and preparing for an upsurge in hospitalization and ICU admissions.


Airfinity, a research company based in London, forecast fatalities at 10,000 per day, peaking at 25,000 after the Lunar New Year on January 22ndThe Economist predicted that as many as 1.5 million may die from COVID in coming months.  The real effect of allowing free movement among a population that is inadequately immunized will only become apparent after return of urban residents to their traditional homes in far-flung provinces following the annual three-week migration.


The burden of COVID will fall disproportionately on the elderly who, unlike their counterparts in Europe and North America, have resisted vaccination even using the imperfect, inactivated domestic vaccines. These are based on obsolete technology and include antigen from the Wuhan 2019 strain. The vaccines manufactured in China require three doses and offer limited immunity against current sub-variants of Omicron strain of SARS-CoV-2 in circulation.  Irrespective of Government statistics that are manipulated, the incidence rate of COVID may be judged from demands for cremation that far exceed capacity and a concurrent black market for Paxlovid.


The justification for the Government decision to lift all COVID precautions without an appropriate transition period, is questioned.  In the first instance President Xi Jinpeng considered it necessary to keep the lid on the pot until he was confirmed for a third term at the 20th National Congress (Ershi Da) during October 2022. Unprecedented street demonstrations coupled with an obvious decline in exports and plummeting GDP were important factors leading to the decision. 


Despite abandoning restrictions, daily activities and hence, the economy have not returned to pre-COVID activity.  The surge in cases has sharply restricted the availability of workers in some provinces with Guangdong, Shandong, and Jiansgu impacted by absenteeism that ranges from 25 to 50 percent of workers at present.  Despite accumulated savings during the 3-year shutdown, consumers are reticent to venture into shopping areas and restaurants, although the young have returned to bars and night-life and entertainment.


It is understood that Foxcon, a major assembler of electronics and source of export volume, warned the Government that lockdowns were seriously impacting the credibility of China as a reliable supplier.  This is evidenced by importers and companies in North America and Europe shifting production from China to plants in Viet Nam and India especially since the onset of COVID. 


During the past five years and with intensification during COVID, President Xi has waged war on the private sector.  Charges of corruption and fraud whether justified or not have been levied against property developers and entrepreneurs representing the new billionaires in a nation only recently freed from the shackles of doctrinaire communism and the inflexibility of Chairman Mao.  Lingling Wei, correspondent for the Washington Post, based in Beijing, recently described the apparent changes in policy with regard to the private sector. Speaking with Fareed Zakaria on the CNN program GPS on Sunday, January 15th, she stated that the Government now recognizes that growth in the economy will only be achieved through the private sector.  The traditional playbook of government spending on infrastructure projects to boost the economy will probably not be effective in restoring GDP and entrepreneurs including Jack Ma are now undergoing rehabilitation.


There will be little if any increase in demand by China for U. S. agricultural products over the remainder of the current marketing year ending in September. Corn exports, predominantly to China, are down by half over the corresponding period in the 2021-2022 year.  Soybean exports are proceeding at a more favorable rate, down six percent for market year 2022-2023.  Recent weekly orders for commodities by China have been, at best, lackluster.  Exports of broiler products to China our best customer by value will, in all probability, continue at existing levels.  For the first eleven months of 2022, exports of all broiler products to China amounted to 583,425 metric tons valued at $1,024 million, 33 percent higher than in 2021.  Of the volume shipped during the first ten months of 2022, feet accounted for 79 percent of volume with only 16 percent represented by legs and leg quarters, the principal export commodity by the U.S. broiler industry. 


In the intermediate term, China will achieve a measure of control over COVID with factory production restored and supply chains strengthened.  It is possible that during late 2023, congestion may reoccur in U. S. West Coast ports, although Gulf and East Coast ports have been expanded and equipped to accommodate imports from China and other Asian nations.


 From a public health perspective, infection of a large, susceptible population with current strains of COVID has the potential to produce new variants that may demonstrate either higher infectivity, pathogenicity or both.  This has implications for the entire world population. Attempting to confine variants to China by imposing travel restrictions is essentially shutting the stable door after the horse has bolted.  We can only hope that WHO has sufficient leverage with more receptive elements within the public health system of China to release reliable statistics and above all the molecular characterization of variants.  In the interim, genetic sequencing of isolates derived from aircraft wastewater can provide some indication of variants circulating in Asia and other continents. 


We can but hope that China can control COVID, applying effective mRNA vaccines that can be modified in the short term in response to emerging variants.  Increasing purchasing power among consumers will maintain demand for broiler feet, soybeans and corn, although the U. S. will compete with Brazil and Argentina for many commodities.


Reagan-Udall Foundation Report on the FDA-A temporary Fix?


A report analyzing the structure and effectiveness of the Food and Drug Administration requested by Commissioner by Dr. Robert Califf in July was released in November. The FDA is responsible for oversight of the U. S. food industry with sales of $1.5 trillion and is also charged with ensuring the wholesomeness of imported foods. 


Under extreme pressure from media and Congress Dr. Califf had no option other than to go outside his Agency to obtain an impartial and objective evaluation of operations relating to the food-related activities of the FDA. Questions concerning the effectiveness of the Agency have received recent attention and especially a publication by Helena Bottemiller Evich, an experienced investigative journalist. Public and institutional concern has followed revelations of inactivity over heavy metal contamination of juices, Cronobacter in infant formula and ongoing foodborne disease outbreaks.


The expert panel that reviewed the FDA was headed by Dr. Jane Henney, a former Commissioner of Food and Drugs and included five research specialists and past regulators.  The panel reviewed the structure and leadership of the FDA, available resources and the authority vested in the Agency. Dr. Henney characterized the report as “providing constructive recommendations that will take time to work through and implement but will benefit the health and safety of the American public”.


The panel through interviews and evaluation of organizational charts demonstrated that food is a stepchild of the FDA compared to drugs and medical devices.  The report noted that the Human Foods Program has “contributed to a culture of indecisiveness and inaction and created disincentives for collaboration”.  In 2019, the FDA organizational structure was modified resulting in the elimination of the position of the Deputy Commissioner for Foods and Veterinary Medicine. The respective heads of the Center for Food Safety and Applied Science, the Office of Food Policy and Response and the Office of Regulatory Affairs all were reassigned to report directly to the Commissioner of the FDA in addition to other functions relating to drugs.  This diluted the effectiveness of the Human Foods Program.  In the absence of a clear chain of command, functions within the FDA operated without consultation, resulting in duplication and omissions.  The report specifically cited the infant formula crisis that emerged in 2021 as an example of structural and organizational deficiency.  The report recommended the restoration of a Deputy Commissioner for food-related matters, reporting directly to the Commissioner and coordinating relevant working groups.


Neglect of food-related responsibilities is evidence by the 240 vacancies in the Human Foods Program and the fact that the Center for Food Safety and Applied Nutrition currently has the same number of full-time employees as were employed in 1978.  Deficiencies in the organizational structure were obviously exacerbated by interpersonal factors as detailed in a 2022 investigative report on the FDA and its activities with respect to food.


The Reagan-Udall Foundation report recommended that funding should be increased to hire suitably qualified, trained and able scientists and administrators who command salaries in industry and academia beyond the scale offered by the FDA. The report also recommended that the FDA has been reticent to exercise its recall authority, leading to delays in removing potentially harmful products from supply chains.


Response to the report has been generally favorable, especially with regard to Commissioner Califf who initiated the process.  Brian Ronholm, Director for Food Policy at Consumer Reports, noted, “We cannot afford to tolerate the status quo and let this moment go by without adopting fundamental changes to improve the ability of FDA to protect the public and ensure our food is safe.”  Outgoing House Appropriations Chair, Rosa DeLauro (D-CT) urged a positive response by Commissioner Califf noting, “FDA needs a change, and the Reagan-Udall Report is a formal acknowledgement of the issues plaguing the food program that begins to chart that path forward.”


 In response to the report, Commissioner Califf stated, “The Agency is committed to providing a public update on the new vision at the end of January 2023.”  He added, “I will closely oversee the Human Foods Program until a determination is made on how we will strengthen and modernize the Program.”  He concluded by stating, “I am fully committed to building a world-class Human Foods Program that works best for the public, our stakeholders and our employees and that will allow us to effectively deliver on our mission. 


One of the options offered in the report comprised separation of the food responsibilities from the FDA and assigning responsibility to a dedicated food safety agency as in the EU.  It is this commentator’s belief that ultimately this radical departure will occur, especially if the recommended changes in structure and additional funding do not result in a more proactive and effective outcome. Any serious crisis to emerge relating to either domestic or imported food may energize Congress and generate a groundswell for a radical but ultimately effective transition


It is hoped that real progress will follow the Reagan-Udall Foundation report and that subsequent action will rise to a level higher than moving the deck chairs on the Titanic.”


COVID Upsurge in China a World Threat


COVID is now regarded as out of control in the People’s Republic of China. Following the precipitous ending of an intended “Zero COVID” policy

imposed by the communist government of China all pretense of suppression was abandoned following the 20th Congress and the subsequent street demonstrations.  Based on hubris and contrary to basic epidemiologic principles, the central government attempted to eliminate COVID infection by a process of mass screening with localized and, in some cases, metropolitan shut-ins and quarantines.  This approach, coupled with an obviously ineffective vaccine has resulted in a high proportion of the population being susceptible to COVID. The government of China squandered two years during which they could have deployed an mRNA vaccine, expanded hospital facilities and established an inventory of effective anti-viral drugs It is estimated from a variety of models that half of the population of China will be exposed to COVID within the first quarter of 2023 and that fatalities may exceed 1.5 million inn three months with the elderly most affected.


True to form, the Government is no longer releasing statistics, but it is estimated that during December, as many 250 million of the Chinese population of 1.4 billion were exposed with fatalities running at over 10,000 per day.  The inactivated vaccine deployed in China in a two-dose sequence provides only short-term protection against severe clinical signs.  The vaccine is based on the 2020 Wuhan strain and is relatively ineffective against the predominant circulating viruses.  These include BA.5.2, a subvariant of the BA.5 Omicron sub-variant and strain BF7 also in circulation.  Both these viruses have emerged in Japan, although the level of protection afforded by mRNA vaccines and personal protective measures should reduce the impact of these variants. 


Both strains preceded the emergence of XBB.1.5 that has been identified in 29 nations. This Omicron variant was responsible for 41 percent of new cases in the U.S. and 70 percent in the Northeast during the last week in December 2022. This strain is highly efficient at binding human ACE receptor cells and is immune evasive. This virus is contributing to the rise in cases in the U.S. requiring hospitalization, averaging 6,500 per day for the week ending January 4th 2023. The strain is responsible for most cases in India where it emerged, and has also extended to other Asian nations, including Singapore.


The situation in China has implications for the rest of the world.  The gross mishandling of COVID with resulting exponential explosion of new cases creates a situation favoring the emergence of new variants, some of which may be more pathogenic with potentially lower protection provided by current mRNA vaccines.


It is questioned whether the approach by the communist government of China was a cynical attempt to suppress infection prior to and during the 20th National Conference that reappointed President Xi to an unprecedented third term and possibly life tenure.  Rapid transition from Draconian restrictions to lassiz faire will cost the nation dearly in lives, expenditure on health support and a loss in productivity.  Obviously, disruption in manufacturing output will depress GNP and may create a new wave of supply chain problems for the U.S and the E.U.


If the world and specifically, the WHO, were dealing with a rational government, appropriate control measures could be implemented on a global basis.  In the absence of epidemiologic data, disregard of transparency verging on obfuscation, international health authorities are operating in uncharted territory. Responding to the inevitability of dissemination of variant strains, many nations imposed restrictions on air travel from China. The simple expedient of demanding COVID Rapid Immunoassay tests before boarding international flights is ineffective. A few individuals on a long-haul journey will result in extremely high infection rates on landing as evidenced by a 40 percent positive test result from a planeload of tourists from China landing at Milan Airport, Italy.  Post-arrival testing is more effective, but quarantine facilities will be required to accommodate those positive and their contacts.  Outright bans on travel are ameliorative but those who are desperate will find ways to evade regulations.  Experience has shown that by the time travel restrictions are imposed, variant strains have already emerged in nations that establish programs of pre-departure testing.


Although we were looking forward to an end to COVID with required masking and other restrictions, it would appear that we are not by any measure out of the woods.  Common sense and basic preventive measures will have to be maintained for the current year.  Fortunately, our mRNA vaccines can be modified over the short term to produce more effective and specific protection provided as boosters. These are only effective on the personal and community levels if administered according to public health recommendations. 


We must have trust in our public health advisors, extend support to the Centers for Disease Control and Prevention and follow advice from medical specialists based on sound science.  Above all, we should reject speculation and politically tainted and anti-science misinformation circulating on the internet if we are going to come to terms with and coexist with this disease.


Time to Consider Vaccines to Control Avian Influenza


The European Food Safety Agency recently updated statistics relating to outbreaks of Highly Pathogenic Avian Influenza (HPAI) in Europe.   From October 2021 through September 2022, a total of 2,520 outbreaks have occurred in poultry with close to 4,000 detections in wild birds.  To date, 50 million birds have been depopulated in an attempt to eradicate the infection.  France recorded the highest number of outbreaks involving regions where pasture management of ducks, geese and chickens is followed.  Despite mandatory housing requirements, HPAI has continued with a surge in cases reported following the fall southward migration of free-living birds.  As with the U.S., there is evidence that domestic birds of diverse families are susceptible to HPAI strain H5N1, but it is unclear whether clinically unaffected birds can serve as disseminators of the virus and there is no reliable data on the duration of shedding.  Again, in common with the U.S. and Canada in 2022, there was no period of quiescence in summer in the E.U. with sporadic outbreaks reported, consistent with spread of the virus by domestic, non-migratory birds.


The European Commission has requested the European Food Safety Agency to determine the availability and efficacy of vaccines against Highly Pathogenic Avian Influenza for poultry and to develop control strategies incorporating vaccination. The Wageningen Institute in Holland has initiated a trial to determine the level and duration of protection against clinical signs and shedding in vaccinated chickens and ducks using commercially available and experimental vaccines.  Currently, vaccines are deployed in Egypt, and presumably other North African nations, and in Mexico.


Vaccination against HPAI was the subject of an international conference convened by the International Alliance for Biological Standardization held in Paris, France on October 25th and 26th.  This meeting considered a number of technical issues relating to vaccination but concentrated on trade and regulatory aspects that are advanced by opponents of vaccination.


Given the depopulation of over 50 million commercial poultry in the U.S. since the beginning of the 2022 epornitic, confirmation of the presence of H5N1 HPAI virus in 45 states and continuing recovery from free-living birds with sporadic outbreaks in commercial poultry, the classification of HPAI in the U.S. as an “exotic” disease must be questioned. A further complication is the growing realization based on circumstantial and anecdotal reports that HPAI may be transmitted over short to intermediate distances by the aerogenous route as has been demonstrated with Newcastle disease. This mode of infection would under practical conditions negate currently applied structural and operational biosecurity, suggesting alternatives, including vaccination to protect poultry.


It is impossible to eradicate a highly infectious endemic disease over the short or even intermediate term and accordingly, the USDA is faced with the options of either running out of money and resources or ultimately birds to depopulate.  The situation in Weld County, Colorado,  with five outbreaks among four large egg-production complexes in six months is a case in point. Essentially the USDA-APHIS is approaching the current epornitic with the same mindset as the 1994 outbreaks in Pennsylvania and is following a whack-a-mole strategy reliant on Commodity Credit Corporation funding.


The time has come to seriously consider strategic application of vaccination as a component of control. If we regard avian influenza as the “Newcastle disease of the 2020s” the approach to control and prevention is self-evident. We have universal vaccination against this previously catastrophic infection, trade continues and the disease is not a restraint to production except in some Scandinavian nations where vaccination is disallowed.


Adoption of vaccination to develop immune populations eligible for trade is feasible based on improved diagnostic capability to certify flocks as free of infection. Advances in vaccination technology will hopefully provide protection through automated or mass administration, raising regional or national flock immunity above the outbreak threshold. If vaccination is to be adopted as a co-strategy with existing control measures it will be necessary to modify outdated restrictions that ignore the realities of extensive worldwide endemic HPAI infection.


It is evident that opposition to vaccination incorporates irrelevant or spurious claims that are dated in the context of scientific advances and the reality of the ongoing World pandemic of H5N1 Avian Influenza. We need more field and molecular epidemiologic data on the mode of transmission of HPAI together with evidence that specific vaccines and their deployment will be effective in suppressing mortality and shedding. Above all we will require unanimity among segments of the U.S. poultry industry that effective vaccines will be commercially beneficial.


Epidemiologic Study of the Ongoing 2022 H5N1 Epornitic is Long Overdue


Recently, Dr. Rosemary Sifford, Chief Veterinary Officer for the USDA Animal and Plant Health Inspection Service (APHIS), noted that Veterinary Services is preparing a risk assessment report on highly pathogenic avian influenza (HPAI). This document is intended to guide producers to implement meaningful practices to exclude infection from their flocks during the ongoing HPAI epornitic.  Dr. Sifford stated, “We are in the midst of doing an analysis on all the data we’ve collected on the affected facilities to make some statement about the level of risk and what are factors that create a higher level of risk.”  The Agency intends to release a report in 2023.


To date, the involvement of APHIS has been totally reactive to outbreaks and the Agency has responded with the depletion of close to 9 million turkeys on 207 farms in 7 states and 42.3 million hens at a total of 33 locations.  Ninety-five percent of the losses in the egg industry have occurred on 18 large complexes with flocks ranging in population from 0.5 to 3 million hens.


Dr. Rosemay Sifford

APHIS has apparently collected data relating to field and molecular epidemiology from the initial cases extending from February through March 2022. This data set would have comprised seven large in-line complexes ranging from 1.2 to 5.0 million hens requiring depletion of 18 million birds. Adequate time has passed to have produced and circulated an interim report providing firm recommendations to rectify any obvious deviations from accepted biosecurity.  This may have prevented some outbreaks on 14 subsequent complexes requiring depletion amounting to an additional 25 million hens. A preliminary opinion with guidance during mid-April 2022 was not an unrealistic goal and would have been far more valuable than a more detailed and comprehensive report promised at some time in 2023.


In reviewing available releases, APHIS failed to provide a meaningful evaluation of risk factors contributing to the 2015 outbreak. It is feared that the promised 2023 version will be more (or less) of the same despite advances in molecular epidemiology. Given the prevailing APHIS mindset and neglect of urgency or a consideration of the financial consequences of HPAI the industry can expect no better guidance than was provided following the 2015 epornitic.


Dr. Sifford and her subordinates have failed in their primary responsibility of protecting the Nation’s flocks through application of available knowledge and experience to prevent disease.  The cost of outbreaks to the public sector including depopulation and indemnity to flock owners is immense, requiring consecutive tranches of funding from the Commodity Credit Corporation, the USDA bottomless piggy bank.  Costs to consumers in the form of triple-digit percent retail increase in prices during a time of inflation have added substantially to the financial impact of Avian Influenza.

The need for a preliminary epidemiologic evaluation is evidenced by the fact that outbreaks have occurred on egg production complexes with apparently high standards of both structural and operational biosecurity as followed by the industry. This may imply that there are mechanisms of transmission that have yet to be identified. If APHIS does not have the imagination, determination, resources or personnel to conduct the required field and molecular studies then these should be outsourced to Land Grant universities or the CDC with APHIS coordinating studies among federal and state agencies and academia. Conducting a telephone survey as contemplated, is a simple and inexpensive, but totally inadequate approach to defining the epidemiology of the 2022 HPAI epornitic.


 If it emerges from a structured investigation that current structural and operational biosecurity procedures, if followed, are inadequate to prevent introduction of infection then alternative and additional modalities are required.  If deviations from accepted biosecurity (“make-belief” or “biosecurity theatre”) are responsible for outbreaks, as implied in the APHIS statement by Dr. Sifford then specific recommendations should be re-emphasized with compliance linked to indemnity. The industry needs to be re-informed of risk factors and deficiencies in order that corrective action can be taken. If however the epidemiologic investigation of approximately 15 outbreaks occurring on in-line egg-production complexes suggests previously unrealized areas of vulnerability, the industry needs to know of these novel risk factors to enhance protection and reduce the probability of exposure.


   Immediate questions that arise include:


  • Can HPAI be transmitted via the aerogenous route?  If so, over what distance? Under what climatic conditions, including wind velocity, temperature and humidity?
  • Are domestic birds, other than migratory waterfowl and small mammals capable of serving as the reservoirs and disseminators of H5N1 avian influenza virus?  If so, what species are involved and the duration of their shedding?
  • Under what conditions does H5N1 virus remain viable on soil and impervious surfaces with and without exposure to sunlight or extremes of weather?
  • What characteristics of the H5N1 strain contribute to greater infectivity, broader host range and persistence in the environment?
  • What deficiencies occurred in accepted standard structural and operational biosecurity on affected complexes with an evaluation of their contribution to outbreaks?
  • Why have so few small cage free contract egg producers been affected?
  • Why have so many turkey farms been infected but the broiler industry has remained unscathed?
  • Is APHIS attempting to eradicate (“stamp out”) an endemic infection? If so alternative approaches including vaccination should be considered –but that is another Editorial!


Collectively, USDA-APHIS, ARS and NVSL together with Land Grant colleges, universities, in cooperation with the biopharmaceutical industry have made great strides in the rapid diagnosis of avian influenza.  Based on appropriate planning by APHIS, the response to outbreaks and cooperation between state and federal agencies has been expedited since the 2015 outbreak, possibly limiting spread of infection.


Given the resurgence in outbreaks of HPAI, APHIS is urged to expedite a review of data gathered and to concentrate on factors leading to outbreaks on the 15 largest in-line complexes in order to protect the remainder of the industry.  This should be a top priority and cannot be deferred until 2023.


As with any Editorial in EGG-NEWS, interested subscribers are invited to provide supporting or contrary views and opinions for review and publication. A response by APHIS would be especially welcome.

Simon M. Shane


China Faces COVID Dilemma


After three years of stringent restrictions including quarantines, lockdowns, enforced regular testing, all in pursuit of a “zero-COVID” policy, the Chinese Communist Party is forced to reconsider their entire approach to suppressing the infection.  Although street protests have been suppressed, the Party recognizes the enmity towards prevailing COVID policy among the 1.4 billion population.  Perhaps viewing the ongoing, televised World Football Cup competition in Qatar has brought home to citizens that China is out of step with the rest of the world.


China has relaxed certain restrictions, including evidence of recent negative testing to use public transport.  Lifting of restrictions is uncoordinated, since according to reports, it is still necessary to demonstrate a recent negative test result to enter some public buildings and stores.  Authorities are now allowing those testing positive to isolate at home instead of enforced removal to quarantine centers.


"Big Whites"enforce COVID restrictions

The susceptibility of the population to COVID is the major barrier to effectively relaxing controls.  China has relied on administration of their domestic CoronaVac inactivated vaccine.  Although moderately effective in preventing severe clinical outcomes, the vaccine requires three doses and has a limited duration of protection compared to mRNA vaccines as used in the Americas and the E.U. Experience in Hong Kong demonstrated the superiority of the Pfizer-BioNTech mRNA vaccine but high levels of infection with severe clinical outcomes due to inadequate vaccination rates were recorded, especially among the elderly.


Epidemiologic models suggest an extensive outbreak of COVID should current restrictions be relaxed.  Over a six-month period, it is predicted that there could be 112 million symptomatic cases, 2.7 million admissions to intensive care and 1.6 million fatalities.  At peak demand, ICU cases would exceed capacity by a factor of 15.  A late November study conducted by Airfinity predicted between 160 and 280 million cases and 1.3 to 2.1 million deaths over an 80-day period.


Officials in China blocked a 2021 joint venture initiative between BioNTech and the Fosun Pharmaceutical Company to manufacture mRNA vaccine.  Recognizing the deficiencies of the CoronaVac inactivated product both in China and in nations where the product was either sold or donated, work on a domestic mRNA vaccine was initiated. This belated activity of reinventing the wheel will ensure that there will not be any local product available for distribution in the immediate future.


The China Monolith

China has evidently painted itself into a corner by deploying an ineffective vaccine and maintaining extreme and impractical measures to achieve “zero COVID” Given that the economic impact of the restrictions are now evident in a declining GDP and that public dissatisfaction is growing, a reversal in policy is imminent. It is predicted that vaccination will be intensified in areas considered essential for economic activity and the Communist Party is now prepared to accept the inevitable avalanche of COVID cases. Naturally the Party will find scapegoats to be blamed for the debacle, saving the image of President Xi, now secure in a third term with hand-picked supporters.


Lest we indulge in Schadenfreude it should be remembered that the U.S. has recorded 1.1 million deaths and 99 million diagnosed cases in a population one quarter that of China since the commencement of the outbreak in 2020. At least 70 percent of losses were avoidable after introduction of the two mRNA vaccines in 2021. We are still loosing 300 to 400 of our fellow citizens each day, mainly among the elderly and those with predisposing conditions. The prevailing “it’s over” sentiment is exemplified by the 13 percent uptake of booster vaccines by those eligible. This ignores the reality of seasonal influenza and the rigors of approaching winter.


The attempts to control COVID in Sweden and China were both incorrect but the U.S. could avert inevitable losses through more extensive vaccination and commonsense disease prevention procedures.   


Industrial Greenhouse Gas Emissions Involve More than Carbon Dioxide


According to self-reported emissions data provided to the U.S. Environmental Protection Agency (EPA), greenhouse gases released from major industrial sources increased by 4.1 percent in 2021, compared to the previous year.  Total emissions, representing 2.7 billion metric tons of carbon dioxide equivalent, were generated by 8,100 required reporting locations producing more than 25,000 metric tons of carbon dioxide equivalent annually.  It is estimated that greenhouse gas emissions reported under the obligatory reporting program, represented half of all U.S. releases. 


Climate News recently highlighted the largest emitters of carbon dioxide and other potent greenhouse gases:-


  • The James H. Miller coal-fired plant in Quinton, AL, operated by the Southern Company, emitted 20.8 million metric tons of carbon dioxide in 2021.  The utility plans on reducing coal-fired generation by 80 percent by 2028, although the James H. Miller plant will continue in operation albeit with some form of abatement.


  • The Bailey Mine operated by Consol Energy, in southwest Pennsylvania, released 90,000 tons of methane in 2021.  This quantity of greenhouse gas is equivalent to the pollution produced by 1.6 million automobiles.  Landfills also contributed to methane emission with a Sampson County, NC. location operated by GLF Environmental responsible for release of 1,600 million metric tons of methane, annually.


  • Nitrous oxide is released by numerous chemical plants synthesizing plastics and industrial chemicals.  The Ascend Performance Materials plant in Cantonment, FL., released 24,000 metric tons of nitrous oxide from the production of adipic acid. This is an exceptional quantity compared to other U.S. chemical plants.  On an equivalent weight basis, nitrous oxide is 250 times more damaging than carbon dioxide and the nitrous oxide emission from the plant was equivalent to the release from 1.5 million automobiles.  Similar plants in the E.U. and the U.S. have installed abatement technology to reduce nitrous oxide emissions.  The Company plans on reducing release of nitrous oxide by 50 percent by 2025 and plans on reducing greenhouse gas emissions by 80 percent by 2030.


  • Hydrofluorocarbons are 15,000 times more potent than carbon dioxide as a greenhouse gas.  The Chemours plant in Louisville, KY., released 180 metric tons of HFC-23, equivalent to the annual emissions of 550,000 automobiles.  The company is now installing equipment that will abate release in accordance with a 2021 EPA directive.


  • Sulfur hexafluoride (SF6) is 25,000 tons more damaging to the atmosphere than an equivalent quantity of carbon dioxide.  The gas is used in high voltage circuit breakers and installations, including American Electric Power released 18 tons of SF6 across ten states, equivalent to the greenhouse gas emissions of 100,000 automobiles.  Currently, 88 U.S. utilities are following an EPA program to reduce emissions, although Duke Energy, with the highest leak rate of 6 percent annually, is not participating in the program and is apparently “working to learn more about the technology and reconsidering involvement” according to a spokesperson cited by Climate News.


  • Methane released from gas storage is almost completely preventable.  The Petal Storage station in Petal, MS., released 2,500 tons of methane in 2021, approximately half the quantity generated in 2020. Affordable Pipeline Partners, the operator of the relatively small facility, is actively but belatedly working to reduce methane release. (more information on this facility can be retrieved by entering “Petal” in the SEARCH block)


Intensive livestock agriculture is frequently blamed by environmental activists for release of methane from dairies, hog farms, feed lots and as a result of improper disposal of animal waste.  The Administration has identified sources of methane release and will intensify action to reduce emissions by the petrochemical industry and from landfills and mines.


Relevance of Some Welfare Research Questioned




During a recent regional meeting, a newly minted assistant professor presented data relating to previous doctoral research conducted at a leading West Coast university.  This study was intended to investigate the behavior of pullets transferred to aviaries with respect to their ability and inclination to ascend the three tiers of a module.  Pullets were reared in either an aviary structure or in a pen with a raised perch or on litter. The trial confirmed the intuitive reality that pullets reared in an aviary showed greater capability of ascending the tiers of the laying aviary compared too floor-reared pullets.  It is axiomatic, but not always followed, that pullets should be reared in an aviary compatible with the system to which they will be transferred.


What represented a concern is the fact that only a limited number of hens were the subject of the trial coupled with the extremely limited length of the experimental aviary installation.  The trial involved direct transfer from either of the rearing systems to the short lengths of laying aviary modules. This aspect of the experimental design ignored the reality that under commercial practice, pullets are confined for a “training period” of approximately three weeks to acclimate to aviary modules. This may have invalidated the obvious conclusion from the trial that deviated from industry practice.


It is questioned whether university trials conducted on a small scale are capable of reflecting flock size or behavior under commercial conditions. Extrapolation from limited scale trials frequently of short duration, and often with an injection of subjective sentiment, forms the basis of recommendations regarding flock welfare. These include standards for area requirements, perches, feeder-space and the allowance and position of drinker nipples.  Standards adopted and enforced by animal welfare certifying agencies are strongly influenced by the research conducted in both E.U. and the U.S. institutions. Advisory panels in the U.S. frequently comprise the same research scientists who are extending their research, some of which may be of questionable validity, into recommendations that may represent millions of dollars in incremental capital expenditure. 


The performance of small numbers of chickens under experimental conditions does not necessarily conform to the behavior of commercial flocks.  Have we been misled by conclusions from inappropriate experiments?  Are recommendations really valid in the context of commercial experience? Are subjective safety margins included?


It is noted that the scientific panels generating welfare standards are composed of academics with minimal contribution from suitably qualified poultry health professionals involved in industry.  There is a paucity of published work on the economic impact of standards with respect to capital cost of housing and installations. Initial costs conforming to standards for flock density and required enrichments impose fixed costs of production, including interest, fixed maintenance and depreciation.  The question arises as to how to design experiments that will provide realistic results that actually contribute to enhanced welfare and productivity. 


Flock performance is almost entirely neglected as a measure of welfare, although it is intuitively accepted that flocks subjected to suboptimal housing and management demonstrate higher mortality and lower egg production than flocks held under conditions conducive to achieving genotype.  It is acknowledged that small-scale experiments that are relatively inexpensive and easy to perform should form the basis of evaluating hypotheses relating to welfare.  It is, however, necessary to validate preliminary results under commercial conditions, especially when recommendations and standards impose high fixed costs on producers. Frequently in a competitive environment cost cannot be passed on to consumers reducing the return on investment in a muli-million dollar in-line aviary complex. It is easy for academics to develop inappropriate or invalid standards that effectively represent spending someone else’s money. The situation is compounded by the fact that many of the same researchers  serve in common on advisory boards for industry associations, welfare organizations and panels convened by major customer concerns. This creates a giant echo chamber with inadequate impartial and disinterested input.


The solution lies in greater cooperation among research scientists, equipment manufacturers and producers to establish realistic standards of housing and management that support quantifiable welfare, flock performance and financial return


Dissent at COP27 Meeting


The overriding conclusion from the COP27 Climate Conference that ended on November 19th is that limiting global warming to a target of 1.5 C (2.7 F) above pre-industrialization levels is unlikely to be achieved.  The target was adopted at the COP21 Paris Conference and has been successively reaffirmed as recently as the 2021 COP26 Glasgow Climate Pact. 


The Intergovernmental Panel on Climate Change reported on the effects of a rise of 2.0 C compared to the target 1.5 C.  The difference of 0.5 C would represent severe impacts on the ecosystem with an additional half a billion people exposed to excessive heat, inundation of islands and low-lying coastal areas, an ice-free Arctic and a succession of floods, droughts and severe hurricanes.  Recent studies have shown that global warming will severely decrease yields of corn, coffee and rice in areas traditionally devoted to these crops.  Wheat and potatoes will, however, potentially increase in production as they are planted at higher latitudes. Increased rainfall could raise production of rice in India and West Africa.  Equatorial nations including Brazil Indonesia and Nigeria would be most affected with sharply reduced corn and rice harvests.


Concern over global warming and the need for international action emerged in 1992 with many nations accepting the United Nations Framework Convention on Climate Change.  Notwithstanding a series of COP meetings, including the Paris Summit in 2015, there has been minimal progress on a worldwide basis to achieve the 1.5 C goal.  It appears that if carbon dioxide emission cannot be reduced from power generation, cement and steel production temperatures will rise to 3.5 C above the pre-industrial level. 


Progress has been made in displacing coal to generate power using renewables and less environmentally destructive natural gas.  Building design and construction materials have improved the energy efficiency of buildings.  Some progress has been made in developing technology to remove carbon dioxide from the atmosphere.  Agriculture could contribute to stabilization of the upward temperature gradient.  The USDA, under the current Administration, has assigned $3.1 billion in a Partnership for Climate-Smart Commodities.  It is questioned whether expending public funds on numerous, small projects will be beneficial either to the U.S. or to the world.  USDA Secretary, Tom Vilsack, announced at COP27 that $300 million would be assigned to 65 projects focusing on small and underserved producers and minority-serving institutions, demographics favored by the current Administration and the Secretary.


There has yet to be a final communique from COP27 but it is clear that sensitive issues including the 1.5 C target and continuing use of hydrocarbons to generate energy will be framed to the advantage of industrialized nations. These include the U.S. and China who have renewed negotiations on environmental rehabilitation. There was no commitment to phase out fossil fuels despite demands from developing nations impacted by global warming and rising sea levels. These countries will be provided with “loss and damage” grants to compensate for deprivation of land and productive capacity.


USDA to Undertake Evaluation of HPAI in Turkeys-Too Little, Too Late!


The USDA-APHIS has belatedly announced that it will conduct a survey on risk factors associated with outbreaks of highly pathogenic avian influenza (HPAI) on turkey farms.  To date, 7.8 million turkeys have been depopulated on 180 farms in seven states.


The case-control survey is intended to identify differences in management practices and farm factors between units infected with HPAI and those that escaped the virus.  It is intended that the telephone case-control survey will be conducted in November. It is questioned whether this exercise will contribute to meaningful recommendations on prevention. It would appear that the intended survey is a replay of the risk evaluation conducted in 2015 after extensive losses among turkey grow-out farms in Minnesota.


It is a matter of record that both EGG-NEWS and CHICK-NEWS have advocated for comprehensive and structured epidemiologic studies on risk factors leading to outbreaks of HPAI.  The study on turkeys should have been conducted at least five million birds ago in April of this year when results might have contributed practical suggestions to protect flocks.


It is questioned whether a telephone survey will provide the data required for an understanding of factors contributing to infection. Telephone surveys are cheap to conduct but are subject to selection bias. The approach lacks the ability to discern trends that would be noted by trained field investigators knowledgeable in both epidemiology and the norms and practices of the turkey industry. These include feed production and distribution, structural and operational biosecurity, farm ownership, work crews, source of poults and relationship of growers with processors.


EGG-NEWS has criticized APHIS for inactivity in failing to conduct an epidemiologic study on the 16 complexes responsible for over 90 percent of the 36 million hens depleted as a result of HPAI during the 2020 epornitic.  The weekly Egg Price And Inventory Reports posted on EGG-NEWS have included the statement, “It would have been helpful for APHIS epidemiologists to have reported on their findings from the epidemiologic questionnaires presumably completed following outbreaks on commercial farms and with special reference to the first seven large complexes affected through the end of March.  The industry should have been advised of possible routes of infection and whether any obvious defects in structural or operational biosecurity contributed to outbreaks.  The preliminary opinion with guidance during mid-April 2022 was not an unrealistic request and an interim report by early-May may have provided more value than a comprehensive document in 2023 or later.”


Failure to have initiated detailed epidemiologic investigations involving field and laboratory studies displays a lack of imagination, initiative and diligence by APHIS. Failure to identify risk factors and modes of transmission of HPAI among the early outbreaks involving egg-production complexes through May, deprived the industry of valuable information that could have been applied to modify or intensify relevant preventive modalities. A more proactive approach to understanding the epidemiology of the 2022 epornitic in each of the production sectors of the U.S. poultry industry may have saved producers, consumers and the public sector a considerable amount of money.


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