By: Michael R. Taylor, J.D.
To make sure that the eggs you serve your family for breakfast are safe to eat, FDA went directly to the source: the farm.
What we learned in visits to farms across the country gave us a real sense of some egg producers’ practical needs and the challenges they face.
This knowledge helped us craft a draft guidance that represents FDA’s latest action related to the “Egg Safety Rule”, a multi-phase 2009 regulation enacted to help keep eggs safe from the bacterium Salmonella Enteritidis (SE), the most common cause of foodborne illness outbreaks tied to consumption of shell eggs.
The new guidance is specifically intended to help those egg producers who provide their poultry with outdoor access comply with the rule’s various requirements such as biosecurity, rodent and pest control, cleaning and disinfection and refrigeration.
Egg producers who allow outdoor access face different environmental realities from facilities that keep their hens inside. The new guidance provides suggestions on how egg producers with 3,000 or more laying hens can protect their poultry from predators, pests, wild birds and other animals and comply with the new egg regulation, yet still provide hens outdoor access. (Egg producers with fewer than 3,000 laying hens and egg producers who sell all of their eggs directly to consumers are exempt from the Egg Safety Rule.)
Before issuing the draft guidance document, FDA did its homework, talking to producers and regulators at state, regional and local meetings to explain our rules and to get first-hand information. In addition, recognizing that there are a wide variety of poultry house styles designed to provide hens with outdoor access, we visited eight poultry farms in California, Texas, Arkansas, Washington, Wisconsin, Indiana, Michigan and Massachusetts in August and September 2012. The farms we visited included operations producing eggs which are certified organic by the U.S. Department of Agriculture’s National Organic Program (NOP). The farms utilized many of the house styles producers are using. Prior to these visits, FDA worked very closely with colleagues at USDA’s NOP in order to understand NOP standards and jointly visited several organic egg farms in Pennsylvania.
In effect, we were on a fact-finding mission to see for ourselves how these farms operate and to better understand the unique challenges these producers face. We gained a better understanding of these challenges and used this knowledge to develop a draft guidance document specifically addressing the challenges and concerns we observed.
We strive not just to be regulators, but to work cooperatively with industry as fellow problem solvers. In this instance, producers were concerned about their ability to meet the requirements of the Egg Safety Rule, were eager to ask discerning questions that made us rethink some of our initial thoughts on how to approach the guidance, and were reassured when they learned that we intended to focus on practical, reasonable advice.
FDA is committed to working hand-in-hand with the people who produce our foods. This approach helps ensure that we understand production processes, and put forth the best advice we can to protect consumers, whose health is our first consideration.
We firmly believe that producers can provide hens with outdoor access and still be in compliance with the Egg Safety Rule.