2000N-0504 - Prevention of Salmonella Enteritidis in Shell Eggs During Production
FDA Comment Number : EC23
Submitter : Ms. Karen Anderson Date & Time: 12/22/2004 10:12:22
Organization : Northeast Organic Farming Association of NJ
Consumer Group
Category :
Issue Areas/Comments
GENERAL
GENERAL
RE: RIN 0910 ? AC14
DATE: December 21, 2004


On behalf of the Northeast Organic Farming Association of New Jersey (NOFA-NJ), I submit the following comments on the proposed rule, Prevention of Salmonella Enteritidis in Shell Eggs During Production, 21 CFR Parts 16 and 118. We are an educational nonprofit that represents organic and sustainable producers and consumers.

We strongly support the small flock exemption included in the proposed rule.
Implementation of these regulations by small-scale producers would be cost-prohibitive, and remove an important source of locally produced foods. Maintaining a diversity of scale in production helps ensure a resilient food system, protects agricultural infrastructure in rural communities, ensures genetic diversity in our poultry stock and provides a backstop in the event of a catastrophic interruption in the flow of food products through the industrial system.

We strongly support the exemption of shell egg producers who direct retail all of their production.
Consumers should have the choice to purchase directly from a producer and make an independent judgment about that producer's production practices.


We strongly object to the protocols required under sec. 118.4(b-d) and 118.5 as unnecessary and/or fundamentally inappropriate in many alternative production systems.
The provisions of this section clearing assume production in confinement facilities with large populations of birds. For example, excluding wild birds, rodents and other potential disease vectors is not practical in operations which pasture their flocks. Organic, free-range, pastured-based and other non-confinement systems were not included in the 1999 NAHMS layer study. The incidence of and transmission paths for salmonella in these alternative production systems have not been studied in this country, the proposed protocols are not practical to implement and may not address the real critical control points in these production systems.

We request that forced molting and other practices that significantly reduce natural immune responses be prohibited in flocks subject to the provisions of this rule.
We believe that the level of scientific certainty that forced molting increases salmonella infection rates is equal to or greater than the supporting science behind other recommendations included in the rule. Forced molting should be prohibited in the interest of public health.

Sincerely,

Karen Anderson
For the Northeast Organic Farming Association of NJ