What the Egg Recall Says About Our Food Safety System

Cross-posted from The Pump Handle.

The Iowa-based company Wright County Egg is recalling 380 million eggs, which were sold to distributors and wholesalers in 22 states and Mexico, due to concerns about salmonella contamination. The eggs have been sold under several different brand names, so if you've got eggs in your fridge you can check FDA's page for info. Salmonella-infected eggs traceable to this producer may have caused as many as 1,200 cases of intestinal illness in at least 10 states over the past several weeks. A second producer, Hillandale Farms, has also issued a recall 170 million eggs that have been shipped to 14 states.

Before getting into what's wrong with our food-safety system, I want to note the recall might not have happened at all if it weren't for surveillance and investigation activities at the state and national levels.

Officials identified the problem because CDC's PulseNet network (whose participant labs perform molecular subtyping of foodborne disease-causing bacteria) identified a much larger than usual number of Salmonella Enteritidis isolates in the samples it received. Ordinarily, CDC gets an average of 50 reports of SE illnesses weekly, but it started receiving approximately 200 reports per week during late June and early July. Public health officials in California, Colorado, and Minnesota conducted epidemiologic investigations and found that shell eggs were the likely source of infection. FDA, CDC, and state partners then conducted traceback investigations and found that many of the restaurants and events where multiple people became ill with SE got their eggs from Wright County Egg.

Disease surveillance is rarely at the top of the priority list for states and federal agencies, and resources are often slashed during tough budget times. In fact, the New York Times recently reported that funding is being eliminated for CDC's vector-borne disease branch; this branch tracks diseases like dengue, which has recently been detected in Florida for the first time since 1934. Given that large outbreaks of foodborne illness have been alarmingly common over the past few years, FDA and CDC will probably continue their food-related investigation activities. Surveillance activities like PulseNet, though, rely on state and local health departments to perform molecular subtyping and submit those results to the national network - and in many states and localities, health departments lack sufficient funding. Lucky for us, some states have continued to fund the important work of detecting and investigating foodborne illness outbreaks.

So our surveillance and investigation system, while it could certainly use more resources, has managed to identify the source of this outbreak of SE illness. But as this and other recent foodborne-illness outbreaks demonstrate, the regulatory system that aims to prevent harmful bacteria from entering the food supply isn't equal to all the challenges of today's food-production system.

It's not as though food safety in this country is a complete disaster; most of us probably feel confident that the food we buy at the grocery store or a restaurant won't make us sick. CDC lists "Safer and Healthier Foods" as one of the Ten Great Public Health Achievements in the 20th Century. But widespread outbreaks of foodborne illnesses are happening with disturbing regularity - think of spinach, beef, peanut butter, and jalapeños in recent years.

The Institute of Medicine and National Research Council put out a report in 1998 about the US food safety system, and its findings still hold true today:

Summary Findings: The Current US System for Food Safety

• Has many of the attributes of an effective system;
• is a complex, inter-related activity involving government at all levels, the food industry from farm and sea to table, universities, the media, and the consumer;
• is moving toward a more science-based approach with HACCP Hazard Analysis Critical Control Point monitoring systems and with risk based assessment
• is limited by statute in implementing practices and enforcement that are based in science;
• is fragmented by having 12 primary federal agencies involved in key functions of safety: monitoring, surveillance, inspection, enforcement, outbreak management, research, and education; and
• is facing tremendous pressures with regard to:

-- emerging pathogens and ability to detect them; -- maintaining adequate inspection and monitoring of the increasing volume of imported foods, especially fruits and vegetables; maintaining adequate inspection of commercial food services and the increasing number of larger food processing plants; and -- the growing number of people at high risk for foodborne illnesses.

The pressures related to increasing imports and large food processing plants have probably grown even more intense over the past decade, as global trade has increased and trends toward greater consolidation in the food industry have continued.

At the root of the fragmentation issue is the fact that USDA and FDA share food safety responsibilities. Relative to FDA, USDA is well-staffed, and its inspectors make daily visits to slaughterhouses and to plants that produce processed food involving meats. USDA regulates the health of chickens, but not their eggs; FDA is responsible for eggs, and pretty much all other food. Critics of the current food system often point out that USDA is responsible for the safety of frozen pepperoni pizzas, while FDA is responsible for the safety of frozen cheese pizzas.

The Washington Post's Lyndsey Layton points out that Congress and FDA have been working to address FDA's food safety shortcomings and the issue of eggs in particular:

Although it has broad authority to regulate the production of food, the FDA historically has inspected egg-laying facilities only if it suspected contamination, said FDA Associate Commissioner for Food Protection Jeff Farrar. That is likely to change under a new agency rule that took effect in July. And food safety legislation pending on Capitol Hill would require the FDA to routinely inspect high-risk food facilities, including henhouses.

... Under legislation that has passed in the House and is expected to be taken up by the Senate in September, the FDA would be required to visit Wright County Egg and other similar producers annually. It would have access to internal company documents that show results of microbial testing and the company would be required to adopt a strategy to prevent contamination and prove that it follows the strategy. The bill also would require companies to keep uniform distribution records, making it easier and faster for the FDA to track contaminated food.

The current outbreak started before the new egg rule took effect, but it might help to prevent such outbreaks in the future. It requires egg producers to follow specific requirements - including pest control and Salmonella monitoring - to prevent Salmonella contamination. However, even the most stringent rules won't ensure a safe food supply if producers are in the habit of breaking them.

The New York Times' William Neuman reports that Wright County Egg owner Jack DeCoster is "well known to federal regulators" for past violations:

In 1997, one of his companies agreed to pay a $2 million fine by the Occupational Safety and Health Administration for violations in the workplace and worker housing. Officials said workers were forced to handle manure and dead chickens with their bare hands and to live in trailers infested with rats. The labor secretary in the Clinton administration, Robert B. Reich, called Mr. DeCoster's operation "an agricultural sweatshop."

Mr. DeCoster's facilities have also been periodically raided by immigration officials. In 2003, Mr. DeCoster pleaded guilty to charges of knowingly hiring immigrants who were in the country illegally and he paid more than $2 million as part of a federal settlement.

Mr. DeCoster was also charged by Iowa authorities in the 1990s with violations of environmental rules governing hog manure runoff.

If our food safety system is going to be strengthened to meet the demands of a changing food landscape, we're going to have to make it more likely that food producers who break the rules will be caught and stopped before they cause outbreaks of foodborne illness. That will probably require giving FDA (or another agency, if we decide to put all food safety responsibilities under a single one) more enforcement resources.