From: Robert Hadad [rhadad@hsus.org]
Sent: Tuesday, December 21, 2004 3:11 PM
To: fdadockets@oc.fda.gov
Subject: Docket nos 1996P-048, 1997P-0197, 1998P-0203, 200DN-0504 RIN#
0910AC14

I wish to comment on the proposed FDA rules on preventing SE in shell
eggs during production. While it is definitely necessary to prevent SE
and other food born illnesses from becoming problematic, extreme
approaches will only hurt family farmers and expand the consolidation of
the industry in favor of the largest producers.

Small scale egg production has been a boom for rural economically
disadvantaged farmers. Free range, day ranged, and pastured poultry are
systems of rearing chickens engaged by small family farms. The eggs
produced provide, in many cases, a substantial portion of farm income.
Egg production is very profitable for these farmers.

Cleaning eggs through the processes mentioned in the Federal Register
Notice would help prevent SE from causing illness. However, if the
mechanisms to do this are not scale sensitive, how will small family
farm commerce survive? 

The issue of preventing outdoor access for poultry as a control method
is extreme and not proven to be anymore successful in preventing SE. In
fact, the testing for SE in the past has focused on large scale egg
producers raising their birds in cages indoors and SE has been highly
prevalent. 

Breeding for SE resistance in hens as well as eliminating SE during the
hatchery stage has proven successful in some of the Scandinavian
countries. Cleaning up the feed industry is another place where SE
infection has been shown to be a major problem. The forced moulting of
chickens also spreads SE more readily. 

Please refer to the attached paper for more information.

Access to the outdoors is a major function of the natural behavior of
chickens. Denying this access will not alleviate the problem but simply
drive many hard working small family farms out of business. Look to
sanitation and areas within the feed and hatchery industries to start a
major prevention program.

Robert Hadad
Director of Farming Systems
Farm Animals & Sustainable Agriculture -
The Humane Society of the United States
2100 L St. NW
Washington, DC 20037
301-258-3113
rhadad@hsus.org