On February 26^th, Secretary Rollins announced a “robust strategy to deliver affordable eggs”.  A review of the five-point program suggests “more of the same” with the promise of additional money and introduction of a few semantic changes that rise to the level of rearranging deck chairs on the Titanic.

Before considering the components of the program, a review of the past three years of USDA policy denotes their failure to control highly pathogenic avian influenza (HPAI). Depopulation in 2022 attained 43.1 million laying hens, 14.4 million were killed in the succeeding year, 39.7 million in 2024 and approximately 30 million hens have been removed from the national population year-to-date.  Despite replacement of approximately 4 million started pullets each month, retention of flocks beyond normal age of depletion and other measures, flock size has fallen from 328 million on February 1^st 2021 through 310 million in 2023 declining to 292 million on February 1^st 2025.

Reduction in supply affecting both shell eggs and products has resulted in a disproportionate increase in price currently a source of embarrassment to the Administration with a pre-election commitment to reducing food inflation.

Attempts at “stamping out” what is obviously an endemic infection with wild bird reservoirs has proven to be unsuccessful and exceedingly expensive to the public sector. Futile efforts by the USDA have incurred a cost of close to $2.4 billion for indemnity and decontamination.  This figure pales in comparison with the cost borne by consumers.  The conservative $3 per dozen differential between the pre-HPAI cost compared to the average price in 2024 amounts to $23 billion over the 7.6 billion dozen consumed in either shell or equivalent liquid form.

The “five-pronged approach” is little changed from what has preceded the current unsatisfactory situation.  USDA will subsidize improvements in structural and operational biosecurity by up to $500 million but will require a 25 percent match by producers.  Deployment of laser installations would be a meaningful improvement in biosecurity given current knowledge of how flocks are infected. These installations if positioned and operated continuously have proven effective in preventing congregation of waterfowl. These birds serve as reservoirs of the virus in the vicinity of farms, many of which are located near wetlands or rivers along the major flyways.  A second improvement in biosecurity could be the installation of effective commercial vehicle washing installations, especially for feed mills supplying egg production and turkey farms.  Accepted structural biosecurity in the form of modules in which employees can shed outer clothing, shower and don farm-provided protective clothing should have been be the responsibility of individual producers.  In any event, producers who are at this late stage are now requesting USDA payments to introduce structural biosecurity should be obliged to undertake to repay grants. Progressive producers have invested in improvements notwithstanding the reality that even the most effective structural and operational biosecurity cannot provide absolute protection against windborne virus.

Throwing money at the problem will not solve the problem of too few hens in production. Replacement of flocks is limited by the availability of day-old chicks from a finite number of parent-level breeders. Restoring the national flock in the immediate term is restrained by the biological reality that pullets commence lay at approximately 20 weeks of age.  Despite the allocation of $400 million from March through the end of the USDA fiscal year, no specifics were provided on how this sum will increase the number of hens in the national flock.

USDA will assign $100 million for vaccine innovation and other strategies to reduce depopulation.  For the edification of Secretary Rollins, vaccines proven to be effective are available off the shelf. Both today and tomorrow. There is considerable published data on the effectiveness of HVT-vector vaccines and for inactivated oil emulsion products.  If there is a deficiency with respect to vaccination it relates to production capacity.  Given the potential demand for vaccines world-wide, the biologics industry will be willing to invest in expanded capacity providing there are no artificial restrictions intended to delay approval and deployment of commercial products.

When we come down to reality it is evident that the reticence to allow vaccination is a fear over trade embargos that may impact the broiler segment of the industry. The USDA is dancing around the single effective modality to reduce the incidence rate of HPAI outbreaks and to restore production.

Tinkering with cage free restriction and introduction of as yet defined “innovative strategies” or the expedient of importation will have no immediate or intermediate effect on the supply of eggs. Enhanced biosecurity alone is not the answer. Depopulation will continue if the USDA persists in a clearly ineffective strategy to control an endemic infection with a wildlife reservoir.

The possibility of zoonotic infection was an aspect of HPAI that was not considered in the “ Five-pronged Approach”.  Neither the U.S. nor the world can afford an H5N1 pandemic given the lessons of COVID.  Admittedly the risk is low despite emerging mutations that have allowed mammal-to-mammal transmission of H5N1 virus. To date only a low level of infection of workers in contact with infected flocks and dairy herds has been recorded albeit with less than enthusiastic surveillance.  Notwithstanding the frequently repeated “low probability of an emerging epidemic or pandemic”, the consequences would be catastrophic and would reflect adversely on the legacy of the Administration if effective control measures including vaccination of large populations of hens were to be ignored.

Avian influenza is the Newcastle disease of the 2020s.  This infection was catastrophic during the 1970s as HPAI is today.  Newcastle disease is effectively suppressed below the outbreak threshold by effective vaccination and is not an impediment to trade in poultry and products.

 In the U.s.The USDA should take cognizance of the findings incorporated in the World Organization for Animal Health document Vaccination and Surveillance for HPAI in Poultry: Current Situation and Perspectives, published following the October 22^nd 2024, meeting of world experts in Paris.

We have the resources to suppress HPAI applying strict biosecurity coupled with vaccination. This is consistent with the World Organization for Animal Health Terrestrial Animal Health Code supporting vaccination.  The WOAH considers that vaccination should facilitate safe trade without increasing the risk of HPAI in poultry and products.

It is time for a radical change in suppressing endemic HPAI. Based on the failure of “stamping out” to control the infection, throwing more money at the situation as in the proposed USDA Five-pronged Approach will not have any meaningful effect on reducing the incidence rate of HPAI or the cost of eggs as denoted by the realities of the past three years.

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In her confirmation hearings Ms. Brooke Rollins who will to become the U.S. Secretary of Agriculture in the new administration of President Trump, acknowledged the importance of highly pathogenic avian influenza (HPAI) to a wide range of stakeholders including the poultry industry, grain farmers and consumers. Secretary Rollins is not expected to be either an epidemiologist or a virologist, but it is hoped that her strong personal qualities, skill and experience as an administrator will lead to a reevaluation of the control and prevention of highly pathogenic avian influenza by the Animal and Plant Health Inspection Service (APHIS) under her control.

The current HPAI epornitic has proceeded unchecked since 2022.  For the edification of the incoming Secretary the box score for 2024 includes approximately 40 million table-egg hens and at least 3 million replacement pullets, 3.4 million commercial meat turkeys and 5 million broilers.  During the month of January 2025 APHIS has presided over the depopulation of close to 5 million laying hens and 0.2 million broilers and turkeys respectively.  Since January 2024 California has lost 52 percent of its flock and the state population of hens is down to 4.4 million. Colorado depopulated 66 percent of its hen population in 2024 with most outbreaks in Weld County leaving the state currently housing a mere 1.3 million laying hens.

The depletion of laying flocks has seriously impacted the supply of eggs with resulting escalation in cost of to consumers and manufacturers.  The National Large white graded loose price increased by 286 percent from $1.62 per dozen during the third week of January 2024 to $6.26 per dozen during the past week. This increase should be compared to the 1.8 percent escalation in the Consumer Price Index (CPI) for food consumed at home as calculated by the Bureau of Labor Statistics. For 2024 the CPI for all food was 2.8 percent. It is estimated that during 2022 expenditure on eggs by consumers was higher by approximately $2 per dozen as a result of H5N1 depopulation, costing households an incremental $15 billion.  The impact on consumers’ budgets in 2024 will exceed this figure.

Agriculture economists are bemused by the disparity between the eight percent reduction in the number of producing hens in comparison to the more than threefold increase in price. This denotes exceptional elasticity (despite the hard shells!). Extreme inflation in the price of eggs is a standout among domestic expenditures. High shelf prices have the potential to embarrass the incoming Administration, given pre-election rhetoric on reducing the cost of food to consumers.  Secretary designate Rollins in her hearing noted “We must work with the great men and women of USDA, the stakeholder communities and state leaders to immediately and comprehensively get a handle on the state of animal disease outbreaks.”

The USDA-APHIS has pursued a program of depopulation and in cooperation with state authorities has achieved high levels of efficiency in diagnosing outbreaks, killing and disposal of flocks and managing decontamination with attendant distribution of indemnity and logistics payments.  It is however evident that HPAI will not simply disappear as it did in 2015 when migratory waterfowl ceased shedding the H5N2 strain virus.  Since 2022, an H5N1 virus of clade 2.3.4.4b; D1.1 genotype has effectively become a panornitic, present on six continents.

APHIS is continuing to implement a “stamping out” policy for a disease that is clearly seasonally and regionally if not nationally endemic. This Sisyphean approach is inappropriate, outdated and unrealistic in relation to the epidemiology of the disease. It is evident that HPAI is introduced and disseminated by migratory waterfowl. Blurring of the previous seasonal fall and spring phases may be due to climatic variation but possibly by extension to domestic resident bird and mammal reservoirs.

There is considerable evidence that the application of effective vaccines as an adjunct to biosecurity can suppress the magnitude and financial impact of outbreaks.  A joint report by the European Center for Disease Prevention and Control in cooperation with the European Food Safety Agency Panel on Animal Health and Welfare confirmed that vaccinated chicken flocks show an increased ability to withstand exposure and demonstrate reduced viral shedding.

A reluctance to allow limited and strategic immunization of U.S. flocks in the face of continuing outbreaks is difficult to comprehend.  Representatives of APHIS have opined that vaccination would be more expensive than depopulation in regional meetings.  If this is the justification driving opposition to vaccination then the Agency should make public their scientific and economic studies to be evaluated by independent agricultural economists and veterinary health professionals.  Could the reluctance to consider tactical vaccination be an institutional inability to admit that past policy and decisions were wrong and that the current approach to control ignoring vaccination may be inappropriate?  It is evident that there is overt pressure by a segment of the industry to resist introduction of vaccination, even on a regional basis, since this may impact exports. Since outbreaks have recently occurred in major broiler-producing states with resulting embargos, the failure of APHIS to negotiate acceptance of vaccination with controls among importing nations has now become a problem to all segments of the U.S. poultry industry.

Extension of HPAI to free-living mammals in contact with infected poultry and dead wild birds emerged as a concern during 2023.  Extensive mortality among marine mammals along the Pacific littoral of South America confirmed that H5N1 can undergo mutation and can become contagious among mammals.  The emergence of H5N1 B13.3 genotype among dairy herds should serve as a warning to the livestock industry. Hogs can serve as mixing vessels for influenza viruses and could contribute to both mutation and drift creating even greater risk for humans.

At present the prospect for emergence of a human epidemic appears minimal.  This said, the consequences would be catastrophic both in terms of public health and to the Nation’s economy as evidenced by the COVID outbreak. Given withdrawal from the WHO and political restraints on federal agencies that support health including the NIH and CDC would place the U.S. in a difficult position should a zoonotic strain of H5N1 emerge.  Prominent virologists in internationally recognized U.S. institutions have raised concerns over possible mutation in the H5 hemagglutinin gene. This was apparent in the two clinical cases in Canada and the U.S. respectively.  To date there has been no evidence of human-to-human transmission among the approximately 70 cases contracted from exposure to either dairy cattle or infected flocks of chickens. One prominent researcher characterized this situation as “Only a matter of time”.  A second specialist noted, “At the end of the day I think it’s a numbers game.”  The fact that producers have placed large numbers of susceptible hens on complexes within all four flyways represents a risk for the occurrence of mutation that could contribute to emergence of a zoonotic strain of avian influenza. Effective vaccines that stimulate immunity in populations of commercial poultry are commercially available. Inactivated H5 and H7 DIVA vaccines have been deployed in many nations including Italy, the Netherlands, the PRC, France and our neighbor Mexico.

It is evident that the approach to control of HPAI adopted by APHIS over the past three years has failed.  Vaccination is required for laying hens and turkeys in areas with a history of reocurring infection.  Decisions relating to vaccination should be based on benefit-to-cost studies taking into account risks of infection, the financial impact of losses and trade consideration that may in reality be overstated.  At the very least, workers coming into contact with live poultry and dairy herds should receive both the trivalent seasonal influenza vaccine and an available H5N1 product manufactured in the U.S. The E.U. has imported this vaccine that has been deployed in Finland and will soon be used in the Netherlands.

The extent of losses among laying hens and other commercial poultry and the extensive cost borne disproportionately by the private sector, producers and consumers should result in a reevaluation of policy with regard to vaccination.  The infection is not controlled, and APHIS should accept epidemiologic and financial reality and recognize the zoonotic potential of H5N1virus.

It is axiomatic that HPAI is effectively “the Newcastle disease of the 2020’s”.  At the outset of my professional career during the late 1960’s, Newcastle disease was as catastrophic as avian influenza is today. This disease is no longer a restraint to production given the availability and universal use of vaccines.

Let us hope that Secretary Rollins will stimulate a reappraisal of vaccination against HPAI and effect changes leading to adoption of tactical vaccination as an adjunct to biosecurity.