The (Egg)noble Lie of Regulatory Paternalism

War is Peace, Freedom is Slavery, and the consumption of raw eggs will almost certainly kill you. That is, at least, what our various regulatory agencies would like you to believe. It’s a noble white lie perpetuated in the name of public health. The only problem is that the exact opposite is likely closer to the truth. 

While endless misleading warnings against raw eggs may be an effective means for reducing egg-borne salmonella illness, such a policy comes at a self-defeating opportunity cost in terms of regulators’ own goals. In attempting to save every life, no matter what the cost, from one type of sickness, they likely cause many more deaths from a variety of other diseases.

From restaurant menus to premade cookie dough, the FDA has guilt tripped a generation of Americans into fearing undercooked egg products through mandatory product label regulations:

SAFE HANDLING INSTRUCTIONS: To prevent illness from bacteria: keep eggs refrigerated, cook eggs until yolks are firm, and cook foods containing eggs thoroughly.

Per the FDA’s own mission statement, their aim is to:

…[protect] the public health by ensuring the safety, efficacy, and security of human and veterinary drugs, biological products, and medical devices; and by ensuring the safety of our nation’s food supply, cosmetics, and products that emit radiation…

A seemingly benign aspect of this admirable goal has been the fight against egg-borne salmonella illness, specifically through warning label requirements and the advocacy against the consumption of any raw egg products. This well-intentioned concern, however, overlooks one small yet important aspect of the situation: You likely couldn’t catch egg-borne salmonella if you tried, and if you did it wouldn’t matter.

USDA researchers Eric Ebel and Wayne Schlosser show in a study published in the International Journal of Food Microbiology that only about 1 in 20,000 unpasteurized eggs even have the bacteria. Pasteurization kills virtually all of the remainder. This statistic is nowhere to be found on the FDA’s website, where they present the matter as a clear and present danger:

Fresh eggs, even those with clean, uncracked shells, may contain bacteria called Salmonella that can cause foodborne illness, often called “food poisoning.”

In light of the unveiled statistics, it becomes clear that the lifting done by “may”  in that assertion is nothing less than herculean. Consider the following back of the envelope math: Let’s say you eat a raw, unpasteurized egg every day of your life for the next 40 years.That totals to 14,600 eggs. If we assume independent conditional probability, the chance that not even a single egg contains the salmonella virus is about 48 percent [(19999/20000)^14600 = 0.4819]. Assuming you don’t have a life threatening auto-immune disorder, the probability of developing salmonella illness from a single infected egg is likewise fairly low. To avoid raw eggs entirely on this basis is analogous to never leaving your home again to prevent a coin toss chance of passing by someone with a cold at some point in your life.

The risk averse among you are probably asking the obvious question: Exactly how deadly is this illness that our beneficent bureaucrats express such great concern over? The Wayback Machine faithfully reports a statistic which the FDA has scrubbed from appearing anywhere on its website: 

The US Food and Drug Administration (FDA) estimates that 79,000 cases of foodborne illness and 30 deaths each year are caused by eating eggs contaminated with Salmonella

That is to say, per the FDA’s own estimates, the mortality rate of egg-borne salmonella is a mere 0.038 percent. That’s approximately one tenth of that of the seasonal flu in 2023. Nine times as many deaths from lightning occur on average each year. Likewise, Patricia Cummings et al. show in a study in the journal Foodborne Pathogens and Disease that salmonella deaths are heavily concentrated among those with comorbidities such as auto-immune disorders and advanced age. Nearly 60 percent of Salmonella deaths from 1990-2006 were those aged 65 and up, and over 24 percent had either cancer, HIV, or a history of drug and alcohol abuse. To put it in perspective, as long as you don’t have the above comorbidities, you are over 4.5 times more likely to win the million-dollar Powerball prize than die from the consumption of a raw unpasteurized egg.

With respect to their irrational and paternalistic stance on raw egg consumption, FDA regulators demonstrate that they ignore opportunity costs completely. 

Eggs are one of the cheapest and most nutrient dense foods on the planet. They are packed with vitamins A, D, and zinc, all essential for immune health and in which vast swaths of the American population are deficient. In 2022, malnutrition deaths more than doubled in the United States from 9,300 to 20,500. That’s over 683,333 percent more deaths than egg-borne Salmonella. While more honest health advice from our regulatory agencies wouldn’t prevent all of these deaths, it defies all logic to posit that our current regime is doing more good than harm in this respect.

The FDA regulates about 78 percent of the US food supply. While it evidently has time to spare cherry picking the data it presents to the public on egg-borne salmonella, it seems to have been distracted from its founding mission. One in five Americans develop skin cancer in their lifetimes, but the FDA hasn’t gotten around to approving new sunscreen active ingredients in nearly three decades. Life-saving drugs often take 12 to 15 years to comply with the requirements of regulatory review, but the FDA made sure not a minute was wasted greenlighting, en masse, opioid prescriptions for cases of minor chronic pain. Many giant problems within the FDA’s purview face the American public. Every minute and dollar the FDA spends tilting at windmills is to the detriment of the people it purports to serve.

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