The U.S. Department of Agriculture, Food and Drug
Administration, and Environmental Protection Agency have
announced the establishment of public dockets about the Food
Safety Initiative Strategic Plan. "The purpose of the plan is to
reduce incidence of acute and chronic foodborne and waterborne
illness by further enhancing the safety of the nation's food
supply."
For Comments directed to USDA, use Docket No. 98-045N. For
comments directed to FDA, use Docket No. 97-0074. To EPA, use
Docket No. OPP-00550; FRL-6019-9.
To obtain copies of the report "Food Safety From Farm To
Table: A National Food Safety Initiative," contact Karen Carson
of FDA at 202-205-5140; email: kcarson@Bangate.fda.gov. Copies of
the report are also available from the government websites. E.g.
USDA-Food Safety & Inspection Service (FSIS): www.fsis.usda.gov.
Information about the National Academy of Sciences' report
on "Ensuring Safe Food from Production to Consumption" can be
found at www.nas.edu.
This is an opportunity to incorporate the concept of a
wholesome nutritional vegetarian (vegan) diet into the dialogue
on food safety and nutritional health, and to encourage the use
of economic resources to develop and promote a wide variety of
vegan food (including fast-food) options.
United Poultry Concerns submitted the following Comments to
the FDA and the USDA-FSIS respectively. Submit written comments
in triplicate to USDA/FSIS Hearing Clerk, 300 12th St. SW, Rm
102, Cotton Annex, Washington DC 20250-3700. Submit written
comments in triplicate to Dockets Management Branch (HFA-305),
Food and Drug Administration, 12420 Parklawn Drive, Rm 1-23,
Rockville MD 20857. Electric Comments can be submitted as an
ASCII file: oppts.homepage@epa.gov. All comments and data in
electronic form must be identified by the docket number OPP-
00550.
Letter from Karen Davis, President of UPC, follows:
USDA/FSIS Hearing Clerk
300 12th Street, SW
Room 102 Cotton Annex
Washington, DC 20250-3700
| October 22, 1998 |
Re: Docket No. 98-045N
United Poultry Concerns appreciates this opportunity to
submit the following comments regarding the President's National
Food Safety Initiative. United Poultry Concerns, Inc. is a
501(c)(3) national nonprofit organization incorporated in the
State of Maryland. We represent thousands of members throughout
the United States.
The issue of food safety is directly related to United
Poultry Concerns' effort on behalf of the welfare of chickens and
other birds used as a human food source. In this regard we
recognize that the stressors to which birds and other animals in
the food system are subjected make them susceptible to a wide
variety of systemic and infectious diseases, many of which can
also affect human health and food safety. Diseases such as
Salmonella enteritidis and E. coli can be transmitted directly to
humans who eat products derived from infected animals. In
addition, people who eat produce are at risk from various
pathogens in the animal-based fertilizer in which the produce was
grown. Humans are also at risk as a result of cross-contamination
with tainted products.
In the February 3, 1995 Federal Register notice of its
proposed HACCP rule, the Food Safety and Inspection Service
acknowledged the relationship between the treatment of animals in
the food system and transmission of foodborne pathogens to
humans. FSIS acknowledged that
There are major aspects in the production phase that can
influence incidence, control, and prevention of potential
human pathogens. . . . Management systems addressing
increased animal welfare and better husbandry decrease
levels of stress, and would be expected to decrease the
incidence of pathogens. For example, improvements in cattle
handling systems reduce stress-related immune suppression
associated with animal processing procedures. A number of
other factors, such as animal density, frequency of feedlot
pen use, and commingling of sick animals, can affect stress
levels and thus risk of human pathogen exposure. . . .
Stressed animals have lowered disease resistance, making
them more susceptible to pathogens and at increased risk of
shedding potential human pathogens. Various forms of stress
can result in increased shedding and clinical disease,
causing increased exposure to penmates, increasing the risk
also to humans through contaminated meat."
Stressors include genetic impositions as well as handling
and management. Three major stressors, the elimination of which
would reduce both suffering and foodborne diseases in birds and
humans are: (1) Forced rapid growth of "meat-type" birds; (2)
Deliberate prolonged food withdrawal from birds used for meat and
eggs; and (3) Ammonia concentration in intensive avian
confinement facilities.
(1) Forced Rapid Growth of "Meat-Type" Birds. Today's
chickens and turkeys have been genetically pushed beyond their
biological capacity. Enormous suffering has been built into their
systems. Genetic selection for forced rapid growth has resulted
in birds that grow three-and-one-half times faster than birds of
thirty-five years ago, resulting in severe metabolic stress
(Feedstuffs Aug. 26, 1996:10). This stress is of itself an
immunosuppressive condition which results in increased
susceptibility to bacterial infection of poultry. Commercial
Chicken Production Manual, 4th ed. states that these birds "have
a lymphatic involution with an atrophy of the bursa of Fabricius,
thymus, and spleen, the lymphoid associates, and are less able to
withstand bacterial invasion because antibody production is
lower" (North & Bell, 863).
Therefore, a long-term vision for food safety in the U.S.,
as long as birds are part of the food system, would have to
include the elimination of genetic selection for growth rate of
"meat-type" birds and promotion of their biological wellbeing.
(2) Deliberate Prolonged Food Withdrawal. (a) Food
Withdrawal Prior to Slaughter. Food and water are deliberately
withdrawn from broiler chickens and turkeys from one to four
hours before catching and from commercial laying hens for three
to four days before catching. Removal of food and water from
birds prior to transport disrupts their gastrointestinal tract
and impairs their immunity, increasing the number of birds
infected with Salmonella ten times above the number of birds
infected before catching (Fliss, Southern Poultry Oct. 1993:15).
(b) Forced molting of hens used for egg production. Forced
molting refers to the manipulation of hormones in hens to
manipulate egg production by means of prolonged intentional
starvation of the birds. Each year, the U.S. egg industry
intentionally deprives millions of hens of all food for an
average of one to two weeks, until they lose 25 to 35 percent of
their body weight. Forced molting is so stressful that it
increases bone breakage and impairs the hens' immune system,
predisposing the birds and their eggs to Salmonella infection.
USDA immunologist Peter Holt reports that while unmolted hens
usually have to ingest 50,000 Salmonella cells to become
infected, molted hens need fewer than ten (Avian Diseases 37:412-
417). Once infected, these hens are more likely to lay
contaminated eggs. "Molting, in combination with an SE
(Salmonella enteritidis) infection, created an actual disease
state in the alimentary tract of affected hens" (Holt, Poultry
Science 71:1842-1848).
Forced molting has been shown to increase the transmission
of Salmonella enteritidis through the layer environment and to
increase the consumption of contaminated feathers by hens
attempting to cope with the hunger and starvation imposed on them
(Holt, Avian Diseases 39:239-249).
Therefore, a long-term vision of food safety in the U.S., as
long as birds are part of the food system, would have to include
the elimination of forced molting in particular, and food
withdrawal in general, as birds deprived of food for hours, days
and weeks lose immunity through stress and nutrient deprivation,
predisposing them to Salmonella enteritidis and other pathogens.
To this end, in April 1998, United Poultry Concerns and the
Association of Veterinarians for Animal Rights filed a petition
with the U.S. Department of Agriculture (APHIS, FSIS) and the
U.S. Food and Drug Administration urging that the forced molting
of hens used for commercial and hatching egg production be
eliminated (FDA Docket No. 98P-0203/CP).
(3) Ammonia Concentration in Intensive Avian Confinement
Facilities. Excretory ammonia is a colorless irritant gas
produced by microbial activity on the nitrogen excretion content,
uric acid, in poultry manure. Ammonia stress is a major cause of
respiratory infection in intensively confined chickens and
turkeys. Ammonia concentration impairs the birds' immune system.
Ammonia dissolves in the liquid on the birds' mucous membranes
and eyes to produce ammonium hydroxide, an irritating alkali-
causing ammonia-burn that stimulates the production of excessive
mucous in the trachea. This mucous mats, and ultimately destroys,
the tracheal cilia which served to block the entry of harmful
agents into the system, inviting colonization of the airways by
airborne microorganisms such as E. coli and Newcastle disease
virus. The bursa of Fabricius, which is the part of the avian
lymphoid immune system that produces circulating antibodies, is
likewise impaired by ammonia, so that when pathogens are inhaled,
and the immune cells of the respiratory tract cannot mount a
response, neither can the lymphoid system respond. The National
Turkey Federation Food Safety Best Management Practices for the
Production of Turkeys: Meat Bird Production/Growout states that
Ammonia in the air is absorbed into the blood of turkeys and
causes immunosuppression. It prevents phagocytosis of E.
coli organisms in the blood and suppresses the lysis of E.
coli organisms within the macrophage cells. It can be a
major factor in contributing to an outbreak of
colibacillosis or turkey coryza (10).
Therefore, a long-term vision of food safety in the U.S., as
long as birds are part of the food system, would have to include
reduction and removal of ammonia pollution. In addition to the
immunosuppressive effects of ammonia concentration in poultry and
hen complexes, predisposing the birds to E. coli and other
infections, studies of the effect of ammonia on egg whites
indicate that even at low concentrations, significant quantities
of ammonia can be absorbed into eggs (Carlile, World's Poultry
Science 40:99-113).
Conclusion. A report published by the U.S. Department of
Agriculture's Economic Research Service states: "The annual cost
of human illness caused by seven foodborne pathogens for which we
have estimates ranges between $5.6 billion and $9.4 billion. Meat
and poultry are the primary sources. . . . Foods most likely to
carry pathogens are high-protein, nonacid foods, such as meat
poultry, seafood, dairy products, and eggs" (Buzby and Roberts,
FoodReview May-Aug. 1995:37-42). The USDA publication
Agricultural Research (Smith, Oct. 1996:16) noted that
Salmonella, Campylobacter and other animal-derived pathogens can
lead to inflammation and destruction of organs and joints that
are "far removed from the site of infection," predisposing
individuals to degenerative diseases such as arthritis.
While United Poultry Concerns supports every effort to
reduce the pain and suffering of animal used for food, we regard
an animal-based diet as inconsistent with either a long- or a
short-term vision for food safety. The production, consumption,
and promotion of meat, poultry, dairy products, and eggs are
barriers to pursuing this vision. The most glaring gaps in the
food safety vision/system are the animals themselves. Animals are
rhetorically absent from the discussion. The National Research
Council's Ensuring Safe Food (1998) epitomizes this absence. It
is significant that FSIS's February 3, 1995 Federal Register
notice of its then proposed HACCP rule subsequently omitted the
part, quoted above, about the effect of inhumane treatment of
animals (e.g. poor husbandry, harsh handling, filthy environment)
on the incidence of pathogens in the human food supply. It is
significant that the document's acknowledgment that a regard for
animal welfare is a responsibility in its own right was deleted.
This section should be restored and implemented.
A related gap is the failure to include in the vision the
goal of an animal-free vegetarian diet comprised of fruits,
grains, nuts, leafy greens, and legumes. It is justifiably
claimed that all of the suffering endured by animals raised for
food is unnecessary suffering. Virtually the same thing can be
said regarding the suffering endured by humans as a result of
their consumption of animal products. Instead of our directing
resources to dealing with the inherent, ever-changing disease and
welfare problems of mass-production and mass-consumption of
poultry, for example, the 30 million bushels of high-protein
soybeans produced on the Eastern Shore each year to feed chickens
should be harvested and processed directly for human consumption.
This is where the creative ingenuity of the present and future
should be focused. As long as there are people on the planet, the
same amount of food will be consumed. Human food does not have to
include, and, if we are genuinely serious about improving our
health and food safety, and reducing our health-care costs, it
should not include animal products. In any case, neither a
slaughterhouse nor an intensive animal confinement unit is
compatible with a positive vision.
United Poultry Concerns appreciates the opportunity to
submit these comments regarding the President's National Food
Safety Initiative.
Sincerely,
Karen Davis, PhD
President
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