The USDA’s 1971 lung-meat ban makes no sense, according to this doctor

The USDA’s 1971 lung-meat ban makes no sense, according to this doctor

On Jonathan Reisman’s first day of medical school, his anatomy professor pointed out which parts of the human cadaver corresponded to which cuts of meat, and thus began Reisman’s obsession with eating organs. Animal organs, that is: He started dissecting goats and sheep on the side while studying, cooking, and eating as he went.

Now Reisman, a doctor and the author of The Unseen Body, hosts organ-meat tasting dinners. (He has occasionally written about his culinary adventures for Slate). But there’s one organ he can’t legally serve: animal lungs.

The U.S. Department of Agriculture banned the sale of lungs for human consumption in 1971.  Reisman is hoping to flip the ban. Last month, he filed a petition with the USDA’s Food Safety and Inspection Service office, stating that “a food being ‘gross’ is not the same as it being unsafe.”

So far, Reisman’s petition has garnered 16 public comments; 15 for and 1 against. It is one of just 20 petitions submitted to FSIS in the past five years, most focused on industry minutiae or animal rights.

“I’ve never seen anyone fall ill from ingesting a lung,” wrote Nicholas Napoli in a comment on Reisman’s petition. Napoli, a doctor in rural Alaska where Yup’ik cuisine features seal, walrus, and beluga whale lung, thinks the ban comes down to “unfamiliarity and fear” rather than science. Others weighed in to make the same point. In fact, the U.S. is one of the few countries that does not allow people to buy or sell lungs.

Even if you don’t want to chow down on a breathing apparatus with Reisman, the lung-meat ban is an interesting case study in how our perceptions of ickiness and health shift depending on the cut of meat in question—and who is eating it.

Whether eating lungs is definitively “safe” is up for debate: There’s a lack of peer-reviewed toxicology or epidemiology studies on lung consumption with which to make a definitive case one way or the other. But there’s no question that the lung ban is an oddity: Other potentially risky protein options are usually regulated, not banned. And, again, plenty of societies make lung a regular part of their diets, without obvious ramifications.

The argument against lungs goes like this: Lung meat, which is spongy, may be extra likely to harbor microorganisms compared to other cuts. Cooking meat thoroughly gets rid of most of that risk, but lungs get leathery when well-done—so many people may not cook them through.

Further, animals breathe in not just microorganisms, but plenty of other things that can get trapped: wildfire smoke, car exhaust, asbestos fibers, etc. “Lungs are basically air filters,” wrote USDA veterinarian Renee Chicoine in a comment on Reisman’s petition. “Human beings should not be eating dirty air filters.” Swallowing asbestos can cause health problems, just like breathing them can.

There are a few counters to these points. First, we’re constantly swallowing our own lung particulate matter, says Reisman. “Our lungs clean themselves,” he said. “The mucus drags all these particulates up to our throats and we swallow it subconsciously literally every day of our lives.”

Plus, some particles don’t get stuck in animals’ lungs and mucus—very small particles can migrate into animals’ bloodstreams. If an animal is breathing in a lot of bad stuff, meat from the whole animal can come with a health risk. This is why, for example, the U.S. bans meat contaminated with high levels of pesticides.

For better or worse, though, environmental contamination in other food contexts often triggers not bans, but strongly worded suggestions. In January, for example, the Food and Drug Administration released voluntary guidelines asking food companies to reduce traces of lead in baby food. Some guidelines eventually lead to strict limits, which the USDA then enforces for producers, but many do not.

Often, as consumers, we are left to weigh the risks ourselves. Think of the lead dust on cocoa beans processed near freeways (recently in the news after a Consumer Reports investigation), or the mercury that fish breathe in through their gills. Both heavy metals are dangerous for humans, but we are still allowed to eat chocolate and fish.

Environmental toxins are allowed in many foods because many foods are unavoidably contaminated thanks to decades of pollution in the U.S. and abroad. State and federal agencies offer conflicting advice to consumers about safe levels and how to navigate those risks. Often, the advice boils down to eating a varied diet and hedging your bets.

Interestingly, lung meat is allowed in pet food, which is regulated by the FDA (cats, for what it’s worth, prefer liver). Canned pet food is cooked to high temperatures, which mitigates the risk from pathogens, but pet owners can also buy completely raw lung meat and feed it to pets raw. Dogs have stronger stomachs than we do, but dogs can still get salmonella, pass it on to humans, and contribute to antibiotic-resistant salmonella strains. If undercooked lung is risky, it is risky in this context too—but the FDA has not felt it necessary to copy the USDA’s ban.

There is one more salient point from the no-lungs side. During slaughter, stomach contents can get into animals’ lungs through a kind of acid-reflux reaction. Stomach contents can spread disease, and the USDA FSIS has a zero-tolerance policy for this “ingesta” if spotted. “The zero tolerance standard alone should be enough to shut this petition down,” wrote Chicoine, the USDA veterinarian. When the ban was first introduced, the Associated Press wrote that “regular inspection procedures were not considered adequate to detect all diseased or otherwise unfit lungs.”

The USDA declined to comment on the record about what kinds of procedures might be adequate, so I asked Elena Gafenco, head veterinarian for Scotland’s Food Standards department. Scotland produces lots of sheep’s lungs, many of which find their way into haggis. Gafenco explained their process in an email: Essentially, ingesta may get from the stomach to the lungs via the throat—but this contamination is noticeable during inspections. If inspectors see ingesta around the trachea, then they do a detailed lung inspection.

The U.S. could un-ban lung and decide to set new inspection standards, like Scotland’s throat check. Perhaps new standards would be logistically difficult for slaughterhouses to follow. Then, the question of selling lungs would be a business decision: If safe inspections are time-consuming and therefore costly, slaughterhouses could just decide whether lungs are worth selling. This might make the ban a moot point. Three companies control most slaughter in the United States today—it’s not clear that they would have an incentive to introduce strict lung-meat inspections, should they be given the option of selling it.

The people who eat lung meat have historically eaten it because it is practical. One widely printed 1967 recipe, for example, recommended Lungen Stew specifically because lung meat was economical. Today, the Peruvian government distributes canned lung meat to fight childhood anemia because it is a particularly cheap source of iron and protein. “It’s inexpensive” is a good reason to eat lung, but it doesn’t bode well for creating a powerful lobby.

There’s one more reason the lung ban may exist, and that is that it was written during a xenophobic backlash. Asian immigration caps were lifted in 1965; three years later, the first Wholesome Meat Act enforcement action was against a Chinese-American company. Maybe that’s a coincidence—but lung was certainly not popular in mainstream American culture. Making lung disappear was easier than tailoring new regulations to accommodate it safely.

Banning a “dirty” cut of meat is also easier than tackling the risky particles themselves. The U.S. could, for example, put more energy into addressing the antibiotic overuse that is making foodborne pathogens increasingly dangerous. Or, if unilateral bans are on the table, it could start by banning the fossil fuels that pollute both animal lungs and our own.

The USDA’s 1971 lung-meat ban makes no sense, according to this doctor

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