Eggs, cholesterol and CVD—Here we go again!


A recent publication in the Journal of the American Medical Association* has resurrected concern over elevated dietary intake of cholesterol and cardiovascular disease (CVD). In recent years, expressing the words of Dr. Robert Eckel, Editor of JAVMA "the association of egg consumption and dietary cholesterol with CVD, although debated for decades, has been thought to be less important."

The article by Zhong and colleagues affiliated with the Northwestern University, Feinberg School of Medicine associates elevated cholesterol intake and hence eggs with a higher incidence of CVD in an analysis based on 29,615 subjects from six prospective studies followed for 17.5 years. The population comprised 45 percent men and included 31 percent blacks. Cardiovascular outcomes included stroke, fatal and non-fatal myocardial infarctions and heart failure. All-cause mortality was compared to CV events. The study adjusted for potentially confounding demographic, socioeconomic and behavioral factors including smoking.

The study concluded that each additional daily 300mg/day intake of cholesterol (say 1.8 large eggs) was associated with a significantly elevated risk (at the 95 percent level of confidence level) of incident CVD, assigning a calculated Hazard Ratio of 1.17. Consumption of one egg every two days was associated with a significantly elevated risk of CVD outcomes with a Hazard Ratio of 1.06. The association between egg consumption and incident CVD was not significant after adjusting for dietary cholesterol consumption.

The authors suggested that the results of their study, associating eggs in the incidence rate of CVD, should be considered in developing dietary guidelines. Although implicating egg consumption the observational study was not able to distinguish between the statistically derived association and actual causation.

It is apparent that in succeeding weeks the Egg Nutrition Center and their consultants in epidemiology will have to evaluate the peer-reviewed article. Dr. Mickey Rubin, quoted in the The Wall Street Journal of March 16th said "this study is inconsistent with multiple recent studies showing no association between eggs and heart disease risk". He will have his work cut out to refute the findings and to promote the nutritional benefits of eggs.

Given the accumulation of scientific evidence contrary to the conclusions of the study there should not be any adverse effect on consumption that has recorded only incremental expansion over the past four years. The danger is that activists opposed to intensive livestock production including vegans, environmentalists and proponents of animal rights will distort and amplify the findings using social media.

If we did not have the AEB and the ENC these entities would have had to be invented. Since we are fortunate to benefit from their resources they are worthy of industry support.

*Zhong,V. W. et al. Associations of Dietary Cholesterol or Egg Consumption With Incident Cardiovascular Disease and Mortality. JAMA. 321:1081-1095 (2019).


Appeal Filed Against North Carolina Hog Farm Nuisance Rulings


Three adverse verdicts have been handed down against Smithfield Foods and its subsidiary Murphy-Brown with direct and punitive damages amounting to more than $500 million in three lawsuits. The Defendant has filed an appeal supported by the American Farm Bureau Federation, the National Pork Producers Council, the North Carolina Farm Bureau Federation and North Carolina Pork Council.

The appeal is based on the fact that farmers contracted to Smithfield Foods functioned in accordance with the North Carolina Right to Farm Act devised to insulate farmers following "normal practices" from claims relating to nuisance. The Defendants also claim that punitive damages should not have been awarded since this category of compensation requires the plaintiff to prove fraud, malice, willful or wonton conduct exceeding gross negligence. The Defendants also claim that jury selection was restricted to a panel of urban residents none of whom were permitted to visit the subject farms.

The North Carolina hog nuisance trials have bearing on egg production units although it is acknowledged that hogs produce far more waste on a live mass basis than hens. The problem of disposal of waste from hog farms has not been adequately addressed by capital investment. There is universal reliance on lagoons and spraying supernatant over pasture. It is evident that if the hog industry continues in North Carolina, there will have to be radical changes in methods of manure disposal with bioreactors as the most practical albeit expensive solution.

Installation of appropriate manure disposal equipment will require capital investment beyond the immediate capacity of contractors. It is obvious that Smithfield Foods and other integrators will have to either subsidize manure disposal or transfer their operations to areas where lagoons can be used without creating nuisance. Simply enacting self-serving legislation at the state level is not a solution. The North Carolina hog situation is a classic case of traditional agriculture being replaced by intensive livestock production without regard for consequential problems of waste disposal. The clock appears to have run out on applying the most expedient and least expensive approach, regardless of the impact on the environment and area residents.

The egg industry progressed from lagoons decades ago and adopted high-rise housing. This transition was in retrospect a mistake but since the mid 1990's new houses are equipped with manure-belt batteries in both confinement and aviary systems. The egg-production industry disposes of manure in a responsible manner as a crop nutrient or by further processing, produces a commercial fertilizer.


GAO Addresses Food Safety


The U.S. Government Accountability Office recently published the High-risk List incorporating 35 government programs and activities including the Federal Food Safety System in their March 6, 2019 edition. The report calls for the Executive Office of the President to develop a national strategy for food safety that establishes sustained leadership, identifies resource requirements and describe how progress will be monitored.  This recommendation was made in the previous high risk report in January 2017 without any action from the White House.


The GAO urges the Government to implement the Performance and Results Act (GRBA) as amended in 2010 to improve strategic and performance planning an interagency food safety collaboration. The  GAO suggested that Congress should direct the Executive Office of Management and Budget to develop performance plans relating to food safety and establish legislation to enable the Food Safety Working Group to improve coordination and leadership.


It is a matter of record that the GAO has called for a single Federal food safety agency combining activities of among others, the USDA-FSIS and the FDA in a single entity consistent with an alternative to the current organizational structure.


When consolidation is mooted, bureaucrats circle the wagons and agree to cooperate and interact.  In January 2018 the USDA and FDA agreed to a formal system of coordination and collaboration with respect to biotechnology.  An obvious example was establishing jurisdictional borders for tissue-culture derived “meat”.


The GAO considers that current agencies responsible for aspects of the Federal Food Safety System are operating without a single performance plan and without clearly defined monitoring of effectiveness.


It would be difficult given resistance to change and “turf” considerations to rearrange responsibility for food safety under a unified sub-cabinet agency equivalent to the status of the EPA.  The U.K. and the E.U. have established unified food safety authorities with benefits to consumers.  It took the national tragedy of 911 to create the Department of Homeland Security consolidating the activities of agencies and bureaus within diverse departments.  It is hoped that evolution towards a unified food safety agency could occur without a serious incident and would be the result of applying mature judgment and logic to a system which currently represents bureaucratic and political expediency.


FDA Announces Strategy for Imported Food Safety


In a February 26th press release, the Food and Drug Administration issued a statement of strategy with respect to imported food. The FDA estimates that the U.S. imports 15 percent of its overall food supply. Products are derived from 200 nations or territories and comprise 30 percent of fresh vegetables, 55 percent of fresh fruit and 94 percent of seafood consumed.

The Food Safety and Modernization Act of 2011 placed emphasis on preventive action to avoid foodborne disease outbreaks. Accordingly, FDA has been granted supplementary oversight and enforcement to meet standards.

The four goals of the FDA strategy to protect the U.S. public are:

  • Food offered for importation meets U.S. food safety requirements

  • FDA border surveillance prevents entry of unsafe foods

  • A rapid and effective response to unsafe imported food

  • An effective food import program should be implemented

During recent months, FDA Commissioner Dr. Scott Gottlieb has aggressively pursued responsibility for aspects of food safety within the jurisdiction of his Agency. Although the goals as stated are realistic and desirable, it is noted that over 125,000 facilities produce or supply foods to the U.S. How the FDA intends to fulfill its mandate is less clear.

Given artificial barriers as designated by Congress, it is doubtful as to how the U.S. can have a seamless and integrated food safety program. Despite lofty goals, increased funding and advances in technology, ultimately a comprehensive food safety agency based on the pattern in the E.U. will have to be established in the U.S. This will leave the FDA with responsibilities for drugs and medical devices that at present it is hard pressed to fulfill. The USDA will have jurisdiction over existing activities with the exception of the Food Safety and Inspection Service.


Control of “Exotic” Newcastle Disease in Southern California


The authorities involved in attempting to control the ongoing outbreak of velogenic viscerotropic Newcastle disease (vvND or "exotic" ND) have been less than effective in suppressing and eradicating the outbreak in three contiguous counties in Southern California. From late May 2018 through February 7th 2019 there have been 363 diagnoses of vvND involving "backyard flocks". This term is a euphemism for fighting cocks and the distinction must be recognized since it has implications for both control and the required approach to effectively limiting the danger of transmission to commercial poultry. To date, four relatively small commercial operations in Riverside County have been affected but it is only a matter time, given the mobility of fighting cocks and their owners that introduction of the virus into a larger and County has recorded 212 outbreaks and adjoining San Bernardino County has experienced 109 cases since May 2018. A total of 62 cases were identified in August compared with 20 in September, 18 in October and 17 in November suggesting a natural decline in incidence associated with the level of immunity or reduced movement. A surge in cases occurred in December with 43 cases followed by 86 in January. The reason for this increase has yet to be explained. In fairness to both APHIS and CDFA it is apparent that they are confronted with a lack of cooperation from the owners of fighting cocks since they are engaged in illegal activity.

Apart from keeping score and posting bilingual notices on various websites neither USDA-APHIS nor the California Department of Food and Agriculture have achieved any meaningful control on a practical level to effectively stabilize and then reduce the incidence rate. The State Veterinarian for California announced a pre-emptive depopulation of all "backyard poultry" in affected clusters in each of three counties at the end of 2018. This declaration in all probability led to dissemination of infection as fighting cocks, regarded by their owners of having high value, would have been transported from the pre-announced areas. It is understood that a single outbreak in Utah County, UT resulted from clandestine transport of fighting cocks from an affected area in Southern California.

The obvious solution to the problem of an alarming increase in incidence rate is to create a solidly immune status in the population of fighting cocks. Both live attenuated and inactivated vaccines with proven efficacy are available. The emphasis should now be on achieving immunity in this population of birds rather than after-the-effect diagnosis of outbreaks followed by depopulation of surviving birds.

When confronted with a disease situation in a discrete population associated with an illegal activity it is obviously necessary to accept realities and address the issue. An analogy might be made with distribution of needles to intravenous drug users to reduce the incidence rate of hepatitis and HIV. Clean needles distributed to users in urban areas will reduce the incidence rate of blood-borne infections albeit indirectly supporting an illegal activity.

Neither fighting cocks nor their Newcastle disease will simply evaporate over time. The authorities have wasted ten months and should by now recognize the endemic status of vvND in the fighting cock population of Southern California. There is nothing "exotic" in this situation and waiting for the infection to "burn out" places commercial flocks at risk. It is more a matter of luck and circumstance rather than intent that the infection has not emerged in a large complex or spread to commercial flocks beyond Southern California.

It is high time that authorities should engender the cooperation of owners of fighting cocks and encourage vaccination to be carried out by owners. It is noted that in the 1971 outbreak of vvND involved 1,340 flocks, including Goldman's Egg City in Moorpark, at that time holding two million hens door-to-door inspection and deployment of vaccination teams probably extended the outbreak through dissemination of virus. This lesson should be applied to the current outbreak. If more than 95 percent of breeding, rearing and fighting birds in the Southern California population can be solidly immunized, the incidence rate will fall sharply and the ongoing risk to commercial poultry and the export market will diminish. Now is the time for realism and concerted action.


Impressions from the 2019 IPPE


By any measure the 2019 IPPE was a success. Preliminary figures indicate an attendance of just over 30,000 with 1,400 exhibitors and 600,000 square feet over three halls of the GWCC. The organization by USPOULTRY for the exhibition, Poultry Science Forum and ancillary educational and social events was exemplary, contributing to efficient and congenial exchange of information and fellowship, especially with clustering of related products among the three halls.

This said, there were some overhangs influencing mood and optimism:

  • The first was the possibility of a partial Federal shutdown. Fortunately the matter was resolved on Thursday night with a Congressional compromise and a Presidential promise to sign the appropriations Bill.

  • Our ongoing trade dispute with China, withdrawal from the Trans-Pacific Agreement, concern over adoption of the USMCA to replace NAFTA and even uncertainties over Brexit were important considerations relating to our industry. From official comments after the IPPE it appears that negotiations with China are progressing and the March 1st deadline to ratchet up the tariff on imports from that nation will be extended.

  • Low prices were uppermost on the minds of both integrators and individual farmers. Profitability in all three segments of the U.S. poultry industry is currently depressed due to an imbalance between supply and demand. Easter consumption is soon to commence hopefully providing relief.

  • The current political climate, both national and international is a source of uncertainty, promoting a reluctance to expand and invest in physical plant and equipment. Additional unknowns affecting the U.S. egg-production industry relate to the types of housing that will be mandated by individual states and what will be accepted by major QSRs and supermarket chains. Attendance at the UEP Welfare Meeting on Monday attests to the concern of producers.

With respect to equipment and installations there were some evident trends and innovations that will become evident in the immediate future:

  • Aviaries will be the preferred system to replace conventional cages. All the U.S. and EU manufacturers displayed models comprising three tiers with top and bottom tiers for perching and feeding and the center comprising a continuous communal nest with either center or side egg collection.

  • Given a consensus among producers that by 2025 at least 30 percent of hens will still be confined to either conventional cages or colony modules it can be expected that many "enrichable" systems installed during the late 2000s in anticipation of the Egg Bill will be converted to enrichment by installation of enhancements and removal of partitions.

  • Grading equipment is becoming faster achieving 700 cases per hour but with greater complexity in response to industry needs. Both major manufacturers showed modifications to reject eggs with soiled shells to avoid cross contamination through the brush rollers.

  • Although antibiotic administration has never been a common practice among the egg segment of the poultry industry, the range of probiotic, prebiotic and botanical supplements developed for broilers and turkeys will have application to pullet rearing and even egg production.

  • Improvement in vaccine technology is paralleling an increased emphasis on biosecurity. A major manufacturer will soon release a bivalent IBD and ILT recombinant HVT vector vaccine with the possibility of adding ND in the near future. An entrant to the field will soon be distributing a live attenuated Salmonella product providing producers with greater choice and security.

In recent years the major manufacturers of equipment and installations for egg production have attended the IPPE as exhibitors on alternate years. It is hoped that the response demonstrated at the 2018 IPPE will encourage annual attendance, given the rate of technical innovation and the dynamics of our industry.


Progress in Bilateral Talks Between the U.S. and China?


The January 30th and 31st meetings between the Chinese delegation led by Vice Premier Liu He and counterparts in the U.S. that also included a meeting with the President are apparently making progress. The President has agreed to meet with President Xi of China before the March 1st deadline although no firm date or location have been set. In a tweet, the President indicated on Thursday 31st that he might be willing to accept a limited agreement by the March 1 st deadline and to extend talks to finalize a comprehensive deal.

The President has previously committed to increasing tariffs on up to $200 billion in imports from China from 10 percent to 25 percent. Backing down on this commitment would be detrimental to support from his base. According to trade specialists increasing tariffs to 25 percent would damage the economies of both China and the U.S. and would have international repercussions.

China has agreed to purchase soybeans and other agricultural commodities partly as a concession, but in reality because they need them. China has also agreed to purchase energy and has indicated that it would welcome American investment in the manufacturing and financial sectors. In contrast there appears to be little progress on resolving the underlying structural issues including theft of intellectual property and coercive business practices that are integral to future growth in GDP in China.

Commodity and financial markets are riled by conflicting messages from the White House. On January 29th, Secretary of the Treasury, Stephen Mnuchin noted that cuts in tariffs are a possibility. He stated "Everything is on the table." This is in contradiction to statements made by U.S. Trade Representative Amb. Robert Lighthizer who has negotiated from a relatively inflexible position supported by avowed sinophobe, Economic Advisor, Dr. Peter Navarro.

It is obvious that the price of soybeans and hence production costs for eggs, turkeys and broilers will depend on the outcome of negotiations and resolution of the current trade disputes. It is expected that if concessions are made, the question of exports of Chinese-origin breast meat to the U.S. will be raised.

At least the parties are talking. The White House issued a communique noting "The two sides showed a helpful willingness to engage on all major issues including the need to remove market barriers and tariffs that limit U.S. sales of manufactured goods, services and agriculture to China." The Xinhua news agency of China reported that talks were "candid, specific and constructive and dealt with trade, structural issues and enforcement".


Steel Tariffs and the Law of Unintended Consequences


The February 4th editorial in The Wall Street Journal on the consequences of steel tariffs succinctly identified the beneficiaries and losers of a precipitous action that in retrospect, was a misplaced bargaining strategy. Any egg producer intending to erect new housing will appreciate the escalation of the cost of steel as a result of tariffs imposed on imports. The intent of the tariffs was to "bring back the U.S. steel industry and create jobs for workers in the rust belt."

It is obvious to any person having passed an elementary course in economics that if imported steel increases in price due to an artificial tariff, domestic producers will take advantage of the price differential, certainly until production rises to meet demand. The Wall Street Journal reported that Caterpillar spent an additional $100 million in 2018 for steel, Whirlpool, $300 million and Ford, $750 million. These substantial figures belie the farcical assertion by Secretary of Commerce Wilbur Ross that the tariffs on foreign steel and aluminum would be a "rounding error". This is a simplistic and erroneous White House characterization of the inflationary effect of tariffs.

Returning to the original intent of the tariffs, there has been no increase in the number of workers employed in the steel industry. As of November 2018 the Department of Labor documented 83,400 employed in domestic steel mills, a few hundred less than in February 2018 at the time tariffs were imposed.

In rebuttal John Ferriola Chairman of Nucor Corporation writing in the February 7th edition of the WSJ points to an increase in U.S. steel mill utilization to 78.3 percent. This is attributed to Section 232 tariffs imposed by the Administration. He notes six new projects initiated by his Company scheduled to commence operation in 2019. Collectively these represent a capital investment of $1.2 billion that will eventually create 800 new direct jobs.

The increase in the price of steel has resulted in escalation throughout the chain of production and consumption of consumer durables and has indirectly increased prices to all consumers. Tariffs may have generated political capital but at a high cost to the U.S. economy and consumers without any tangible benefit to workers and shareholders of companies using steel and aluminum. Tariffs concentrate gains in a narrow sector and generate widespread negative effects in the economy. There is clearly a negative reaction by an aggrieved trading partner by imposing countervailing tariffs as a punitive measure as exemplified by the tit-for-tat trade war with China.

It is hoped that with eventual ratification of the USMCA and possible bilateral trade agreements with Japan, Korea and even the EU, tariffs will be rescinded to the benefit of our Nation.


"Ag Gag" Statutes Under Scrutiny


Eight states have passed "Ag Gag" laws. Although specific provisions may differ, the basic intent is to prohibit unauthorized persons entering an agricultural operation to obtain clandestine video recordings. In addition, many of these statutes prohibit false statements on employment applications to gain entry to facilities. The states that have enacted "Ag Gag" laws are Iowa, Idaho, Kansas, Missouri, Montana, North Carolina, North Dakota and Utah.

Shortly after enactment of the first laws, plaintiff lawsuits were filed in Federal courts questioning the constitutionality of restrictions on entry to livestock operations to obtain clandestine videos. The Animal Legal Defense Fund and the People for the Ethical Treatment of Animals have been leaders in opposing "Ag Gag" laws. In this endeavor, they are joined by legal academics and media.

To date, three of the "Ag Gag" statutes have been struck down principally on First Amendment considerations but also Fourteenth Amendment due process claims. The Iowa law passed in 2012 was subject to plaintiff lawsuits in late 2017. A Federal court in Iowa held the statute unconstitutional maintaining the substance of what the law intended to prevent did apply to speech. Even if falsehoods are involved, the First Amendment is applicable, if the falsehoods that may include creative editing of images, do not actually cause "legally cognizable harm" or provide "material gain" to the agent exercising First Amendment rights. The Court may have place a fairly narrow interpretation on "material gain" with respect to the plaintiffs. Organizations such as PETA are driven less by concern over animal welfare than they are in raising funds. By publicizing clandestine videos, the allegedly welfare-oriented organizations actually intensify their funding from donors by reinforcing their welfare (rather than pro-vegan) credentials and by posting videos and publicity from news conferences.

With respect to the Iowa statute, the Federal court maintained that the state failed to prove a compelling interest, which in the case of an intrusion on a specific farm in Iowa, would certainly not be the case. The courts rejected claims relating to biosecurity as the justification for legislation restricting access to agricultural facilities. The Court considered that laws relating to trespass and other statutory protections would be more applicable to restricting access that broadly framed "Ag Gag" laws.

With respect to the Idaho law, a Federal district judge determined that the statute violated both the First and Fourteenth Amendments. On appeal, the Ninth Circuit ruled that false statements to obtain production records or to inflict harm on an owner or to obtain material gain were valid provisions.

In evaluating the Utah "Ag Gag" statute, a Federal district judge considered the statute unconstitutional. The state maintained that the law was to protect animals and workers from disease and injury, an overtly simplistic contention that did not stand scrutiny.

The Kansas and North Carolina laws are undergoing challenge again on First and Fourteenth Amendment considerations. The North Carolina Property Protection Act applies broadly to agricultural and industrial enterprises which holds violators liable to the owner if unauthorized access is obtained for the purposes of obtaining records or undertaking clandestine photography.

The challenge to the North Carolina law was dismissed by courts in 2016 on the basis that the plaintiffs lacked standing. The United States Court of Appeal for the Fourth Circuit reversed the finding of the lower court and the case was remanded back for trial.

Given that three out of eight "Ag Gag" laws enacted by states have been ruled unconstitutional and two others are under litigation, egg producers cannot rely on "Ag Gag" laws for protection given validation of First Amendment rights accorded to journalists or agents of animal rights organizations.

Apart from carefully scrutinizing applicants for positions and ensuring barriers against unlawful access, farms should be operated in accordance with acceptable standards of welfare. Conformity with housing and procedures specified by certification organizations such as the AHA are required. Applying appropriate biosecurity, there is no reason why journalists and representatives of consumer groups cannot be admitted to farms in a proactive measure to avert negative publicity invariably following an intrusion.


Rebuttal of EAT-Lancet Commission Report


Joel Newman of the American Feed Industry Association provided a factual rebuttal of the EAT-Lancet Report. He made a strong logical case for lifting artificial restraints to GM technology and promoted the nutritional value of animal-derived protein. Unfortunately he did not address the core issue responsible for the projected disparity in population growth and food production.


The EAT-Lancet Report produced by a Commission of 37 scientists from 16 nations recommended a drastic shift from animal-derived protein to a vegetable diet in order to feed a burgeoning population anticipated to reach 10 billion by mid-century. This is a classic “become vegetarians or we will all starve” approach placing the onus on OECD nations.


Let’s be politically incorrect and dig deeper into the problem of future starvation.

It is evident that population growth contributing to the extra mouths will be in Africa and specific nations in Asia. Here are some observations relevant to the challenge we apparently face:-


  • If there was meaningful control of population growth in the countries that will be most affected, coupled with education and emancipation of women we would not have to collectively change our diets to any extent. Some of the nations most in need have appalling records of gender exploitation and cruelty to their womenfolk based on tribal and religious imperatives.
  • Africa has seen the effects of post-colonial land use policies that have sharply reduced agricultural productivity. Land redistribution (a euphemism for theft) in Zimbabwe turned the nation from a net exporter of corn into a bankrupt klepto-autocracy unable to feed its people. Now we may be observing a similar developing scenario in the Republic of South Africa. Land redistribution as in East Africa, based on politico-tribal imperatives, resulted in sharply reduced productivity. This was due to subdivision of economically viable farms that previously applied modern technology, fertilizers and improved cultivars with access to agricultural banks. The resulting family-operated small-holdings are simply subsistence units with no excess production to support growing urban populations or export.
  • Competition for resources and specifically water has resulted in tribal-conflicts which detract from efficient land utilization. Farmers cannot plant and reap harvests amid displacement from their lands and ethnic cleansing by warring clans and marauders.
  • In some nations in Africa and Asia with mineral or other resources that could support the rural and urban poor, inefficiency, corruption and gross mismanagement have deprived citizens of money that would otherwise be channeled into education, health and agriculture.



Do-gooders in the EU have been at the forefront of opposing GM and gene-deletion technology that could increase productivity. They have so demonized the approach to enhancing yields, decreasing pesticide use through application of GM, that nations in Africa and specifically, India as an Asian giant, are unwilling to allow farmers the option to advance productivity. Joel Newman is correct in his contention that artificial restraints to production, including application of the ‘precautionary principle’, have impeded growth in productivity of available arable land.


Let us turn the problem of feeding an expanding population on its head. If we do not have the additional three billion population in 30 years and if the nations most affected could improve their productivity we would not have to be concerned over famine and mass starvation. Essentially those in charge of these nations are not making any attempt to improve the long-term wellbeing of their people. Why should we then change our diets and displace our established animal agriculture industry?


USDA-APHIS Defend the Flock. Are They Tuned in to Reality?


As more than 140 individual outbreaks of vvNewcastle Disease have been diagnosed in 'backyard flocks' (in reality a deceptively mundane characterization of fighting cocks) spread among three counties in southern California since May 2018, APHIS simply kept score. Inevitably the uncontrolled infection spread to three commercial units based on proximity and failure to implement effective biosecurity.

APHIS is promoting a Protect the Flock campaign that encompasses a few principles of operational biosecurity appropriate to subsistence farms but is otherwise pablum. The recommendations with respect to commercial farms represent a detachment from reality in their simplicity and lack of detail. Perhaps APHIS and the CADFA are operating under a politically correct mandate not to offend owners of fighting cocks. The website lists a litany of measures that are suitable for homeowners backyard hens but are inadequate to protect commercial flocks from AI and ND irrespective of pathogenicity.

It is important to consider both the risk of introducing infection and the consequences of introducing a disease. In the case of catastrophic infection costs are immense accruing from depletion of the flock with or without indemnity, decontamination and loss of revenue and goodwill. In January 2017 the risk of vvND was low but consequences were high. In January 2018 as we now realize, the risk is considerably higher in Riverside and San Bernardino Counties. Is it proportionately higher in Stanislaus County three hours away by truck heading north on I-5 and Route 99? Or in the bordering states of Utah, Nevada or Arizona?

There has been far too much complacency and overt self-delusion by owners and authorities concerning investment in Structural biosecurity and hence supervision of Operational components of biosecurity for commercial laying operations. A capital investment of $100 million in infrastructure, housing, equipment and a packing plant in a new complex justifies commensurate expenditure on structural biosecurity. The basic capital investments should include:-

  • Fencing of the perimeter encompassing housing for flocks. Simply drawing lines on a site plan is an exercise in futility since there is no physical barrier to prevent uncontrolled entry of unauthorized persons or conversely to control the entry of authorized persons including employees shortcutting around biosecurity installations.

  • Blacktop or alternative impervious roads with drains are required within a site for service vehicles. Hardened roads allow natural decontamination by sunlight and other measures. Pathogens will persist in mud mixed with biological material and will be tracked into houses.

  • All personnel entering or leaving a designated live-bird area must shower in a purpose-built biosecurity module. Makeshift facilities including modified cargo containers may be inexpensive but they are invariably ineffective. "Personnel" includes owners, managers, supervisors, maintenance staff, house workers and crews for transfer, depletion, vaccination and beak-trim.

  • Functional and effective vehicle wash installations including a drive-through spray race and dip should be installed at the main entrance to the complex or other points of entry as required.

  • An on-site laundry facility is recommended for the biosecurity module to process Company-supplied clothing appropriate to gender and climate

It is axiomatic that effective Operational biosecurity is impossible to implement without investment in Structural facilities. Any compromise that neglects the known principles of the epidemiology of specific pathogens of concern or fails to consider the financial implications of risks and consequences is simply an exercise in "virus-roulette"

Why APHIS is pussyfooting around realities and failing to lay down minimum requirements for structural biosecurity relating to large egg-production complexes is incomprehensible. After all they have the ultimate responsibility for the control of outbreaks of exotic (actually regionally or seasonally endemic) diseases and disbursement of indemnity.


The China Impasse


Negotiations have recommenced between the U.S. and China to resolve the trade war that has raised the cost of imported goods and disrupted the sourcing and supply of ingredients worldwide, adversely impacting U.S. farmers. The actions initiated by the U.S are apparently hurting the economy of China, so both sides have an incentive to reach an accommodation.


Negotiations have recommenced between the U.S. and China to resolve the trade war that has raised the cost of imported goods and disrupted the sourcing and supply of ingredients worldwide, adversely impacting U.S. farmers. The actions initiated by the U.S are apparently hurting the economy of China, so both sides have an incentive to reach an accommodation.


Simply agreeing to rescind mutually destructive tariffs would in itself represent an accomplishment by restoring trade to a pre-June 2018 status. This will not address the underlying structural issues that represent the intent by China to advance their economy at the expense of the U.S., the EU and nations subjected to neo-colonialism in Africa. For two decades China has advanced a program of State-sponsored actions to achieve the Made in China 2025 objective. Authorized policies include government support of quasi-independent industries dumping products on world markets; coercive joint-venture agreements with foreign manufacturers to share proprietary technology and ignoring established rules relating to intellectual property. More recently aggressive hacking of databases and company information by state agencies has escalated representing overt commercial espionage.


The recent action by the Administration to oppose the policies of China is not merely an expression of America-first unilateralists. The Economist published a commentary in the December 15th edition under the heading of Chaguan (literally a tea-house for discourse- named for the eponymous capital of Sichuan Province) that emphasizes the effect of China policy on other industrialized nations. The article notes that placating or cajoling the errant nation over two decades and hoping for a change have been disappointing. China recognized that the openness of the West and their reliance on the World Trade Organization and United Nations agencies was a vulnerability to be exploited to their advantage. The Economist refers to now disillusioned internationalists as “unhappy ex-doves reading intelligence reports”.


Our negotiators clearly appreciate the apparent challenge of rescinding bilateral tariffs, representing the easy part, but they also have an appreciation of the underlying structural imperatives motivating China. It is difficult to envisage how the U.S. team will reverse entrenched policies imbued in a generation of bureaucrats intent on maintaining growth by any means possible. Even in two months with the clock ticking. There is concern that a Band-Aid will be placed over tariffs and negotiators will talk past each other and avoid the deeper issues or accept insincere offers to reform.  


Hopefully the negotiations will reverse the immediate trade issues and restore exports of U.S. farm commodities to China. Certainly the slowdown in economic growth in China implies an incentive to make concessions. It would however have been beneficial not to have alienated our traditional allies since a concerted and coordinated response to the underlying policies pursued by China would be more effective than a unilateral approach.


Addressing Gloom-and-Doom


The first edition of CHICK-NEWS for 2019 mailed on Wednesday contained a wish list for the coming year.  Collectively we would want to see a more harmonious and productive legislature, immigration reform, freedom from catastrophic disease and   bountiful 2019 corn and soybean harvests.


Our anticipations as we wish our colleagues and contacts the usual “Happy New Year” are tempered by anxiety and concern over the immediate future.


  • We are in the 14th day of an entirely unnecessary partial Federal shutdown. Although essential services continue, the effects are now becoming evident. The shutdown is self-inflicted and is due to the temporary breakdown in collective responsibility for our national wellbeing by politicians motivated by their personal and parochial considerations.  There is validity in the contentions of both sides of this impasse. The solution is compromise for the greater good.
  • Wild fluctuations in the stock market are symptomatic of a sense of insecurity and instability. While our economy is apparently sound the U.S. faces international pressures with a slowdown in China, uncertainty over Brexit, disparity between supply and demand for energy and restraints to the exercise of free trade.
  • The prospect of political deadlock as the 116th Congress is sworn in and anticipated tension between the House and the Executive Branch has ominous implications. We cannot afford to waste time and effort in political bickering while Congress needs to enact legislation to resolve the immigration crisis, protect our homeland security, reduce the national debt and relieve poverty through job creation. If one side claims victory over an issue ultimately we all loose.


There is no simple solution to a very complex series of problems, many of which are interrelated and are the result of neglect by previous Administrations. Some challenges are the result of impetuous recent decisions and are now subject to the Law of Unintended Consequences. Politicians on three continents and especially in our own Nation need to put aside pre-election rhetoric, deflate their egos and move beyond the personal imperative for re-election. Implementing bipartisanship, adopting a sense of “doing what’s right” and applying the Golden Rule would go a long way to addressing problems which are glaringly apparent during the first week of 2019. We have swept up the confetti, cleared away the champagne glasses and it is now time to get to work and confront realities. 


The swearing-in of the 116th Congress could result in brinkmanship and confrontation without resolution of our problems.


This commentator is optimistic that reason will prevail, compromise will emerge as an acceptable approach and that problems will be amicably resolved. We are reliant on a growing economy and increased spending to sustain growth in consumption of eggs and poultry products. We need a rational immigration policy to staff our farms and plants. We need functional infrastructure to move ingredients and products. We need unrestricted fair trade to capitalize on our production potential.


All of this can be accomplished by the Executive and Legislative branches of our government placing the common good above narrow political restraints.  


Debunking the Food Safety Magazine Article on Salmonella and Eggs


Every few months an article appears either in print or more usually on the web deprecating the intensive egg-production industry. Motivation for these diatribes and their veracity is usually based on welfare considerations, environmental concerns, veganism or their combination. The article that appeared in the December 2018 edition of the trade journal Food Safety entitled Walking on Eggshells: Do You Know the Risks? had a different genesis but was overtly disparaging of our industry and our product.


Authored by an ambulance-chasing attorney Jory D. Lange and his paralegal Candess Zona-Mendola the article was apparently intended to drum up business for the Lange Law firm It lacked any redeeming message with respect to promoting food safety. The Lange opus is replete with factual errors and displayed a profound ignorance of the epidemiology of egg-borne salmonellosis and a wanton disregard of facts.


The article as with others of a similar ilk conflates the 2010 outbreak of Salmonella Enteritidis (SE) infection affecting more than 2,000 consumers with the 2017 minor outbreak of Salmonella Braenderup infection responsible for about 50 cases.


The Wright County, event resulted from the venality and depraved indifference of Austin “Jack” DeCoster and his son Peter who knowingly distributed potentially contaminated eggs from their Iowa farms through distributors, brokers and dealers. DeCoster and his activities were never representative of our industry. He has been embroiled in civil lawsuits and state and federal sanctions for over 30 years. The combined portfolio of fines and settlements attests to his status as a scofflaw, eventually serving prison time for placing profit over prudence. He and his actions should have been formerly repudiated by the Industry in 2010, having crashed a seasonally rising market, depressing consumption and market price over a four-month period, depriving producers of over $100 million in revenue. DeCoster is unfortunate history (we hope) and was totally out of step with our industry, then and now.


Apart from the DeCoster- SE outbreak there have been no reported cases of egg-borne SE infection since introduction of the FDA Final Rule on Prevention of Salmonella implemented in 2011 attributed to compliant farms holding flocks of over 3,000 hens. In point of fact the incidence rate of egg-borne salmonellosis was in sharp decline during the late 2000s following the introduction of Egg Quality Assurance Programs adopted by many state egg associations and individual companies. Published annual CDC data on food-borne infections and their vehicles should have been reviewed by Lange and Ms. Zona-Mendola before asserting and implying that U.S. eggs are unsafe.


The recent outbreak of Salmonella Braenderup was totally and completely unpredicted. With now previous cases of this rare serotype being associated with eggs. Although receiving inordinate publicity the case was associated with an infinitesimal attack rate. Consider that the complex in question was producing 1.7 million eggs per day consumed by a population in the mid-Atlantic and northeastern states estimated to be 100 million over a six-month period. Only 43 cases were documented by the CDC between November 15th 2017 and May 16th 2018 confirming an attack rate of 8 per 100 million  population per month. The outbreak may not have been detected before introduction of FoodNet in 1995 and the application of whole genome sequencing to trace the source of an infection from 2016 onwards.


 The authors of the Walking on Eggshells article make considerable mention of the findings of the FDA 483 Warning Letter issued to the Company. In point of fact there were deficiencies in hygiene and biosecurity at the complex as disclosed during a multi-day audit by a somewhat inexperienced investigation team. The inspection incorporated taking hundreds of samples for microbiological culture. Only a few sites in the plant and manure pits in two houses yielded the pathogen suggesting other than extensive farm and plant contamination. Implicating flies and a few mice that were present on the farm as a contributory factor in the outbreak would only have been valid had the CDC inspectors actually sampled insects and rodents. Reference to a worker observed touching his intergluteal cleft, as cited in the FDA 483 and reproduced in the article was actually a maintenance employee who had no contact with product. Second-hand reading of the FDA document with inappropriate interpretation evidently resulted in inadvertent bias introduced into the article.


In the event the Company voluntarily issued a recall covering 250 million eggs, the equivalent of six-months production, of which all but about one sixth had been consumed. The Company immediately diverted eggs to breaking and pasteurization while removing two million hens.  The expense of decontamination and upgrades together with depopulation and loss of revenue possibly exceeded $30 million.



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