Unscrambling The Egg Mess: What The British Have Done

Eggs fully traceable; most breeder flocks vaccinated; table egg producers must test for Salmonella

"If you do not test for Salmonella then your eggs will be classified class B. These can only be used for human consumption if they are heat treated before entering the food chain."

-UK Department for Environment, Food and Rural Affairs (Defra) Egg FAQs

Salmonella Enteritidis illnesses in the United Kingdom increased six-fold (from 1,101 to 6,858 confirmed cases annually) between 1982 and 1987. The first egg-linked Salmonella Enteritidis outbreaks in the United States occurred in 1985.

In 1988, CDC-led research discovered what was behind these dramatic changes in Salmonella illness patterns. CDC determined that eggs were becoming infected with Salmonella Enteritidis while they were still being formed inside the oviducts of infected laying hens.

The conclusion drawn from this research was inescapable. The only way to produce Salmonella-free eggs was to start with a Salmonella-free flock of laying hens, and to keep the hens free from Salmonella infections.

The UK's Department for Environment, Food and Rural Affairs (Defra) took action:

1. A Salmonella control program was implemented for breeding flocks in 1993.
2. In 1998, a program was set up to vaccinate UK laying hens against Salmonella Enteritidis.

By 2004, the Food Standards Agency was able to report that more than 80% of laying hens in the UK had been vaccinated against Salmonella Enteritidis. As a result of the vaccination program and the other control requirements instituted by UK regulators, the level of Salmonella contamination in shell eggs dropped by two-thirds between 1996 and 2004. And the number of reported human illnesses due to Salmonella Enteritidis fell to its lowest level since the late 1980s.

What else have the British done that can be put to good use in the United States? Here are a few of their initiatives.

Traceability

Eggs in the UK can be traced directly back to the producer. Since 2004, the UK has required every individual shell egg destined for retail sale or for caterers to be stamped with the method of production (i.e., caged, free-range, organic), the country of origin and the production establishment. Only producers with fewer than 50 laying hens are exempt from the egg marking requirement.

This is an example of a traceable egg, produced under the British Lion Quality Code of Practice, a voluntary program of the British Egg Industry Council, under which approximately 85% of table eggs are produced in the United Kingdom.

For comparison, this is a carton of Target market pantry brand eggs, identified as "Produced and packed by or for Sparboe Farms"

Mandatory slaughter of infected breeding flocks

"When a breeding flock of Gallus gallus is suspected of being infected with Salmonella Enteritidis or Salmonella Typhimurium the flock is placed under official control by the Competent Authority. This applies to breeding flocks from day old through to end of production. If the flock is in the laying phase no further eggs may be sent for hatching and no birds or hatching eggs may leave the holding, except under licence issued by the Competent Authority. When infection with Salmonella Enteritidis or Salmonella Typhimurium has been confirmed, the owner is required to have the birds slaughtered in accordance with Community legislation on food hygiene."

Mandatory testing by egg producers

"Producers must test for Salmonella as set out in the Salmonella NCP (National Control Programme). Any eggs which come from a flock that has not been properly tested or which is suspected or known to be Salmonella positive must be treated and marked as class B eggs. To avoid handling such eggs in their packing centre without first obtaining Animal Health consent and to avoid incorrectly classifying unmarked eggs as class A eggs, packers should take steps to satisfy themselves that the eggs they receive from producers are from tested and Salmonella free flocks." Only small producers (with fewer than 350 laying hens) are exempt from this provision.

Responsibility and Accountability

"If you are an egg producer in England, and you do not test your laying birds for Salmonella in line with NCP and your eggs are intended for the retail market (Class A eggs), then you must treat your eggs as class B eggs. If you fail to do so then you may be given a penalty notice for your failure to comply or even face a criminal prosecution in court for non-compliance." Only small producers (fewer than 350 laying hens) are exempt.

"For egg packers, you may also face a penalty, or criminal prosecution, for allowing eggs onto your premises where they come from a flock where the salmonella testing under the NCP is not up-to-date, or the flock is suspected, or is known to be, infected with the relevant salmonella serotypes. Likewise you may also face a penalty or criminal prosecution for packing and marketing those eggs as anything other than class B eggs."

Consequences

"The range of penalties for non compliance are:

• Marketing restrictions automatically apply.
• A £100 to £4,500 penalty depending on the severity of the contravention.
• The issue of a compliance notice which will be made public.
• Criminal prosecution."

How does the British system compare with the US situation?

After several years of sitting "shovel-ready" on the shelf at FDA, the US Egg Safety Rule finally was promulgated in 2009, and began to take effect in July 2010 – for the largest egg producers (more than 50,000 laying hens) only. Medium-sized producers (3,000-50,000 laying hens) have an additional 2 years to comply; small producers are at liberty to ignore most of the Egg Safety Rule requirements (except for temperature control).

The Egg Safety Rule requires producers to:

• Buy chicks and young hens only from suppliers who monitor for Salmonella bacteria (also required by the British)
• Establish rodent, pest control, and biosecurity measures to prevent spread of bacteria throughout the farm by people and equipment (also required by the British)
• Conduct testing in the poultry house for Salmonella Enteritidis. If the tests find the bacterium, a representative sample of the eggs must be tested over an 8 week time period (4 tests at 2 week intervals); If any of the four egg tests is positive, the producer must further process the eggs to destroy the bacteria, or divert the eggs to a non-food use (British system is more demanding)
• Clean and disinfect poultry houses that have tested positive for Salmonella Enteritidis (also required by the British)
• Refrigerate eggs at 45 degrees Fahrenheit temperature during storage and transportation no later than 36 hours after the eggs are laid (European requirements differ from this)

The Egg Safety Rule does NOT require producers to label egg cartons with a "best before" or "expiration" date. That comes under USDA jurisdiction, and is not mandatory, even for the largest producers.

The Egg Safety Rule does NOT require producers to test their eggs unless environmental testing in a poultry house has detected Salmonella Enteritidis.

The Egg Safety Rule does NOT mandate automatic marketing restrictions in the event of non-compliance.

One of the biggest difficulties faced by FDA in an investigation is tracing a contaminated food to its source. Traceback is especially problematic when food products – such as shell eggs – are sold in bulk for repackaging by wholesalers or distributors.

This is not the first time that a food borne illness outbreak investigation has shown up the inadequacy of food traceability in the United States. As the British have shown, the technology exists to correct this major gap in our food safety system.

Enhancing traceback for fruits and vegetables is one of the elements of the long-stalled FDA Food Safety Modernization Act. What about eggs? What about peanuts? What about the thousands of other raw ingredients and processed foods that circulate through our food supply?

Or must US legislators and regulators continue to demonstrate that the definition of insanity is to repeat the same actions over and over again in the expectation of achieving a different result?

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