Dishrag Diaries

Here are my final thoughts on eggs (for a bit, anyway), particularly regulation and it’s effects on egg safety. I’d like to share three real-life stories with you.

The Infamous Egg Recall

On December 11, 2010, The Washington Post reported on the oversights that led to the recent Salmonella outbreak which sickened 1900 and led to largest recall of eggs in our nation’s history. Interestingly, the close of the article seemed to imply that further regulation would be a good way to make our eggs safer, which led me to wonder if the author ought not go back and read the first 90% of his article again. But, anyway, let’s look a few interesting quotes from the article:

* “(T)he $4.4 billion egg industry had been seeking mandatory rules for years, despite the red tape and extra costs.” Wow. That is so nice of them to put worries about our safety before worries about “extra costs.” Or, wait a minute… is there another reason?

As Susan Dudley, administrator of the Office of Information and Regulatory Affairs at the Office of Management and Budget (OMB) from 2007 to 2009 (who was opposed to regulation based on her agency’s cost-benefit analysis), said, “One needs to be skeptical when an industry seeks regulation, because it often confers competitive advantage. It could be over other companies or over international firms. And it often raises costs and it’s consumers who get hurt.” The George W. Bush administration “repeatedly expressed concern that the rules could hurt small businesses and end up dictating how Americans should eat their eggs” and “was concerned that federal rules would devastate small farmers without substantially reducing illnesses.”

Yet “United Egg Producers wrote to OMB, reiterating support for federal action and lobbying to shape any impending rules.” (Emphasis mine.) The result of this selfless offer of help? The OMB officials had to insist that the rules be reworked to prevent harm to small businesses…” (My emphasis again.) (And if you’re thinking, ‘Surely it’s easy to exempt small producers,’ make sure to read to the end.)

* “The threat of salmonella-tainted eggs did not exist a generation ago.” But in the 80s, a new strain of salmonella emerged which was egg-specific, being passed from the ovaries of infected hens. (If only there was some way to raise hens that would keep them healthy!) This strain lives inside the egg and can’t be washed off.

* “There are more than 15 federal agencies and 71 interagency agreements dealing with food safety.” You can imagine the turf wars! As this year’s egg crisis emerged, the government focused on ways to handle and prepare eggs. The USDA and FDA disagreed on how to go forward, and so each agency deployed economists, scientists, lawyers and policymakers. “Their rivalry to become the top agency (emphasis mine) was so intense, they refused to share their plans with each other until they were made public,” despite formal agreements pledging to share information and work together. In fact, from May until August, “USDA officials did not pass along to FDA concerns about sanitation problems that they had noted repeatedly in the packing houses at Wright County Egg” (all emphases mine), one of the two Iowa egg farms who drew most of the blame for the outbreak. On daily reports: dirty equipment, unsanitary cooler and storage areas, and the presence of bugs, among other deficiencies. Farm workers would correct the issues and the USDA would continue grading. But some of those eggs contained salmonella, and were shipped by the thousands to retailers and restaurants across the country.

“(O)fficials have pledged yet again to try to bridge the gaps between agencies.” Oh, good. That will probably work.

* “When FDA inspectors paid their first visit to Wright County Egg after the outbreak, they found henhouses bulging with manure, mice and other hazards that can spread disease.” Oh when, oh when are we going to get this poor egg industry their requested regulation so they can somehow figure out what is and isn’t good for the health of hens?

Some of the main concerns about government food-safety regulations: Whether they work, and the Whys and Whos of their creation. But another big concern is their effect on small producers. Let’s look at another real life situation.

One Farmer’s Story

(All information in this section is based on, and largely quoted from, chapter six of Everything I Want to Do is Illegal, by Joel Salatin – A must read, particularly in regard to government regulation. You will be challenged, regardless of your political persuasion!)

Some background: Salatin’s farm, Polyface, had supplied eggs to a local restaurant that had a salmonella outbreak. The health department ignored the fact that the raw Hollandaise sauce had been left on the counter for five hours, that the restaurant was full of raw seafood and meats and fresh garden produce with dirt dangling from the roots, and had cleanliness issues. Instead, they saw farm-fresh eggs in the cooler and immediately determined that they were the culprit. The chef called to alert Salatin, who immediately went to the field and collected both fecal samples and eggs, and sent them to an accredited lab for Salmonella analysis, at his own cost of $200 for the four samples. A couple of days later, Salatin received an expected visit from USDA inspectors.

They asked for a sample of 100 eggs and began looking for “adhering dirt,” which means anything that could be physically scraped off, such as “egg yolk from a broken egg, manure, a piece of straw from the nest box, a feather, or even a piece of cardboard from the egg carton.” When they were done, the inspectors determined that two out of the 100 eggs had adhering dirt, and so those eggs were illegal to sell. “They were, in fact inedible, which is the operative term for eggs that do not pass. Inedible eggs are illegal to sell.” Salatin writes, “We were, in fact, criminals.”

“To help set the stage, keep in mind that [Salatin] do[es] not like to wash eggs if they are clean. When a hen lays an egg, she coats it with a shiny film that acts as a bacterial protection. It also reduces evaporation from the porous shell. If the egg is clean, it’s clean…” and you want to leave that protective film on if at all possible. Customers often ask for unwashed eggs, knowing that the film will be intact.

Back to Salatin’s story: Joel now had 1200 eggs that had just been deemed inedible. He asked the inspectors what to do, and they recommended they he go through them, clean them well, and be ready for a re-inspection. The inspectors did return, gave a cursory glance and “[s]uddenly the eggs were edible again.”

“The important thing to understand here is that nobody checked the inside of the egg. When a carton of eggs says “Grade A Large” [which indicates the eggs have been candled - a process by which ultra-bright light is used to look inside the egg] and has that identifying USDA shield on it, nothing about that inspection checks the inside of the egg. Nothing checks for the things that can hurt people. The inspection only deals with visually observable qualities: exterior shell and interior air space, thickness and blood spots. Blood spots don’t hurt anyone; they are just yucky to see when you’re eating an egg…

“The point is that anything that could make you sick is never part of the grading system. People put a lot of credence in a system that excludes the most important part. This is typical of the inspection system: it checks for the least important things and doesn’t check for the most important things.”

A few days later (two weeks after the initial phone call), the lab analysis arrived. Salatin was elated to find no traces of Salmonella were detected, even in the manure. Knowing that his eggs had NOT caused the Salmonella outbreak, he “eagerly waited to hear from the health department’s findings.” After another week of not hearing, he contacted the health department himself and inquired after their lab cultures and their findings. The health department response: “We didn’t culture anything… cultures don’t mean anything… Culturing your eggs or the sauce would have been meaningless.” (Emphasis mine, because, really, does that make any sense?) The conversation continued:

Salatin: Well, if you didn’t culture anything, how do you know it was our eggs then? After all, you did put our eggs in the report.

Health Department Lady: When I saw unwashed eggs, I knew that was the culprit because this strain has been found on unwashed eggs.

Salatin: Only on unwashed eggs, or other things, too?

HDL: Other things, yes, but also on unwashed eggs.

Salatin: Then how do you know it was our eggs? Maybe it was something else.

HDL: This was my determination.

Salatin: The owner-chef told me it could have been any number of things.

HDL: Unwashed eggs are inedible… Look, consumers expect that their eggs are washed. In my opinion, an unwashed egg is inedible.

Salatin then advised her of his lab results, but continued to receive the reply that unwashed eggs were inedible. (Interestingly, in France, you can’t sell a washed egg. “If it has to be washed, it must go into a pasteurized product in liquid form. Only unwashed eggs are legal to sell as shell eggs.”)

In this chapter, Salatin describes a nearby commercial egg farm’s washing technique:
This was a typical battery caged setup with 50,000 birds in one house adjacent to the packing house. The chickens would lay the eggs on the floor of their wire cage (9 birds in a 16 inch x 22 inch cage) which slanted toward a rubber belt conveyor. The conveyor delivered the eggs straight into the processing facility. No nest, no straw, no privacy. A gentle amalgamation technique pushed the eggs onto little rollers that carried them first into a hooded washing machine. A 100-gallon reservoir held the wash water and it sprayed over the eggs while little brushes wiped the eggs as they rolled along. Amazingly clever – and stinky. A clean batch of wash water contained soap and tons of chlorine. As the eggs came along, of course, some would break. Shortly, the water turned yellow. Of course, manure built up in the water as well. Before long, what started as a nice pristine-looking heavily-chlorinated dish water became a putrid, smelly hot shower of yellow sulfur-smelling manure-laden gunk spraying over the eggs. And it stunk to high heavens. Remember, eggshells are porous. A tiny bit of that cleaning liquid permeates the egg.

He shared the above information with the health department official as well. “She refused to acknowledge that an egg could be clean otherwise, and refused to discuss the aforementioned fecal cleansing method. Although she admitted that the regulations did not require washing, she simply sniffed and said, ‘An unwashed egg is inedible.’ ”

A little addendum to this story is that about a year later, Smithsonian Magazine featured Polyface in a piece which included interviews with some of the chefs who choose Polyface products, including their pastured eggs. The very same health department official went to the three restaurants interviewed, “actually carrying [the article] under her arm” and “threatened to close them down if they did not immediately discard [Polyface] eggs. What’s a chef supposed to do? Our culture has been conditioned to believe the government bureaucrat who captures the headlines with: ‘Eggs served at local restaurant pose health risk. Ordered to destroy allegedly inedible eggs.’ ”

One of many examples of bureaucratic vendettas which can hurt local farmers.

But Aren’t They Exempt?
A Look at the So-Called Food Safety Act

You know a bill isn’t something the American people want when it has be renamed, hidden among unrelated legislation and passed in secret while everyone else is busy with Christmas. And yet that’s what brings us to the passage of H.R.2751, formerly a ‘Cash for Clunkers’ bill which was amended to replace the language with what was formerly S.510, the FDA Food Safety and Modernization Act. Among the groups opposed to the Act were the Weston A. Price Foundation and the Farm to Consumer Legal Defense Fund. Below are the talking points from FTCLF:

• The FDA Food Safety Modernization Act is fundamentally flawed and is not in the best interest of small farmers, especially those who produce raw milk. The Act is a major threat to the local food movement.

• FDA does not respect individuals’ rights to obtain healthy, quality foods of their choice. The agency has stated as a matter of public record that: “There is no absolute right to consume or feed children any particular food” and that citizens do “not have a fundamental right to obtain any food they wish.”

• As the FDA has participated in armed raids on small-scale co-ops and membership organizations, this agency should not be given any additional power.

• FDA has adequate powers under existing law to ensure food safety and effectively deal with foodborne illness outbreaks. FDA has power to inspect, power to detain product and can readily obtain court orders to seize adulterated or misbranded food products or enjoin them from being sold. The problem isn’t that FDA needs more power; it’s that FDA does not effectively use the power it currently has. The agency has power to inspect imported food yet inspects only 1% of food coming into this country from outside our borders.

• The Act does nothing to address many significant food safety problems in this country, such as those resulting from confined animal feeding operations (CAFOs), genetically modified organisms (GMOs), and various contaminants (e.g., BPA, pesticides, herbicides, etc.).

• FDA has used its existing power to benefit the pharmaceutical and biotechnology industries at the expense of public health (e.g., allowing the overuse of antibiotics in confined animal feeding operations and refusing to require labeling for genetically-modified foods). This Act does not address the fundamental problems at this agency in order to truly protect public health.

• The Act will expand FDA’s involvement in regulating food in intra-state commerce, further interfering with local communities. State and local governments are more than capable of handling any problems related to food in intrastate commerce. All the major outbreaks of foodborne illness involve either imported food or food in inter-state commerce.

• The Act will hurt our ability as a nation to be self-sufficient in food production because it has more lenient inspection requirements for foreign than domestic producers creating an unfair advantage for food imports. Giving an advantage to foreign producers will only increase the amount of food imported into this country that does not meet our domestic standards. The Act does not address food security–the ability of a country to produce enough food to meet its own needs.

While opposing the bill in its entirety, groups such as these attempted to ease the burden the bill would lay on the shoulders of small farms and local producers by fighting for the inclusion of Tester-Hagen amendment. The approved version of the bill did include this amendment. So small farmers are safe right? As usual with government regulation, it’s not quite that easy. Let’s take a look at a practical example of how this all will work, courtesy of this Activist Post (the emphasis below is, once again, mine).

If Grandma wants to sell her famous raspberry jam at the county fair (within 275 miles of her canning kitchen) she will indeed be qualified for small producer exemptions, but not before she forks over 3 years of financials, documentation of hazard control plans, and all local licenses, permits, and inspection reports. She must submit this documentation to the satisfactory approval of the Secretary; and if she fails to do so, the entirety of S.510 can be enforced on her.  That’s hardly what I would call an exemption.

Because small producers are being forced to jump through stringent local and Federal regulatory hoops just to qualify, the bill appears to be designed not to make it “illegal” to sell homegrown goodies, as some suggest, but to make the system so cumbersome that small producers will say forget it and give up their local food business — which is what many… have speculated is the hidden corporate agenda of the bill.

Forget the alarmist claims made by S.510 critics for moment.  The one thing this bill will undeniably do is squeeze the little local guy out of the food industry through excessive regulation — regardless of the political backslapping or media joy over bipartisanship and propaganda over “exemptions.”  The bottom line is that it’s common sense that local organic farmers produce a healthier and more nutritious product than their factory-farm counterparts, yet it is those promoting health who will suffer the most under this food “safety” bill.

Enjoy Your Farm-Fresh Eggs While You Can:
Some Ideas

Time will tell what effects recent and future regulation will have on local food sources. For now, get the healthiest eggs you can. Here are some great ways to enjoy them:

• Homemade mayo, and then ranch or egg salad.
• Quiche. I enjoyed this recipe recently for Crab and Swiss Quiche. (I used the no-roll crust, simply substituting sprouted flour.)
• I made this Breakfast Casserole for Christmas Day. Also try French Toast Frittata for breakfast.
• Egg Nog, Vanilla Steamers, Hot Chocolate.
• Smoothies. Figure out your own favorite blend using pastured egg yolks, coconut oil, raw milk and cream, raw yogurt, fresh or frozen fruit, raw honey, vanilla, soaked or homemade peanut butter (or other nut butter), real maple syrup… What’s your favorite mix? A great idea from Kelly the Kitchen Kop: Freeze your smoothie leftovers in popsicle containers. Another great idea: Use your clabbered milk in your smoothies!
• Omelets. My two favorites are Mexican omelets (make eggs with a little homemade taco seasoning, then add salsa and cheese, and maybe even some sour cream) and Greek omelets (with feta, tomatoes and spinach). Either can be tossed into a healthy wrap for a breakfast on the go!
• Plain ol’ hard boiled eggs, with sea salt and pepper. One of my favorites. Or top your sauteed greens with sliced hard-boiled eggs and drizzle with balsamic vinegar. YUM.
• One of my friends (you know who you are!) loves having salad with a fried egg on top, letting the yolk drip down like a dressing. A great way to eat veggies for breakfast, but sounds gross to me! Try it, if you’re game, and let me know!
• One weird thing I did try was an idea from another blogger (I’m sorry I can’t remember who!) and I LOVE it. A great way to get some probiotics into your breakfast: Top your fried egg with sauerkraut slaw (sauerkraut mixed with a little mayonnaise, sea salt and pepper). It’s delicious!

This post was entered in Healthy Home Economist’s Monday Mania.

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