On December 11^th, senators representing both sides of the aisle addressed a letter to the White House urging adoption of vaccination as an adjunct to biosecurity to address the endemic and widespread incidence of highly pathogenic avian influenza (HPAI) manifest as an epornitic since 2021.

The group of 23 senators including Senate Majority Leader John Thune (R-SD), with Mike Rounds (R-SD) and Amy Klobuchar (D-MN), respectively Chair and Ranking Member of the Senate Committee on Agriculture, Food and Forestry, urged Brook Rollins, Secretary of Agriculture to implement “renewed action” to address the problem of HPAI.  The letter stressed the need to apply science and to take into account the needs of all stakeholders. This implies balancing enhanced protection afforded to farmers against the possible loss of export markets for broiler leg quarters.

The USDA is apparently developing a vaccination policy but has yet to release any document.  In response to the letter, an unnamed USDA administrator noted, “Farmer biosecurity efforts are the most effective tool for mitigating the bird flu.”  For the edification of this individual, HPAI can be introduced onto farms by the aerogenous route, effectively negating even the most stringent structural and operational biosecurity.  The additional statement that USDA policy “Is grounded in decades of scientifically validated epidemiological practices and biosecurity protocols” is a self-validating misstatement of reality. The effectiveness of tactical preventive vaccination using a range of currently available commercial vaccines has proven effective in the industries of many nations including our southern neighbor. Essentially HPAI is the ‘Newcastle disease of the 2020s’. The infection was effectively controlled by immunization during the 1970s and is currently a problem only in nations without vaccination programs, defective vaccines or inappropriate administration.

At the end of the first quarter of this year, as depopulation of large egg production complexes and turkey growing farms attained a high level, the USDA announced a “more-of-the-same” program funded by $100 million to “research vaccines and therapeutics.”  More than 400 research proposals have been submitted to USDA to investigate aspects of HPAI. Even if the most promising of these avenues of research receive support, and achieve positive results it will not have any impact on the anticipated losses during seasonal migration of free-living birds during 2026 and 2027.

If the USDA has in fact developed a policy for vaccination then it should be released for review by the scientific community including epidemiologists and poultry health professionals in addition to flock owners, consumer advocates, exporters of poultry products and other stakeholders.  Concern that those advocating the status quo persist with their opposition to vaccination based on the potential impact on exports to the detriment of egg and turkey producers in high-risk areas.  Inactivity is impacting adoption of preventive vaccination consistent with endorsement by the World Organization for Animal Health as an adjunct to biosecurity but with surveillance.

Persistence of infection in the U.S. poultry industry represents a public health threat with the possible emergence of a zoonotic strain of H5N1 avian influenza. Some mutants of H5N1 have crossed the barrier from avian to marine and terrestrial mammalian species.  The debate over vaccination is also clouded by opposition to proven vaccination as a modality to protect human populations by immunization as exemplified by Robert F. Kennedy Jr. and his appointed acolytes.  The Secretary of the Department of Health and Human Services previously advocated allowing HPAI outbreaks to simply run their course, a sentiment echoed by the USDA Secretary until she was appraised of the realities of the infection and the consequences of her support for an inane, simplistic and irresponsible approach to the control of HPAI. 

We do not need interminable research on vaccines.  The U.S. poultry industry needs an honest evaluation based on risks and potential consequence of either withholding or applying currently available commercial vaccines according to a predetermined program for hens and turkeys in high-risk areas.  The USDA as an institution should stop temporizing and flirting with the promise of a policy on vaccination against HPAI and release their policy document for open discussion and scientific and economic evaluation.

Transparency is an effective disinfectant against bureaucratic intransigence and hidden agendas.

Following a Presidential directive, the federal government has established a taskforce to investigate “anti-competitive behavior” among meat processors and other segments of the U.S. food industry.  Initially the probe involving the Department of Justice and the Federal Trade Commission will focus on the red meat industry with the high price of beef as the dominant economic and political issue.

Announcing the Presidential Executive Order establishing the taskforce, the White House noted that “all necessary appropriate actions will be taken not just to the food supply chain but whether control of food-related industries by foreign entities is increasing the cost of food products in the U.S. or creating a national or economic security threat to Americans.”  The statement added, “anti-competitive behavior, especially when carried out by foreign-controlled corporations threatens the stability and affordability of America’s food supply.” In the event of disclosure of criminal collusion, proceedings will be initiated as appropriate.  Red meat processing in the U.S. is an oligopoly with a high proportion of foreign ownership.

So much for the $5 million ‘donation’ by JBS.

Agriculture economists attribute the high price of beef to disparity between supply and demand occasioned by herd reductions following drought and low prices in recent years. Placing tariffs on imported beef and especially from Brazil exacerbated the supply side of the equation.

It remains to be seen whether the Food Supply Chain Security Taskforce will confirm collusion or whether this is an exercise in scapegoating.  Should food inflation continue, the probe initially directed at the beef industry may be extended to other sectors including broiler meat and eggs. 

It is apparent that the largest five egg producers and possibly others in the U.S. will be confronted by the same intrusive and ultimately expensive civil law suits as experienced by the broiler and hog industries. The same claims of collusion using commercial databases and alleged price-fixing will form the basis of class-action lawsuits experienced by hog packers and broiler integrators that led to significant payouts to plaintiffs and generous fees for law firms.

With the restoration of shelf prices for shell eggs, pressure on the industry, exemplified by previous action by state attorneys general has abated.  Unprecedented escalation in the price of eggs following significant depopulation resulting from HPAI focused attention on the product, eroding consumer goodwill and stimulating the ire of the White House. Should losses that occurred during the first quarter of this year reoccur in 2026, the industry could well be faced with investigations by the task force especially given an election year.  Price restraint by both producers and retailers would appear prudent given that the Administration has politicized supply-demand realities, agricultural economics and the preparation and interpretation of USDA production statistics.

In a recent interview Stephen Vaden, Deputy Secretary of Agriculture acknowledged the increasing incidence rate of highly pathogenic avian influenza (HPAI) especially affecting turkey and egg production.  It is apparent that USDA is justifiably promoting biosecurity as an essential but sole component of prevention through a program of farm audits.  Producers are encouraged to use the resources of USDA to identify deficiencies in either structural or operational biosecurity and to effect improvements. 

In his interview Vaden stated that “vaccination isn’t available yet.” This is completely wrong and an institutional USDA self-delusion.  Major EU biopharmaceutical companies offer a range of vaccines of proven efficacy ranging from conventional inactivated oil emulsion preparations to advanced live, modified vector vaccines suitable for mass administration by in ovo injection

Vaden points to the “Poultry Innovation Grand Challenge” funding 58 projects to combat avian influenza. He further indicated that “vaccine development and rollout will take time”.  Again, this is a manifestation of USDA policy of temporizing or opposing immunization as an additional modality in the face of a prolonged U.S. epornitic.

Effectively the USDA continues to make appropriate noises about vaccination but appears to be delaying a decision under duress that deploying vaccines against HPAI would impact export of broiler leg quarters. The World Organization of Animal Health (WOAH) has approved vaccination as an adjunct to control and prevent the ongoing HPAI pandemic. Notwithstanding  the official position of the Agency, the USDA remains recalcitrant to consider a change in policy to allow controlled, tactical immunization of egg production and turkey flocks in high-risk areas accompanied by high levels of biosecurity and with appropriate surveillance.

USDA should accept reality in that:-

• HPAI is endemic in the migratory waterfowl and marine populations of the world,
• The infection will simply not ‘go away’
• Ongoing HPAI represents a cost to consumers, the public sector and producers far exceeding the value of the potential loss of export revenue from leg quarters
• HPAI is transmitted inter alia by the airborne route effectively invalidating even the strictest biosecurity measures
• Many importing nations accept the WOAH principles of controlled vaccination with surveillance, regionalization and compartmentalization
• H5 HPAI is potentially zoonotic

ByHeart a small-scale manufacturer of infant formula, in a market dominated by a few majors, has recalled all products as a result of contamination with spores of Clostridium botulinum. Since August, 31^st 35 cases have been confirmed in infants with at least 70 under investigation.  Fortunately, no fatalities have been reported. The diagnosis is based on clinical observations and is followed by effective available treatment.

Similarities with this case and the major 2022 recall from the Abbott, Sturgis, MI. facility are striking.  At issue is the failure of the Food and Drug Administration (FDA) to effectively monitor production plants and to enforce either corrective action or closure.  The most recent investigation disclosed three isolations of Clostridium spores from 36 unopened containers suggesting a high level of contamination in the Allerton, IA. facility.  Disclosures obtained under the Freedom of Information Act confirmed an unsatisfactory situation with regard to the plant dating back to 2022.  Deficiencies documented in official warning letters included the presence of pests, defective structures including ceilings and floors, failure to maintain an appropriate pathogen surveillance program, incorporation of untested ingredients, previous isolations of Cronobacter and an observation that “the Byheart plant was not designed to facilitate maintenance and sanitary operations”.  It is significant that the company received approximately 2,000 complaints relating mainly to organoleptic quality but also some health-related complaints including nine characterized by the FDA as “sensitive/serious”.

It appears that FDA has not learned anything from the Abbott episode and that the Agency has obvious deficiencies in their oversight of plants manufacturing food products and pharmaceuticals.  Regrettably the Agency has been politicized and there is little hope for practical improvement given the exodus of experienced managers, a deliberate reduction in staff, resignations and retirements all prompted by current policies of the Department of Health and Human Services. The appointment of incompetent or unqualified management based on ideology and conformity with non-scientific principles as expressed by Robert F. Kennedy Jr, Secretary of the Department suggest future health problems related to failure of the FDA to fulfil the missions detailed and funded by Congress.

Subscribers are directed to the recent ProPublica article on highly pathogenic avian influenza (HPAI).  The incisive report was based on interviews with prominent poultry health professionals and incorporated an analysis of available redacted epidemiologic data obtained under the Freedom of Information Act.

EGG-NEWS has long maintained that HPAI can be introduced onto farms by virus entrained on windborne dust and dander thereby invalidating even the most extreme structural and operational biosecurity.

USDA policy appears to be predicated on two principles:

• That the use of vaccination against HPAI in high-risk areas for egg production flocks would result in the collapse of U.S. exports.  This contention is supported by a well-organized lobby exerting pressure on the USDA through the Congressional broiler caucus.  Accordingly, pseudo-scientific arguments are advanced deprecating vaccination which has proven to be an effective method of prevention when combined with high levels of biosecurity.  The USDA should have predicted the persistence and severity of HPAI and actively engaged with trading partners to accept limited and controlled vaccination with appropriate surveillance following the principles of the World Organization of Animal Health.

• The USDA has studiously avoided conducting meaningful epidemiologic studies that may initially have confirmed that the infection was endemic with seasonal dissemination of virus by migratory and now resident free-living birds.  It would appear that the USDA functions with the earnest hope that the infection will simply “go away” as it did at the end of the 2015 epornitic.  Unfortunately, this presumption has been disproved by the ongoing seasonal epornitic since 2022.  Despite having qualified personnel and financial resources USDA has failed to conduct meaningful epidemiologic studies to identify risk factors and to establish that the infection can be transmitted by wind as has been documented in a number of peer-reviewed articles. Collectively the literature advances evidence of aerogenous transmission and the effectiveness of controlled vaccination.

The USDA conducted superficial epidemiologic studies in 2022 involving telephone surveys using a standard format administered months after outbreaks.  All that emerged from the inadequate investigations was that proximity to free standing water and wetlands and the presence of wild birds were risk factors.

Absent a clear policy on vaccination and reliance on the obviously imperfect protection afford by biosecurity, the U.S. industry will be confronted with ongoing seasonal outbreaks.

The longer that the epornitic persist, the greater will be the risk of emergence of a zoonotic strain of avian influenza.  Mutations in the genome of  Clade 2.3.4.4b avian influenza virus strain H5N1 have occurred resulting in infection of dairy herds and marine mammals.  The World Health Organization regards avian influenza as a potential pandemic virus and accordingly the greater the efficiency of suppression infection through vaccination, the lower will be the risk of a significant public health concern.

If all costs as a result of infection are takin into consideration, agriculture economists guiding policymakers should not only consider the expense of depopulation and indemnity but should include the cost to consumers. Escalation in the price of eggs occurs following seasonal outbreaks due to a disturbance in the supply to demand equilibrium.  Costs to consumers should reflect consumption of seven billion dozen in shell and liquid form annually. Escalation in wholesale and shelf prices over seasonal values as a result of HPAI have amounted to $2 to $4 per dozen for extensive periods since 2022.

The so-called multipronged program to combat HPAI announced by secretary of Agriculture Brooke Rollins is at best more of the same and at worst a delaying tactic. Facile and unhelpful comments by Robert F. Kennedy Jr.  Secretary of Health and Human Services to simply allow infected flocks to die in the hope of establishing resistant strain among the five percent survivors of an outbreak belies the reality that commercial chickens are hybrids. In any event failure to control HPAI by USDA would absolutely result in a termination of exports.

If the USDA knuckles down to reality and accepts scientific fact and refrains from sophistic misinterpretation of the literature to suit a non-vaccination policy the industry would be more secure and all stakeholders would benefit.  There is apparently a draft policy on vaccination that has had limited circulation but neither the UEP nor the AVEP, representing poultry health professionals has received a copy for comment.

The bottom line for the USDA is that H5 HPAI is endemic, is carried by migratory birds, is disseminated among other routes by air movement and is potentially zoonotic.  Further intransigence cannot be tolerated since a windborne endemic disease with seasonal reintroduction of virus by wild birds cannot be eradicated. By depopulation. The USDA and those opposing avian influenza vaccination should recognize that HPAI is effectively “the Newcastle disease of the 2020s”.  This infection was effectively suppressed, controlled and effectively eradicated in commercial poultry production worldwide through application of vaccination.