Dangerous Eggs
Life Flow One
The Solution For Heart Disease
A Book By
Karl Loren
This page starts with a terribly frudulent story about the dangers of eatting eggs. Then, click here, to read an already-published critique of this story.
Center for Science in The Public Interest
Elizabeth Dahl
Staff Attorney, Food Safety Program
Caroline Smith DeWaal
Director, Food Safety Program
May 1997
Center for Science in the Public Interest
$5
We gratefully acknowledge the assistance of Michael F. Jacobson, Lucy Alderton, Kimberly Loui, and Grace Ko in preparing this report. We also thank the experts in government and industry who reviewed drafts of the report.
The Center for Science in the Public Interest is a non-profit organization that focuses on food and nutrition policies. It is supported largely by the nearly one million subscribers to its Nutrition Action Healthletter.
Center for Science in the Public Interest
1875 Connecticut Avenue, NW, Suite 300
Washington, D.C. 20009-5728
(202) 332-9110
Copyright © April 25, 2008 2:40 AM by Karl Loren on behalf of Vibrant Life, ALL RIGHTS RESERVED. Permission is granted for non-commercial downloading, copying, distribution or redistribution on two conditions: One, that some form of copyright notice is included in every copy distributed or copied, showing the copyright belonging to Vibrant Life, Burbank, CA, at www.oralchelation.com . The second condition is that the material is not to be used for any purpose contrary to the purposes and objectives of this site. This permission does not extend to materials on this site which are copyrighted by others.
Executive Summary
Key Facts About Scrambled Eggs
Key Conclusions and Recommendations
Introduction
SE Has Increased Throughout the Nation Consumers Are at Risk of Illness from SE in Eggs
Government's Inadequate Response Allowed the SE Problem to Grow Out of Control
Failing to Stop SE on the Farm: The Agencies Compete Rather than Cooperate.
A Slow and Ineffective Program to Trace Human Illness Back to the FarmThe Pennsylvania Pilot Program: A Successful Control Program Is Abandoned
Failing to Stop SE at the Packing and Processing Stage: No Inspection for Safety.
Failing to Stop the Growth of SE During Transportation and Storage: Inadequate and Unenforced Refrigeration Requirements
Failing to Warn Consumers of SE in Eggs at Supermarkets and Restaurants
Conclusions and Recommendations
Endnotes
Figures and Tables
Eggs used to be safe. Parents, without worrying, could let their children lick the bowl after preparing cakes and cookies. Consumers, without fear, could eat raw or undercooked eggs in salad dressings, egg nog and stuffing. Sunny-side-up eggs with runny yolks were great with toast. Now those same cooking practices can lead to severe illness and even death, if the eggs are contaminated with Salmonella.
What happened to safe eggs? Why are eggs today associated with more food poisoning outbreaks than any other single food? Why are public health officials now urging us to eat only fully cooked shell eggs or to use pasteurized egg products?
The answers to those questions involve a complex story with numerous plot twists: a biological adaptation that allowed bacteria to enter otherwise sterile eggs; federal agencies inspecting frequently to assure egg quality but never providing regulations adequate to ensure egg safety; and industry lobbyists dictating Congressional action.
The result is that eggs have become the number one contributor to food poisoning outbreaks in the nation, with annual consumer costs in the hundreds of millions of dollars. Hundreds, and possibly thousands, of people die every year from contaminated eggs.
The story began when a strain of Salmonella bacteria called enteritidis found its way first into the ovaries of chickens and then into their eggs. The problem was identified by federal disease detectives in the mid 1980s. The first farms producing contaminated eggs were all located in the northeastern U.S. and with quick action, the problem might have stopped there. But the numerous federal agencies with oversight responsibilities for eggs didn't act. Instead they competed with each other, stumbled over each other, and ultimately backed down in the face of industry pressure. Meanwhile, Salmonella enteritidis (SE) reached epidemic proportions.
Today, internally contaminated eggs are showing up from coast to coast. There is no way to tell without laboratory testing which eggs contain Salmonella and which ones are contamination-free. Grading programs run by the United States Department of Agriculture continuously check Grade A eggs for blood spots and yolk size, but have no controls for the harmful bacteria found in eggs. That responsibility falls to the Food and Drug Administration, which inspects egg plants an average of once every 10 years and merely recalls already-tainted food instead of preventing contaminated food from reaching the market. Consumers are generally unaware of the hazard and continue to eat raw and undercooked eggs, without realizing that such practices are risky.
Key Conclusions and Recommendations
The history of the federal government's failure to curb the SE epidemic illustrates the ineffectiveness of having multiple government agencies responsible for regulating the same food. The agencies were further hamstrung by a Congress that cut funding for a pilot control program just as it was beginning to show results and an industry that, except for producers in Pennsylvania, resisted attempts to prevent egg contamination on the farm.
Effective government action could have prevented many illnesses and deaths over the past twenty years and could prevent countless future unnecessary tragedies. To protect consumers from the hazards of SE, we recommend the following steps.
Eggs, once considered a safe food, have become increasingly contaminated over the last 15 years by a strain of Salmonella bacteria known as Salmonella enteritidis, or SE. While Salmonella sometimes is present on the outside of egg shells, no one ever thought the inside of eggs could be contaminated by bacteria. It was a surprise when government scientists first linked human illness from SE to internally contaminated eggs in 1986.
Since the early 1980s, the SE problem in shell eggs (fresh eggs purchased in cartons) has ballooned out of control. The Centers for Disease Control and Prevention (CDC) reported five times as many SE cases in 1995 as in 1980. (See Figure 1.) By 1994, SE caused an estimated 200,000 to one million human cases of salmonellosis each year. Contaminated eggs cause at least 80 percent of these illnesses, according to data from CDC.
Illness from SE can be fatal to the elderly, children, and those with weakened immune systems. The SE bacteria caused more reported deaths between 1988 and 1992 than any other foodborne pathogen. Hundreds or even thousands of people die from eating SE-tainted eggs each year.
SE is responsible for the lion's share of food poisoning illnesses, about a third of all food poisoning outbreaks where the cause is known. (See Figure 2.) The estimated annual cost of illness from SE ranges from $118 million to $767 million.
The magnitude of the current SE crisis was not inevitable. Before 1984, SE outbreaks were largely confined to one geographical area, the northeastern United States. The problem spread to the mid-Atlantic states in the late 1980s. In 1992, a government-supported control program began in Pennsylvania that required testing of hens and cleaning of poultry houses. This program showed promise in reducing the number of food poisonings from SE. However, federal support for that program was discontinued in 1995, and no nationwide program has ever been implemented.
The government response to SE-tainted eggs has been inadequate and ineffective. When Salmonella showed up on the outside of egg shells in the 1970s, government programs helped to curb the problem. Unfortunately, no similar programs were developed to stop the internal contamination of eggs with SE. A number of factors have contributed to the federal government's failure to control the SE epidemic: overlapping and unclear lines of jurisdiction between different government agencies; inter-agency competition; lack of support from Congress; and a lack of urgency among health officials.
Among other absurdities, a system has developed in which shell eggs are monitored continuously for quality and cleanliness by a federal marketing agency, but are inspected for microbiological and chemical contamination by the leading federal food safety agency only once every ten years, on average. Egg product plants (plants that produce liquid, frozen or powdered egg products) are inspected continuously by yet a third agency.
SE Has Increased Throughout the Nation
Between 1980 and 1995, the number of SE cases reported in the U.S. increased by more than fivefold. SE, which had been present in low levels, began growing out of control in the northeastern United States and then steadily increased across the country.
By 1984, SE began appearing in larger numbers outside the Northeast. (See Figures 3 and 4 and Appendix.) By 1986, the year CDC first linked SE to consumption of raw and undercooked eggs that were internally contaminated, the incidence of SE in the Northeast had increased more than sixfold over 1976 levels. While the number of cases of illness leveled off in the Northeast between 1990 and 1994, cases in the Rocky Mountain region doubled and cases in the Pacific region quadrupled during that same time period. In 1994, California accounted for about a quarter of the nation's laboratory-confirmed cases of SE. A USDA survey showed that the frequency of SE isolates in unpasteurized liquid eggs nearly doubled in the northeastern and western U.S. between 1991 and 1995.
To make matters worse, a more virulent form of SE, known as SE phage type 4, has appeared in five SE outbreaks in California and has also appeared in Utah, Arizona and Nevada. Although scientists do not yet know why, this new type causes five times as many human salmonellosis cases as other types of SE in the regions where it appears. In Europe, phage type 4 has become the predominant form of SE.
Even though CDC data in 1986 clearly documented the increase in the number of human illnesses from SE, federal food safety officials allowed SE to continue to spread around the country, resulting in millions of illnesses and thousands of deaths over the past 10 years. (See Table 1.) The federal government partially funded and pilot-tested an SE control program from 1992 to 1995 in Pennsylvania. However, this program did not develop into a comprehensive, nationally coordinated approach to testing for and controlling SE. Instead, in 1995, at the urging of the egg industry, Congress cut the federal funding for this program and prohibited USDA employees from working on the SE problem.
Table 1. A Ten-Year History:
How a Tiny Foodborne Bacteria Outsmarted the Federal Government
| SE Increases Throughout the Nation | Year | Federal Government Fails to Act |
| Almost 6,000 SE food poisonings reported for the year | 1986 | After an outbreak sickens 3,000, CDC identifies eggs as a source of SE food poisoning |
| 1987 | USDA decides not to establish a mandatory SE control program | |
| Almost 8,500 SE food poisonings reported for the year | 1989 | FDA and USDA simultaneously develop competing SE control programs |
| 1991 | * USDA begins control program targeted only at flocks that have been identified as the
cause of human illness through tracebacks * Congress passes law requiring egg refrigeration; USDA never enforces it |
|
| 1992 | USDA, Pennsylvania government, and industry begin voluntary pilot program | |
| Over 10,000 reported SE food poisonings for the year | 1995 | Congress cuts funding for successful pilot program and for traceback program, at egg industry request |
Consumers Are at Risk of Illness from SE in Eggs
SE is found inside eggs laid by otherwise healthy hens that are infected by the bacteria. It is estimated that one out of every 10,000 eggs, or about 4.5 million eggs each year, are infected with SE. Consumers have no way of knowing which eggs are infected. The SE bacteria multiply inside eggs that are not properly refrigerated (to an internal temperature of 45 degrees F.) As few as 10 to 100 SE organisms may be enough to cause illness in elderly people, children, and the immuno-compromised.
The elderly residents of nursing homes are especially at risk of death from SE: 85 percent of reported deaths from SE between 1988 and 1992 were from this group. SE infection causes flu-like symptoms, such as diarrhea, abdominal pain, nausea, fever and chills, and can have more serious complications, such as rheumatoid arthritis, meningitis, kidney or heart disease, and death.
Thorough cooking of eggs will kill the bacteria. However, many common egg-preparation practices are not sufficient to kill SE. Some high-risk practices include:
Another high-risk practice common in restaurants, nursing homes, and other institutions is pooling eggs in a large container after breaking and before cooking them. One SE-positive egg can contaminate dozens of others. This practice can result in major outbreaks of human illness if the pooled eggs are allowed to remain too long at room temperature and then are not fully cooked.
A recent government survey found that about half of all consumers surveyed had eaten undercooked eggs in the past year. Although the SE problem in eggs has been fully documented for more than ten years, this survey, combined with the increase in human illnesses, demonstrates that both industry and government have failed to sufficiently inform consumers about the risk of consuming undercooked eggs.
As many as 45 percent of all egg-laying flocks in the U.S. are now infected with SE, according to government estimates. Yet the spread of SE throughout the nation could have been stopped, or at least substantially slowed, years ago with appropriate government intervention. Control of SE is possible when government, with the cooperation of producers, demonstrates a commitment to eliminating the human health risk of this pathogen. In Sweden, for example, only five SE-infected flocks have been identified in the entire country since 1987. The Swedish government has a rigorous control program directed at all types of Salmonella in both laying hens and broilers. The program requires testing of laying flocks at least three times during their lives, with destruction of all flocks that are found to be SE-positive.
By contrast, the U.S. government failed to take effective action when confronted with evidence of human illness from SE-contaminated eggs. Any one of the following steps could have substantially cut today's high level of SE infections:
Instead, the federal agencies that share responsibility for regulation of eggs and the egg industry made only minimal and sometimes counterproductive efforts to stop SE. A confusing array of laws, regulations, and voluntary programs divides responsibility among four federal agencies:
In addition, state governments may inspect poultry houses, egg packing and processing plants, and retail establishments such as restaurants and supermarkets.
This crazy quilt of jurisdiction over eggs led to government inaction and inefficiency in the face of the emerging SE problem. The government agencies failed to take effective action at any of four key steps in egg production where SE could have been controlled: (1) on the farm; (2) at the packing and processing plants; (3) during transportation; or (4) at the retail level. The agencies were also hindered by Congress, which failed to establish clear jurisdiction for egg safety in one federal agency and placed the concerns of egg producers over public health.
Failing to Stop SE on the Farm:
The Agencies Compete Rather than Cooperate
The response of both FDA and USDA to reports of increasing numbers of SE food poisoning traced to eggs was to compete with each other, rather than to cooperate to solve the problem. Although the two agencies at first worked together during discussions about the problem, they did not cooperate in developing a solution.
The two agencies were initially unsure who had jurisdiction over infected laying flocks. APHIS is responsible for preventing the spread of communicable diseases among poultry and other domestic animals. However, FDA also has broad authority under the Public Health Service Act to make and enforce regulations to prevent the spread of communicable diseases from animals to humans. Further, the Food, Drug and Cosmetic Act gives FDA authority to prevent "adulterated" foods from entering interstate commerce. These two laws give FDA the power to recall eggs produced by infected flocks or to require them to be diverted to pasteurization plants.
In 1987, USDA officials decided not to establish a mandatory SE control program out of fear that the government would have to reimburse infected flock owners for substantial losses from the destruction of their flocks. Ironically, in the early 1980's, USDA spent at least $60 million to combat an outbreak of Avian Influenza, a virus that affects poultry but poses no human health threat, by destroying flocks and reimbursing owners. In contrast to USDA's approach, Canada's federal government requires destruction of laying flocks that are linked to human illnesses from SE, with full compensation to the producers. To date, the SE problem in Canada has remained comparatively small.
In August 1988, APHIS and FDA approved an industry-developed voluntary SE control program, but took no regulatory action. When it became clear that the voluntary SE control program was not slowing the spread of SE, a disagreement emerged between the two agencies as to how to solve the problem. FDA urged a mandatory program, while APHIS wanted to continue with the voluntary program.
For a period of time in 1989, FDA and APHIS were actually simultaneously developing competing mandatory SE control programs. Rather than working cooperatively, FDA officials were unwilling to discuss their proposed plan, which required testing of all laying flocks in the U.S., with APHIS. FDA publicly announced the plan before sharing it with APHIS.
In December 1989, to the surprise of FDA officials, APHIS announced a mandatory SE control program that targeted only flocks already implicated in SE food poisoning incidents. FDA then withdrew its stronger plan and supported APHIS's plan.
A Slow and Ineffective Program
to Trace Human SE Illnesses Back to the Farm
APHIS's plan targeted only those flocks to which human illness could be traced. Rather than sampling a large number of flocks to determine how widespread the problem was, the agency adopted a purely reactive approach, waiting until illnesses and deaths occurred before taking any regulatory action.
APHIS's SE control regulations, issued in 1991, applied to laying flocks whose eggs were implicated in SE food poisoning incidents, or that included hens from already-identified infected breeder flocks. Once a flock was identified as meeting one of those two conditions, the regulations required testing of manure and equipment from the laying houses, and of the internal organs of chickens. Chickens or eggs from those flocks could not be moved out of state (unless the eggs were sent to pasteurization plants) until extensive testing, including tests of the hens' internal organs and the poultry houses, show the complete absence of SE. The regulations place no limits on marketing eggs from contaminated flocks within a state.
The effectiveness of the tough-sounding regulations depended on successful tracing of human illness from SE back to the farm. In 1990, 19 outbreaks were traced back to flocks under the program, a success rate of 86%. By 1993, the success rate had declined to 14% (three of 21 outbreaks). The program was criticized for slow and redundant tracebacks. The average traceback took four months from the time of an outbreak until the decision was made to test a suspected flock. The tracebacks were so slow in part because APHIS refused to accept traceback work that had already been completed by state agencies.
APHIS's relationship with the states was not the only weakness in the program. APHIS also failed to work cooperatively with FDA. In one example, APHIS conducted an investigation of an outbreak of SE food poisoning in New York. The investigation implicated a Pennsylvania chicken flock, which tested positive for SE. However, APHIS waited almost a month before notifying FDA of the test results. By then, it was too late for FDA to find and recall eggs from the infected flock that had already been shipped to market and consumers were unnecessarily exposed to SE.
Though the regulations remain in place, APHIS no longer does tracebacks from SE food poisoning incidents to implicated flocks. Responsibility for the traceback program shifted to another USDA agency, FSIS, under the USDA Reorganization Act of 1994. One year later, in 1995, Congress cut funding for the program at the behest of industry groups. Since that time, the traceback function has been taken over by the FDA. As of December 1996, FDA had undertaken four traceback investigations.
The Pennsylvania Pilot Program:
A Successful Control Program Is Abandoned
In April 1992, USDA began a voluntary pilot program to control SE in Pennsylvania with the help of egg producers and state government agencies. The goal was to reduce SE contamination in shell eggs in Pennsylvania, a state that had been particularly hard hit by SE. The program contained the following requirements for producers:
USDA was supposed to monitor the program's requirement that eggs from contaminated flocks be diverted to pasteurization plants. USDA's Office of Inspector General found that USDA was failing in this regard. There were no shipping controls in place to ensure that eggs from infected flocks went to pasteurization plants. Two pasteurization plants were also selling fresh shell eggs, unaware that they were receiving eggs from known SE-positive flocks.
Even without full enforcement by USDA, the Pennsylvania program apparently reduced the incidence of SE in the flocks. When the program was implemented in 1992, multiple manure and other samples were taken from the houses of 70 laying flocks. In 1992, 38 percent of laying houses had at least one SE positive sample, but by 1995, only 13 percent of flocks had a positive SE sample. In 1992, 23 percent of all the samples taken tested positive for SE, down to only 3.2 percent of samples in 1995. Human illness from SE in the market area for Pennsylvania eggs (New York, New Jersey, and Pennsylvania) also decreased between 1992 and 1995. A team of 15 scientists from federal and state government agencies attributed at least part of this decrease to the Pennsylvania program and recently recommended that the interventions in the Pennsylvania program be implemented by all egg producers.
Despite the apparent success of the program, in 1995, Congress cut $3 million in funding for USDA's SE control task force, which included all funding for the Pennsylvania pilot program, after lobbying by the egg industry. USDA employees were prohibited from spending any time on the program. The program, now called the Pennsylvania Egg Quality
Assurance Program, is still operating on a voluntary basis in Pennsylvania, and about 85 percent of the state's producers participate. However, without federal involvement, the plan will not be expanded nationwide.
Failing to Stop SE at the Packing and Processing Stage: No Inspection for Safety
The spread of SE could have been slowed by more stringent inspection at the packing and processing level. Eggs that came from SE-infected flocks should have been diverted to pasteurization plants, rather than sold as shell eggs. Eggs that came from geographical areas with known high SE rates should have been sampled to determine if they contained SE.
Nevertheless, although three agencies have responsibility for inspecting eggs during processing, no government agency has been monitoring eggs for SE. In fact, even when USDA knew of SE-infected flocks in Pennsylvania, it continued to allow some eggs from these flocks to be marked "Grade A" and sold in supermarkets.
FDA occasionally inspects shell egg- packing plants and is responsible for moni-toring whether eggs are contaminated with SE. However, FDA's inspection resources are so limited that it inspects most food manufacturing plants under its jurisdiction an average of only once every ten years. (See Figure 5.) Ironically, USDA inspects egg plants much more frequently, but does not check for SE contamination.
USDA, through its Agricultural Marketing Service (AMS), provides a voluntary grading program for shell eggs that is paid for by participating producers. Approximately 40 percent of the nation's shell egg producers participate. The program grades eggs for quality, but does not inspect eggs to determine whether they are free of microbial contaminants such as SE. Participating egg-packing plants are inspected for sanitation and proper washing of eggs.
AMS is also responsible for the Shell Egg Surveillance Program. AMS inspectors visit shell egg plants four times a year to ensure that dirty eggs, cracked eggs, and eggs with blood spots are properly disposed of and are not sold to consumers in cartons. However, this program does not include testing eggs for SE and diversion of infected eggs to pasteurization plants.
Until November 1995, AMS was also responsible under the Egg Products Inspection Act for inspection of egg product plants, plants that produce liquid, frozen, or powdered egg products. While these products are generally pasteurized and pose little threat from SE, under the Act, AMS provided continuous safety inspection of egg product plants. Congress shifted the inspection of egg products to USDA's FSIS effective May 1995 and now FSIS conducts continuous inspection in these plants. In contrast, there is no continuous inspection in shell egg plants, or any safety inspection at all beyond FDA's infrequent visits.
Failing to Stop the Growth of SE During Transportation and Storage: Inadequate and Unenforced Refrigeration Requirements
Refrigeration requirements are a key element of any SE control program. If SE is present inside the eggs, refrigeration can help prevent the SE organisms from multiplying. To prevent SE growth, eggs should be refrigerated at an internal temperature of 45 degrees F or lower from the time they leave the farm until they reach the supermarket. However, the government agencies have been unable to provide a cohesive strategy for regulation of refrigeration temperatures during transportation and storage.
The way eggs are processed means that they often leave packing plants warmer than room temperature. They are washed in hot water, immediately placed in cartons, stacked in pallets of several dozen cartons, and then, frequently, shrink-wrapped in plas-tic. These industry practices make it difficult to cool eggs sufficiently, especially those eggs at the center of a pallet of cartons.
By a 1991 amendment to the Egg Products Inspection Act, Congress required USDA to issue regulations mandating that eggs be held under refrigeration at an ambient temperature of 45 degrees F after packing and during transportation. Ambient temperature refers to the tem-perature of the air in the area where the eggs are, not to the eggs' internal temperature.
Both USDA and FDA were given enforcement authority under this amendment. Although an internal temperature, rather than an ambient temperature, of 45 degrees F is necessary to prevent the growth of SE, many observers agree that the ambient temperature standard would be better than the complete absence of a temperature requirement, which is the current situation. After they leave the plants, eggs in some states can legally be shipped, stored, and displayed in supermarkets at room temperature.
In October 1992, USDA issued a proposed rule requiring storage and transportation of eggs at an ambient temperature of 45 degrees F, but never finalized it. FSIS, which was given responsibility for implementing the law when egg safety functions were transferred from APHIS to FSIS, believed that the ambient temperature at which eggs are kept is not the relevant factor in assuring the safety of eggs and declined to enforce the requirement.
Since 1992, USDA has never mandated either the 45 degree F ambient temperature or the scientifically superior internal temperature standard for the egg industry. To further complicate matters, yet another USDA agency has a conflicting temperature requirement based on quality, not safety considerations. The AMS voluntary grading service requires an ambient temperature of 60 degrees F or less in egg handling and storage areas. About 40 percent of the egg industry participates in this program.
The 1991 amendment also gave authority to FDA to ensure that food manufacturing establishments, institutions, and restaurants comply with the ambient 45 degrees F requirement. FDA does not inspect many of these facilities and has failed to enforce the Congressional mandate.
Failing to Warn Consumers of SE in Eggs at Supermarkets and Restaurants
Since the government has not taken steps on the farm, during processing, or during transportation and storage to prevent SE outbreaks, the last opportunity to prevent illness is to warn consumers not to eat raw or undercooked eggs. A warning label on egg cartons informing purchasers how to protect themselves could have prevented many illnesses and deaths. A government survey recently found that half of all consumers had eaten undercooked eggs in the last year. Despite this, the federal agencies have not taken critically needed steps to warn consumers of the risk of SE.
FDA, the agency with the legal authority to require egg carton labels, has required warning labels on foods with a far smaller public health impact than SE-tainted eggs, such as low-calorie protein products (60 deaths) and iron-containing products (3,210 illnesses and two deaths). Yet FDA has not taken the simple step of requiring a label on egg cartons, which could help to prevent the 200,000 to one million illnesses from SE each year.
In contrast, USDA issued a regulation requiring safe-handling labels on meat and poultry sold in supermarkets shortly after the 1993 Jack in the Box outbreak caused by tainted hamburger. Those labels have provided valuable information to consumers. One survey has shown that 66 percent of all respondents and 70 percent of parents with children under the age of 12 have noticed the safe-handling instructions. Another survey found that six out of 10 shoppers surveyed were aware of the safe-handling labels and that 43 percent of these shoppers had changed their meat and poultry handling practices as a result. The surveys show that labeling can be an effective way to provide food safety information to consumers.
FDA has also been ineffective in advising restaurants and other establishments on safe egg handling. FDA delayed for years publication of an updated version of its food safety recommendations for restaurants (known as the Food Code), so that safe-handling guidelines for eggs were not included until 1993. In the 1993 Food Code, FDA recommended that eggs (along with all other perishable foods) be refrigerated at an ambient temperature of 41 degrees F or lower. FDA also recommended that eggs be cooked to at least 145 degrees F, or that pasteurized egg products be used for uncooked foods or for highly susceptible populations. No warning against pooling eggs was included. FDA recommended that restaurants provide a consumer warning about the risk of eating undercooked animal foods, but no suggested language was provided, and the recommen-dation has been adopted by only a few states.
Both FDA and USDA's FSIS provide safe egg cooking advice to consumers. However, this information is generally available only upon request from the agencies. The recommendation given out on USDA's safe food-handling hotline is to cook eggs until the white is firm and the yolk is just beginning to set (and is no longer runny).
The history of the federal government's failure to curb the SE epidemic illustrates the ineffectiveness of having multiple government agencies responsible for regulating the same food. Instead of providing additional food safety protection, the numerous agencies charged with regulating eggs actually hindered each other in stopping the SE problem. The agencies did not identify which of them was responsible for controlling SE in eggs; they competed with each other instead of cooperating; and, when faced with decisions about how to regulate to solve the problem, chose the least protective approach. The agencies were further hamstrung by a Congress that cut funding for a control program just as it was beginning to show results and an industry that, except for producers in Pennsylvania, resisted attempts to prevent SE contamination on the farm.
Effective government action could have prevented many illnesses and deaths over the past twenty years and could prevent countless future unnecessary tragedies. To protect consumers from the hazards of SE, we recommend the following steps.
In a recently published report titled "Scrambled Eggs. How a Broken Food Safety System Let Contaminated Eggs Become a National Food Poisoning Epidemic", the Center for Science in the Public Interest (CSPI) has concluded that the leading cause of food borne illnesses in the United States is the egg. Using a combination of reported statements by "experts" and a variety of scientifically loose calculations, CSPI has made a number of statements which we believe are misleading at best, and simply wrong at worst. The following responses address some of the many debateable aspects of the report.
| CSPI says: "While Salmonella sometimes is present on the outside of egg shells, no one ever thought the inside of eggs could be contaminated by bacteria. It was a surprise when government scientists first linked human illness from SE to internally contaminated eggs in 1986. Since the early 1980s, the SE problem in shell eggs (fresh eggs purchased in cartons) has ballooned out of control. The Centers for Disease Control and Prevention (CDC) reported five times as many SE cases in 1995 as in 1980." | Truth is: Given the fact that internal contamination first appeared in 1986, it does not seem too surprising that the number of SE cases was higher in 1995 than in 1980 when there wasn't a SE problem. If one looks at the data for 1986 compared to 1980 it is clear that there was a three-fold increase and between 1986 and 1995 less than a two-fold increase. Data selection can make a large difference in interpretation of the findings and clearly CSPI has a greater interest in the more extreme examples. |
| CSPI says: "Hundreds or even thousands of people die from eating SE-tainted eggs each year." | Truth is: According to the document "Update on Salmonella serotype Enteritidis (SE) Infections" issued on 4/16/97 by the Centers for Disease Control and Prevention, "To date, 10 SE outbreak-associated deaths have been reported for 1995 and 1996." The data also indicate that in 1994 there were no reported SE-associated deaths. Seven of the deaths occurred in nursing homes. Hardly seems enough to be misinterpreted as hundreds or even thousands of deaths from eating eggs! |
| CSPI says: "SE is responsible for the lion's share of food poisoning illnesses, about a third of all food poisoning outbreaks where the cause is known." | Truth is: The graph that CSPI uses to document this one-third "lion's share" shows that 67% of food poisoning outbreaks were non-SE. Also note that this is "where the cause is known" which is often less than fifty percent of all outbreaks. |
| CSPI says: "A USDA survey showed that the frequency of SE isolates in unpasteurized liquid eggs nearly doubled in the northeastern and western U.S. between 1991 and 1995." | Truth is: One component of the Pennsylvania Pilot Project was to divert eggs from SE contaminated flocks to egg processing plants for pasteurization. Clearly it would be expected that the number of SE isolates at these facilities would increase. And once pasteurized, these products pose no risk. |
| CSPI says: "The first farms producing contaminated eggs were all located in the northeastern U.S. and with quick action, the problem might have stopped there. But the numerous federal agencies with oversight responsibilities for eggs didn't act. Instead they competed with each other, stumbled over each other, and ultimately backed down in the face of industry pressure." | Truth is: The egg industry worked with Congress in getting funding for the Pennsylvania Pilot Project and was instrumental in forming the joint project to determine what the SE problem was, the factors involved, and what preventive measures were effective in getting rid of SE. |
| Return
To Top CSPI says: "Congress passes law requiring egg refrigeration; USDA never enforces it." |
Truth is: The egg refrigeration legislation was initiated and strongly supported by the egg industry. Eggs sitting out at room temperature for a long time period is one of our biggest concerns, and unfortunately a problem beyond our control. |
| CSPI says: "Over 10,000 reported SE food poisonings for the year." [1995] | Truth is: There were 410 SE outbreaks reported between 1990 and 1996 of which only 131 were shown to have been egg-related. Not all SE food poisonings are egg-related. |
| CSPI says: "It is estimated that one out of every 10,000 eggs, or about 4.5 million eggs each year, are infected with SE." | Truth is: In 1995 and '96 there were roughly 55 SE outbreaks each year and some 50 to 60 billion eggs consumed. Another way to look at the data is that there was one outbreak per billion eggs consumed. Keep in mind that those 4.5 million eggs are only a problem if they are temperature abused by leaving out at room temperature for more than 2 hours, and then undercooked. |
| CSPI says: "The SE bacteria multiply inside eggs that are not properly refrigerated (to an internal temperature of 45 degrees F.)." | Truth is: The industry supports egg refrigeration laws. But why is it if 45 degrees F is effective in stopping SE growth does CSPI want national egg refrigeration laws at 41 degrees F? Most egg producers wanted the 45 degree law and have established facilities to meet the requirement. After years of setting these standards are producers now expected to change again? |
| CSPI says: "The elderly residents of nursing homes are especially at risk of death from SE: 85 percent of reported deaths from SE between 1988 and 1992 were from this group." | Truth is: And under virtually ever circumstance the problem was pooling eggs, temperature abuse and insufficient cooking. The egg industry has an active education program for institutional food services and strongly recommends that hospitals and nursing homes use pasteurized egg products. |
| CSPI says: "Eggs that came from geographical areas with known high SE rates should have been sampled to determine if they contained SE." | Truth is: The idea of sampling eggs is an interesting one since CSPI acknowledges that the incidence is only 1 per 10,000 eggs. How many eggs would one need to test to be assured that there were no false negatives? It certainly would take a lot of scrambled eggs to find that 0.01% of contaminated eggs. |
| Return
To Top CSPI says: "In 1992, 38 percent of laying houses (in PA) had at least one SE positive sample, but by 1995, only 13 percent of flocks had a positive SE sample." |
Truth is: And after the federal Pennsylvania Pilot Project ended, and was under industry and state supervision, the number of laying houses SE positive decreased to 7.5% in 1996. Doesn't this suggest that the egg industry can maintain an effective program? |
| CSPI says: "Both FDA and USDA's FSIS provide safe egg cooking advice to consumers. However, this information is generally available only upon request from the agencies. The recommendation given out on USDA's safe food-handling hotline is to cook eggs until the white is firm and the yolk is just beginning to set (and is no longer runny). " | Truth is: The American Egg Board and the Egg Nutrition Center provide a variety of egg safety brochures for both consumers and institutional food service organizations. The American Egg Board is an active participant in the SafeServe program and a member-contributor to the Partnership for Food Safety Education. |
| CSPI says: "The agencies were further hamstrung by a Congress that cut funding for a control program just as it was beginning to show results and an industry that, except for producers in Pennsylvania, resisted attempts to prevent SE contamination on the farm." | Truth is: The control program was the PA Pilot Project which by definition was a pilot project to determine effective means of reducing SE contamination. The findings from that project have been incorporated into industry HACCP programs. Rather than resisting attempts to prevent SE contamination on the farm, the industry has initiated HACCP programs including training programs for producers. The industry has committed substantial resources to establish national HACCP programs and these programs are being established. Maybe we just weren't fast enough in getting the more than 3,300 flocks nation wide under immediate control. |
Contrary to inaccurate and inflammatory statistics released 5/14/97 by the Center For Science in the Public Interest (CSPI), Salmonella enteritidis (SE) bacteria in eggs are not causing 'hundreds and possibly thousands of food-poisoning deaths each year.' According to the document "Update on Salmonella serotype Enteritidis (SE) Infections" issued on 4/16/97 by the Centers for Disease Control and Prevention, "To date, 10 SE outbreak-associated deaths have been reported for 1995 and 1996." This CDC document summarizes egg-related Salmonella outbreaks for the years 1995 and 1996. The egg is one of nature's most nutritious, economical and versatile foods. With proper care and handling, it poses no greater risk than any other perishable food.
The number of outbreaks linked to Salmonella contamination of shell eggs has steadily declined from a high of 77 in 1989 to 50 in 1996, according to John Mason, former director of the United States Department of Agriculture (USDA) Salmonella enteritidis (Se) Control Program that tracks Se outbreaks and their causes. According to Dr. Mason, the risk of contracting egg-related salmonellosis is extremely low for healthy individuals. "There is one outbreak for every 1 billion eggs consumed," he said. "The decrease can be attributed to better handling and proper cooking of eggs by foodservice establishments," said Dr. Mason. "Consumers can virtually eliminate the risk at home by cooking eggs properly." According to the American Egg Board, eggs should be cooked until the white is set and the yolk begins to thicken, but is not hard. Salmonella is destroyed when kept at a temperature of 140 degrees F for three and half minutes or if it simply reaches 160 degrees F.
Many egg producers have voluntarily instituted quality assurance and sanitation measures to control Salmonella at the farm level. Research supported by the egg industry, academia, Food and Drug Administration (FDA) and USDA is addressing the causes of Salmonella and the best way to control the problem. To minimize the risk of egg-related salmonellosis, consumers should follow these practices recommended by USDA, the FDA and the American Egg Board:
Buy refrigerated, grade A or AA eggs with clean, uncracked shells.
Copyright© 1997. Egg Nutrition Center. All copy and images.
Last updated 15 May 1997
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