People are urged to write (hard copies only) to the FDA to oppose the
irradiation of eggs. They should ask that implementation of the new
egg irradiation regulation be delayed and that a public hearing be
held. Deadline for letter is August 21. Address must be exactly as
below. Docket No. must be included at the beginning of letters so
letter will be counted. "Comments" means a 1-page substantive
letter, i.e. not just a sentence or two. Our reasons for opposing egg
irradiation are below. They can be formulated in people's own words
more briefly. No need for end notes. Karen
Dockets Management Branch |
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville, MD 20852
| Docket No. 98F-0165 |
August 1, 2000
Re: Irradiation in the Production, Processing and Handling of Eggs
United Poultry Concerns appreciates this opportunity to submit
written objections and to request a hearing concerning the Food and
Drug Administration's decision to legalize the irradiation of eggs.
On behalf of our 10,000 members nationwide, United Poultry Concerns
requests that implementation of the new regulation be delayed and
that a public hearing be held.
Our objections focus on the fact that the irradiation of eggs is an
intervention strategy which fails to address primary causes of
Salmonella enteritidis- contaminated eggs. Irradiation falsely
implies that eggs are inherently unwholesome products that can only
be made "clean" and "safe" by complicated nutrient depleting
technologies like irradiation. In reality, (a) hens' eggs have
virtually full-proof many-layered barriers against pathogens given
that, in nature, hens' eggs are intended to hatch healthy chicks
(CDC, 1990; Davis, 1996); and (b) chronically stressed,
immunocompromised hens are laying contaminated eggs for human
consumption in crowded, filthy buildings and are subjected to a
variety of disease-inducing practices including stressful lighting
programs and the intentional starvation of the hens known as forced
molting. These practices impair hens' immune systems, predisposing
them to Salmonella infection. Irradiation masks these primary causes
of Salmonella enteritidis (SE) in eggs, and, we are assured, it won't
even do that.
Short Background: Salmonella enteritidis has pathologically migrated
from hens' intestines to their oviducts where it can be an
infectious ingredient in eggs as they are being formed inside the
Crowded concentrations of hens in confinement during the past 40+
years is linked to the fact that a specific type of Salmonella
-Salmonella enteritidis- has developed that can live not only in the
intestines but in the ovaries and oviducts of hens used for egg
production. SE infects eggs as they are being formed inside the hen
(CDC, June 8, 1990). According to Avian Diseases (1996), "Although
salmonellas are widespread in nature, the intensification of
livestock production has led to an increased risk of clinical and
subclinical salmonella infection. The pyramidal structure of the
poultry industry has provided an opportunity for dissemination and
persistence of Salmonella enteritidis, particularly phage type 4,
which has resulted in an epidemic increase in human salmonella food
poisoning cases caused by consumption of egg or poultry meat
products" (Davies and Wray, 1995).
Objections to Irradiation of Eggs
Both government and industry point out that irradiation of eggs
cannot substitute for sanitation, or for recommended packaging,
refrigeration, cooking, and serving of eggs. "Irradiation of fresh
shell eggs at the doses requested in the petition will reduce, but
not entirely eliminate, microorganisms in eggs," according to the
Federal Register, July 21, 2000. Moreover, these microorganisms can
grow back from a few to many despite radiation. Notwithstanding,
irradiation has been approved as a compensation for poor sanitation
and pathogen-promoting economic practices at the farm level and as a
compensation for the fact that hens used by the egg industry are
pathologically susceptible to infected ovaries and oviducts from a
microorganism whose normal habitat is the intestinal tract. It
appears that for the egg industry, an attractive feature of
irradiation is its ability to extend the shelf life of eggs by
reducing bacterial spoilage. I.e., old, irradiated, vitamin-depleted
eggs can sit there a week or so longer with "fresh" stamped on the
carton. Meanwhile, the most targeted pathogen, SE, has been shown to
be the most irradiation resistant type of Salmonella (Brown, 1994)
following exposure to approved levels of radiation of meat and eggs
up to 3.0 kiloGrays (kGy).
Filthy Laying Environment This filth includes not only the manure
dripping down and encrusting the bars of the wire cages and piling up
in the pits beneath the cages. It includes the toxic excretory
ammonia gases from the decomposing uric acid in the manure - gases
that can range dangerously between 60 and 200 ppm in crowded chicken
houses (Davis, 1996). The high levels of ammonia not only permeate
egg shells; they predispose the hens to immunosuppression and to
airborne pathogens including Salmonella as a result of the excessive
mucous that accumulates in the birds' trachea in response to the
ammonia overload. Irradiation ignores the disease-producing filth and
toxicity in the hens' environment that predispose them and their eggs
to Salmonella enteritidis in the first place (Davis, 1996).
Stressful Lighting Programs
Fifty-two weeks of 15-17-day lighting schedules (mimicking the
longest days at the peak of summer) force commercial laying hens to
lay an abnormally large number of eggs based on the fact that, in
nature, egg-laying is hormonally synchronized with the lengthening
and shortening of days North & Bell, 1990). The harsh artificial
lighting schedule is a primary cause of immunosuppression in the
hens, making them susceptible to Salmonella infection (Smith, 1994).
Irradiation does not address this immunosuppressive,
pathogen-inducing practice but, rather, encourages it to continue.
Forced Molting (Prolonged Starvation of Hens)
Forced molting is a starvation practice employed by the US egg
industry to manipulate egg laying and the economics of production. It
involves the removal of ALL food from hens used for commercial egg
production for 5 to 14 days (typically 10 to 14 days) to manipulate
the hormones responsible for egg production and feather cover. Forced
molting is designed to force the birds to lose 25 to 30 percent of
their body weight, particularly the abnormal fat which accumulates in
their oviducts from lack of exercise and related stresses of
confinement (Davis, 1996; United Poultry Concerns, Petition to FDA
[Docket No. 98P-0203/CP1], April 14, 1998).
According to the US Department of Agriculture, "[E]xtended starvation
and water deprivation practices lead to increased shedding of
Salmonella enteritidis (Se) by laying hens subjected to these
practices" (Stolfa, August 21, 1998). USDA further states: There is
epidemiologic evidence which associates [forced] molting with higher
prevalence of SE in flocks. Molted SE-positive flocks also seem to
produce SE-positive eggs more frequently than their non-molted
counterparts. Experimentally, Holt et al. (1996, 1995. 1994, 1993,
1992) have demonstrated that molting is associated with increased
numbers of SE in hens' intestinal tracts, and higher rates of
SE-positive eggs are produced following molt. Schlosser et al. (1995)
demonstrated similar results in a field study during the Pennsylvania
Pilot Project. In that study [which comprised 31 flocks from May 1,
1992 to May 1, 1994] molted flocks produced SE-positive eggs twice as
frequently as non-molted flocks for a period up to 140 days following
molt (Salmonella Enteritidis Risk Assessment-Shell Eggs and Egg
Products, June 12, 1998; Aug. 10, 1998, p. 40).
In April of 1998, United Poultry Concerns and the Association of
Veterinarians for Animal Rights filed a Citizen Petition with the
Food and Drug Administration (Docket No. 98P-0203/CP1) requesting the
FDA to prohibit forced molting based on the FDA's authority to
prohibit farming practices that have been shown to harm human health.
Forced molting has been shown in both laboratory and field studies to
increase hens' susceptibility to Salmonella enteritidis infection.
Yet despite scientific documentation showing the link between forced
molting and SE infection of hens and their eggs, including the USDA
Farm Animal Well-Being Task Group Meeting documents of July 21, 1998,
obtained by United Poultry Concerns through a Freedom of Information
Act request, the FDA has failed to take action (Troxell, September
Instead, the Food and Drug Administration has ignored our Citizen
Petition, while granting Edward S. Josephson's petition to irradiate
eggs, although, according to a News Release published by the health
research group Public Citizen, on July 24, 2000, radiation
"treatment" of eggs will deplete vitamins, disrupt proteins, and mask
factory farm filth. Public Citizen says in its News Release that "The
request to irradiate eggs was made by Edward Josephson, who during
the 1960s and 1970s oversaw the U.S. Army's food irradiation
headquarters in Massachusetts, where dozens of studies revealed
serious health problems in lab animals that ate irradiated food,
including premature death and cancer."
Public Citizen is challenging the Food and Drug Administration's use
of three laboratory rodent studies which the FDA says satisfied the
agency that the petitioned use of irradiation on fresh shell eggs
"raises no toxicity concerns" (Federal Register, July 21, 2000, pp.
45280-82). Public Citizen indicates otherwise.
United Poultry Concerns requests the FDA to delay implementation of
the regulation and to hold a public hearing on the agency's decision
to legalize the irradiation of eggs. We object to the fact that the
FDA refuses to regulate practices that predispose hens and their eggs
to SE in the first place, while telling consumers that, for example,
vitamin depletion in eggs can be made up for in other foods, when, in
fact, an increasing number of other foods are being irradiated and
are thus similarly nutritionally compromised. In addition to the
filthy buildings in which the eggs destined for irradiation are laid
by Salmonella-disposed, inhumanely treated hens, irradiation will be
added to these eggs, along with vitamin depletion and unappealing
visual and textural characteristics. All this, plus all those "little
changes" in the fatty acids, "structure," "digestibility," and
"biological value of protein" noted in the Federal Register notice of
July 21, indicates that a public hearing should be held as soon as
possible to discuss the synergies and implications of all these
"little changes." Concern is serious given the fact that irradiation
will not reduce the need to treat eggs like Salmonella-contaminated
products that can cause acute illness, chronic arthritis, and other
systemic degenerative diseases and possibly fatal illnesses in
babies, in the growing population of elderly people, and in the large
number and diversity of people of all ages with susceptible immune
systems (CAST, September 1994).
Brown, R. Irradiation to be discussion topic at poultry exposition.
Feedstuffs. Dec. 12, 1994:17, 25.
CAST (Council for Agricultural Science and Technology). Sept. 1994.
Foodborne Pathogens: Risks and Consequences.
CDC (Centers for Disease Control). June 8, 1990. Questions and
Answers About Salmonella enteritidis and Eggs. Memorandum To the
Davies, R.H. and C. Wray. 1995. Studies of Contamination of Three
Broiler Breeder Houses with Salmonella enteritidis Before and After
Cleansing and Disinfection. Avian Diseases 40:626-633.
Davis, K. 1996. Prisoned Chickens, Poisoned Eggs: An Inside Look at
the Modern Poultry Industry. Summertown, TN: The Book Publishing
Federal Register, July 21, 2000. Irradiation in the Production,
Processing and Handling of Food. DHHS-FDA. 65.141:45280-45282.
North, M.O. and Donald D. Bell. 1990. Commercial Chicken Production
Manual, 4th Ed. New York: Van Nostrand Reinhold.
Public Citizen. July 24, 2000. News Release: Radiation "Treatment" of
Eggs Will Deplete Vitamins, Disrupt Proteins, Mask Factory Farm
Stolfa, P. August 21, 1998. USDA-FSIS. Letter to Karen Davis.
Troxell. T.C. DHHS-FDA. September 30, 1999. Letter to Karen Davis.
United Poultry Concerns and the Association of Veterinarians for
Animal Rights. April 14, 1998. Advance Notice of Proposed
Rulemaking: Egg Safety From Farm to Table. Citizen Petition to the
Food and Drug Administration. Docket No. 98P- 0203/CP1.
USDA Farm Animal Well-Being Task Group Meeting, July 21, 1998.
USDA-FSIS. Salmonella Enteritidis Risk Assessment-Shell Eggs and Egg
Products. Final Report. June 12, 1998; August 10, 1998: 40.
United Poultry Concerns, Inc.
PO Box 150
Machipongo, VA 23405-0150
(Action Alert - Tell FDA to Oppose Egg Irradiation)