Interpreting and enforcing the FDA Egg Safety Rule – there’s no need to be afraid!
Some of you may have heard about the recent draft guidance from the FDA regarding outdoor access for organic and pastured egg producers. There is a lot of misinformation about what this means for organic and pasture-raised egg producers, and we want to set the record straight.
This draft guidance was created in response to requests for clarification on how the FDA Egg Safety Rule applied to farms with outdoor access and pasture. Among other things, the Rule requires that wild birds (as well as cats and other animals) must be prevented from entering the poultry house, due to concerns that they might carry salmonella. There was a lot of confusion and concern about whether this extended to outdoor areas, as that would effectively mean that these types of systems would no longer be feasible. If it became both impractical and all but impossible to keep wild birds out of an outdoor based system, then farms using these systems would have to be closed.
We have made huge efforts to show the FDA the unique challenges we face in complying with their regulations. We’ve given them tours of our farms to show them how our systems are different from conventional agricultural systems and what we do to protect the safety of our eggs; had meetings with FDA officials to discuss solutions to these issues; and submitted comments to the federal register.
During every one of these meetings, both in Washington and on our farms, and in our writings, we have stressed to the FDA that we felt that the data from numerous independent studies, and from our own experience, has showed that well managed outdoor systems are simply not susceptible to salmonella outbreaks. Rather the true cause of salmonella outbreaks in poultry flocks is the deplorable, overcrowded conditions that attract high concentrations of rodents and flies, and with them, the passing of salmonella to the birds. We asked the question: are you more likely to get ill wandering in an open field or riding in a crowded bus or airplane? And we asked that the new rules not apply the same considerations, interpretations and enforcements to pasture and poultry houses systems.
Overall, we felt that our voices were heard. The draft guidance now clarifies that pastures are not considered part of the poultry house, and so are not subject to the same requirements. While they make recommendations for restricting access to wild birds etc, they stress that these are just suggestions. The FDA acknowledges that each system is unique, so producers must determine what works best for their own operation to effectively comply with the Rule.
We applaud this outcome-based attitude to a complex issue and the FDA’s willingness to work with the organic & pasture-raised egg producers to find a workable solution that protects food safety while letting our ladies live as naturally as possible!Jackie Sleeper is Vital Farms’ Director of Quality and Animal Welfare. Prior to Vital Farms, Jackie was Director of Certification with Humane Farm Animal Care (Certified Humane).