With an estimated 228,000,000 individual eggs subject to Wright County Egg’s massive recall yesterday, and the subsequent cascade of companies issuing their own recalls because they used contaminated Wright County eggs, this mary very well turn into one of the largest food product recalls and outbreaks in recent memory.  After all, only minutes ago, California health officials announced that 266 residents (that is 266 residents of California alone) were sickened in the outbreak; multiplied by the magic number 38.6 (i.e. the estimated number of unconfirmed cases in any Salmonella outbreak), there may be more than 10,000 victims of this outbreak in California alone. 

What is the extent of Wright County Egg’s liability in this outbreak?  The answer depends on the number of cases counted in the end-reckoning, and the numbers will probably be staggering.  But what about its culpability?  The in-depth discovery that will certainly happen in the wake of the lawsuits that we intend to file against the company will follow the FDA’s guidance document to egg producers.  See Egg Guidance in full.   

Here’s a select few questions to be asked, and very clear answers, according to the FDA:

A.  Cleaning and Disinfection:

1. When am I required to clean and disinfect my poultry houses?

You must clean and disinfect your poultry houses before new laying hens are added to the houses if you have had an environmental test or an egg test that was positive for SE [Salmonella enteritidis] at any point during the life of a flock that was housed in the poultry houses prior to depopulation.  [editor’s note:  with as many illnesses nationally as there appear to be, has Wright County Egg had to just destroy its entire flock of laying hens?]

(21 CFR 118.4(d))

2. What procedures must I follow when cleaning and disinfecting my poultry houses?

When cleaning and disinfecting your poultry houses, you must follow these procedures:

You must remove all visible manure;
You must dry clean your positive poultry houses to remove dust, feathers, and old feed; and
Following cleaning, you must disinfect your positive poultry houses with spray, aerosol, fumigation, or another appropriate disinfection method.
(21 CFR 118.4(d)(1), (d)(2), and (d)(3))
 

B.  Refrigeration:

1. When must I refrigerate my eggs?
You are required to refrigerate eggs from farms with 3,000 or more laying hens beginning 36 hours after they are laid.

(21 CFR 118.4(e))

2. What is the maximum temperature required for holding and transporting eggs that are at least 36 hours old?
The maximum temperature requirement for holding and transporting eggs that are at least 36 hours old is 45 degrees F ambient (air) temperature.

(21 CFR 118.4(e))

C.  Environmental testing for SE

1. Why must I test my poultry house environment for SE?
Environmental testing for SE is one indicator of the effectiveness of your SE prevention plan.

(21 CFR 118.5(a))

2. When must I test my poultry house environment for SE?
In addition to the required environmental test of the pullet environment when pullets are 14 to 16 weeks of age (§118.4(a)(2)(i)), you must perform environmental testing for SE (as described in §§118.7 and 118.8) in each poultry house when any group of laying hens constituting the flock within the poultry house is 40 to 45 weeks of age (§118.5(a)). If you induce a molt in a flock or a group in a flock, you must perform additional environmental testing for SE in the poultry house at 4 to 6 weeks after the end of each molting process. Each time a flock or group within the flock is molted, you must perform environmental testing in the poultry house at 4 to 6 weeks after the end of the molting process.

(21 CFR 118.5(b))

3. What am I required to do if my environmental test is negative?
If your environmental test at 40 to 45 weeks is negative and your laying hens do not undergo induced molting, you do not need to perform any additional environmental testing within that poultry house, unless the poultry house contains more than one group of laying hens. If the poultry house contains more than one group of laying hens, you must perform environmental testing on the poultry house when each group of laying hens is 40 to 45 weeks of age. (21 CFR 118.5(a)(1)) If your environmental test at 4 to 6 weeks after the end of the molting process is negative and none of your laying hens in that poultry house is molted again, then you do not need to perform any additional environmental testing in that poultry house.

(21 CFR 118.5(b)(1))

4. What am I required to do if my environmental test is positive?
If your environmental test at 40 to 45 weeks is positive, then you must:

Review and make any necessary adjustments to your SE prevention plan to ensure that all measures are being properly implemented; AND either
Begin egg testing, as described in § 118.6; OR
Divert eggs to treatment for the life of the flock in that poultry house.
(21 CFR 118.5(a)(2))

If your environmental test at 4 to 6 weeks after the end of a molting process is positive, then you must:

Review and make any necessary adjustments to your SE prevention plan to ensure that all measures are being properly implemented; AND either
Begin egg testing, as described in § 118.6; OR
Divert eggs to treatment for the life of the flock in that poultry house.
(21 CFR 118.5(b)(2))

5. When must I have the results from egg testing?
You must have results of egg testing within 10-calendar days of receiving notification of the positive environmental test.

(21 CFR 118.5(a)(2)(ii))

D.  Testing Eggs for SE

1. When must I test eggs for SE?
You must test eggs for SE whenever you have an environmental test positive for SE and you choose not to divert eggs from the flock in the positive house to a treatment for the life of that flock. If the environmental test for pullets at 14 to 16 weeks of age is positive, you must either divert eggs to treatment for the life of that flock or conduct egg testing within 2 weeks of the start of egg laying.

(21 CFR 118.6 (a)(1))

2. How do I test eggs for SE?
You must conduct four egg tests on the flock in the positive poultry house at 2-week intervals.

(21 CFR 118.6 (c))

3. If all four egg tests are negative for SE, am I required to do any further egg testing?
No. If all four egg tests are negative for SE, you do not need to test any more eggs from that flock.

(21 CFR 118.6 (c))

4. What do I do if any of the four egg tests is positive?
If any of the four egg tests is positive for SE, you must divert, upon receiving notification of an SE-positive egg test, all eggs from that flock to treatment for the life of the flock or until four egg tests at 2-week intervals are negative for SE.

(21 CFR 118.6 (c) and (d))

5. What if one of my four egg tests is positive, and I divert to treatment and then later achieve negative results for four egg tests at 2-week intervals?
In this situation, you may return to table egg production, upon receiving notification of a negative result for the fourth egg test. However, you must conduct one egg test per month on that flock for the life of the flock.

(21 CFR 118.6 (e))

6. If all my monthly egg tests are negative for SE, may I continue to supply eggs to the table egg market?
Yes. As long as all of your monthly egg tests are negative for SE, you may continue to supply eggs to the table egg market.

(21 CFR 118.6 (e) (1))

7. What am I required to do if any of my monthly egg tests is positive for SE?
If any of the monthly egg tests is positive for SE, you must divert eggs from the positive flock to treatment for the life of the flock or until four egg tests at 2-week intervals are negative for SE.

(21 CFR 118.6 (e) (2))

8. Am I required to label or otherwise identify eggs I am diverting to treatment?
Yes. If you are diverting eggs, the pallet, case, or other shipping container must be labeled and all documents accompanying the shipment must contain the following statement:

“Federal law requires that these eggs must be treated to achieve at least a 5-log destruction of Salmonella Enteritidis or processed as egg products in accordance with the Egg Products Inspection Act, 21 CFR 118.6(f).”

This statement must be legible and conspicuous.