United Poultry Concerns October 10, 2000
UPC Comments To FDA Regarding Salmonella Enteritidis
FDA DOCKET NO. OON-1460

UNITED POULTRY CONCERNS, INC
PO BOX 150
MACHIPONGO, VA 23405
757-678-7875
FDA DOCKET NO. OON-1460
OCTOBER 10, 2000

United Poultry Concerns takes this opportunity to submit Comments regarding the Salmonella Enteritidis Research Public Meeting of September 8, 2000 in Atlanta, Georgia. United Poultry Concerns president, Dr. Karen Davis, registered for and participated in the meeting. One focus of the meeting was the effect that forced molting (via starvation of hens for an average of 10 days and for as long as 14 or more days) of laying hens has on the occurrence of Salmonella Enteritidis (SE) in the hen, her ovaries and oviducts, her eggs, and in the laying houses. Peter Holt, Agricultural Research Service, summarized his decade of research showing causality between food withdrawal and SE in the hen, her reproductive system, her intestines and other internal organs, her eggs, and the layer facility. He stated that his published papers described pathologic changes in experimental birds only, and that he was not extrapolating from the laboratory to the field (the breeder and commercial houses). He said this although in a paper dated July 2, 1998, "The Effects of Induced Molting On the Severity of Acute Intestinal Infection Caused by Salmonella Enteritidis, Holt and ARS colleagues state unequivocally: "These [experimental] results are important to the layer industry since they show that a prevalent industry procedure has a substantial effect on the severity of an SE infection and these effects are observed early in the disease process."

The researchers at the meeting sounded the theme of "more research is needed" claiming that "research gaps" exist with respect to commercial (and breeder) laying environments ("the field"), which, in reality, are most likely to be even more infested with SE than the laboratory, because of the conditions that prevail in these environments (filth, manure pits, severe overcrowding, toxic ammonia, airborne dander, dust, microorganisms, etc).

For the public record, United Poultry Concerns has submitted many detailed comments to the FDA over the past two years. In particular, see our April 1998 Citizen Petition (Docket No. 98P-0203/CP1), and our August 14, 2000 submission regarding "Current Thinking Papers on the National Standards for Egg Safety" (Docket No. 00N-0504).

We are not going to reiterate the information contained in those documents other than to point out that Dr. Charles Beard (ARS, US Poultry & Egg Association) told the audience at the AVMA Symposium on Poultry Management and Production, July 11, 1999, in New Orleans, that "no field studies have been done on the link between SE and induced molting," when in fact, he knew when he said this that the USDA had collaborated with the Pennsylvania Department of Agriculture in a two-year study of thirty-one flocks of hens, between 1992 and 1994, which "demonstrated that molting is associated with increased numbers of SE in hens' intestinal tracts, and higher rates of SE-positive eggs are proceeded following [the forced or 'induced'] molt" ("Salmonella Enteritidis Risk Assessment-Shell Eggs and Egg Products," 1998).

All available evidence, including decades of food deprivation research with mammals and birds (including but not limited to chickens) shows that food deprivation (as opposed to hibernation and other natural behavior of species)) weakens the animal's immune system and thus makes the animal susceptible to systemic and transmittable diseases. If the Food and Drug Administration truly had the public interest in mind, the agency would err on the side of caution by immediately prohibiting the inhumane egg industry practice of depriving hens of sustenance for days and weeks at a time for strictly economic purposes. Instead of this logical, publicly responsible action, however, the FDA has opted to use public tax money to pay researchers to do more "studies" to fill "gaps." (No end in sight.)

At the September 8 meeting in Atlanta, it was noted by panelists that oversight at farms ("in the field") is a huge problem because of all the variables, egg company reluctance to have the research conducted on their farms, and so on. It is significant that although the causality between SE and forced molting has been reported and acknowledged in Egg Industry magazine, avian disease and poultry science journals, and elsewhere for at least a decade, there is no consistent government (USDA, FDA) oversight of henhouse farms, and there was said to be "no test whatever to determine whether on-farm [SE reduction] practices are working."

To conclude: United Poultry Concerns perceives that the Food and Drug Administration has priorities that supercede the agency's mandate to protect public health when it comes to economic practices linked to SE in hens, eggs, hen houses, and consumers. For every "gap" there is a convincing mountain of substantive evidence that causally links forced molting and SE. A responsible Food and Drug Administration would ban forced molting immediately, future studies or not, rather than continue to place at risk a USDA-projected 2.1 percent of the U.S. population (approximately 6,300 individuals minimum), allow conditions to persist at the farm level that will continue to make babies, elderly people, and others sick and miserable, cause a certain number of these people to die prematurely, and increase the risk of "horrible infections including septicemia and deeper tissue infections reported in people who have been infected with SE" (stated by one of the speakers, seemingly Charles Beard, according to our notes taken at the Sept 8 meeting).

Karen Davis, PhD
October 10, 2000
President
Docket No. 00N-1460
United Poultry Concerns, Inc.
PO Box 150, 12325 Seaside Road
Machipongo, VA 23405-0150
Tel: 757-678-7875
Fax: 757-678-5070
Email: Karen@upc-online.org
Web Site: www.upc-online.org


United Poultry Concerns, Inc.
PO Box 150
Machipongo, VA 23405-0150
757-678-7875
FAX: 757-678-5070
www.upc-online.org

(UPC Comments To FDA Regarding Salmonella Enteritidis)