The federal count of the Cyclospora outbreak is 1,947 people in nine states, with 98 hospitalizations, no deaths, and illness onsets running from June 22 (what happened to May?) through July 20. Michigan by itself reported 9,253 cases on Monday, with 160 hospitalized as of July 23 and illness in 72 of the state’s 83 counties. Add up what the fifty states publish on their own pages and the national floor sits somewhere past 16,000. Three questions live inside that gap, and they are the questions that decide who gets counted as a victim of this lettuce and who does not.

First, what are the chances the nine-state outbreak is not Taco Bell or Taylor Farms at all as some have been spinning here at IAFP, and is instead a different restaurant or a different product? Second, what are the chances Taylor Farms is behind other Cyclospora illnesses in those same nine states that are not counted as Taco Bell cases? Third, what are the chances Taylor Farms is behind cases in the other states its product reached? Here are my answers and the numbers I used to get to them.

The first question is the easiest, and my answer is about one chance in ten — almost none of which is “a different restaurant.” Start with what the 1,947 actually is. FDA’s advisory says it plainly under the heading Stores Affected: cases with Taco Bell exposure have been reported from nine states. Taco Bell exposure is the case definition. The chance these people did not eat at Taco Bell is zero, and the chance that 1,947 people across nine states shared that exposure by coincidence is not worth writing down.

The real question inside the question is whether the ingredient is right. Michigan did the work that answers it. The state analyzed food exposure details from 190 of the Taco Bell cases and found that 90 percent of those interviewed had eaten iceberg lettuce. FDA’s traceback converged on a single supplier serving those locations. Taylor Farms then recalled all iceberg sourced from central Mexico and, as of July 18, suspended production of everything at the Doctor Mora plant. A company does not shut a plant over an ingredient it has ruled out.

Against that, there is no confirmed positive product sample, and the one that was announced was withdrawn. There is no published genetic match between the patients and the product. CDC noted early that not all Taco Bell locations in these states received shredded iceberg from the same supplier. I would put roughly eight to ten percent on a different Taco Bell produce item or a second supplier alongside Taylor Farms, and about two percent on something outside Taco Bell altogether.

One distinction has to stay separate. “Taylor Farms is the source” and “the recalled lots are the source” are different claims. The recalled foodservice product shipped June 29 through July 16. The earliest exposures in this outbreak precede that window. Taylor Farms can be the right answer while the recall is the wrong instrument.

The second question — whether Taylor Farms is behind the illnesses in those nine states that are not Taco Bell cases — gets a much higher number. I would say ninety percent that some of it is, and more likely than not that a large share of it is. The reason is structural rather than scientific. A man in Toledo who ate from a five-pound Sysco bag in a hospital cafeteria cannot enter the 1,947. A woman in Kansas who bought a Marketside bag at Walmart cannot enter it either. Neither of them ate at Taco Bell. They are excluded by the definition, not by the evidence.

Everything else points the same direction. The recalled foodservice product went into all nine outbreak states, and Sysco distributes those bags to hospitals, ballparks and restaurant chains. Michigan’s chief medical executive, Dr. Natasha Bagdasarian, has said her state’s investigation did not identify a single fast-food chain as the source, and that about twelve percent of patients have no clear link to lettuce or to a fast-food chain — which means roughly eighty-eight percent do, and most of those people are not Taco Bell cases. Michigan’s health department still says no specific produce type, grower or supplier has been identified as the source of its outbreak and that other foods cannot be ruled out. The nine states together report something on the order of 14,200 illnesses against a federal outbreak count of 1,947.

What I cannot do is put a defensible share on it. My range for the roughly 12,000 non-outbreak cases inside those nine states is that forty to seventy percent are the same product moving through channels other than Taco Bell, with the rest divided among ordinary background illness, travel-associated cases, and the testing surge that any well-publicized outbreak produces. Nobody will narrow that range without genotype comparison or lot-level traceback, and neither exists yet.

There is a plainer reason many of those cases are in nobody’s outbreak count. Ingham County has reported about 700 cases and has five nurses. It investigated about half of them and then decided to drop the older ones in order to keep up with the new. Michigan also reported 1,077 new cases on Monday, 475 of which were not previously reported because of delayed lab testing. Those people were not excluded from the outbreak because they failed a test. They were never asked the question.

The third question — whether Taylor Farms is behind cases in the other states its product reached — is where the arithmetic runs against the intuitive answer, and it is worth doing in public. Divide the country into three groups and compare rates instead of raw counts. The nine outbreak states hold about 67 million people and report roughly 14,200 illnesses, or about 21 cases per 100,000. The nineteen states that received recalled Taylor Farms product but are not in the outbreak hold about 155 million people and report roughly 1,400 illnesses, or about 0.9 per 100,000. The twenty-two states that received none of the product hold about 112 million people and report roughly 1,020 illnesses — also about 0.9 per 100,000.

Receiving the recalled lettuce, outside the nine, is associated with no measurable excess at all. Whatever this product did, it did more than twenty times as much of it inside the nine states, and beyond them it leaves no fingerprint that state-level numbers can see.

That is not the same as zero. Jack in the Box confirmed recalled lettuce reached its restaurants in Texas, Oklahoma and Louisiana. Marketside bags went to Walmart stores in fifteen states. Contaminated product shipped into nineteen more states did not make nobody sick. My estimate is tens to low hundreds of cases spread across all nineteen, identifiable one person at a time and only where somebody still has a bag, a receipt or a lot code. Call it eighty percent that some of those cases are out there and twenty-five percent that they amount to a large share of the 1,400.

Two honest counterweights belong with that. Those nineteen states never got the testing surge Michigan and Ohio got, so their counts sit closer to baseline and a real signal could be buried under ordinary underdiagnosis. And Alabama, Mississippi and South Carolina received recalled product and publish no case count at all, so part of my denominator is a guess.

What would settle any of this is not new science. CDC has run targeted sequencing on Cyclospora since 2018 for precisely this purpose, to tell apart clusters that look like one outbreak. Four questions follow, and the data to answer all four is already in federal hands.

Have the cases in the nine states who did not eat at Taco Bell been genotyped against the cases who did? That single comparison would resolve my second question, which is the one that covers the most people.

Has any case from the first half of the epidemic curve been walked back to a lot code? If a June illness traces to Doctor Mora product shipped before June 29, the recall never covered the front end of this outbreak.

Were the roughly 14,000 counted cases outside the outbreak definition ever screened against that curve, or were they set aside because no interviewer ever reached them?

And why did the case definition move? CDC’s first notice put the earliest onset at June 22. The July 17 update moved it to May 13. The July 24 update moved it back to June 22 and added four states. Forty days went out of the definition and came back, and no explanation has been attached to either move.

A lot-level traceability rule would have answered the lot-code question in twenty-four hours. It was supposed to be law on January 20 of this year. The first people in this outbreak got sick in the spring.

None of these questions are rhetorical. Every one of them can be answered with records the government already holds. Until somebody answers them, the number that gets printed — 1,947 — describes how many sick people ate at one restaurant chain. It does not describe how many people this lettuce did or did not make sick.

Seven members of Congress have written seven letters about this outbreak in the last fourteen days. Not one of them has been publicly answered. The most recent went out Monday morning, and it is the first one addressed to a company rather than to the government: Rep. Robert Garcia of California, the ranking member of the House Oversight Committee, wrote to Bruce Taylor, the chief executive of Taylor Fresh Foods. Michigan reported 9,253 cases the same morning. Here is the whole file, in order, and what each letter is asking for.

Sen. Amy Klobuchar of Minnesota went first on July 14, writing to both acting agency heads. Her ask is a restoration list: FoodNet, the Food Emergency Response Network, the Food Safety Inspection Service, the Public Health Infrastructure Grants and the Preventive Services Block Grant. “As a currently uncontrolled large foodborne outbreak across the country continues, cuts to these programs are impacting our nation’s ability to prevent, detect, and contain foodborne illnesses,” she wrote. The line in her letter that has aged best is the one about what was lost structurally rather than financially: there is no longer a central location for reporting and comparing data across state lines.

Rep. Greg Stanton of Arizona wrote to Secretary Kennedy on July 15 and asked the six questions an investigator would ask. Who directed the decision to cut FoodNet’s required surveillance from eight pathogens to two, and what scientific or budget analysis supported it. What funding has been reduced or redirected since January 2025. How many people working on foodborne and parasitic disease surveillance have been terminated, reassigned, or left vacant. Which system now performs the active laboratory outreach FoodNet used to do. How many personnel are on the federal Cyclosporaresponse right now. And what evidence supports the department’s claim that none of this affected the investigation. He wants answers by August 3. He is a Representative, not a senator, which some of the coverage has gotten wrong.

Sen. Jon Ossoff of Georgia wrote on July 16 and did not bury the thesis. “Your foolish and self-indulgent demolition of critical public health programs puts Americans at risk,” he told the Secretary. He asked three questions — has FoodNet been restored to require tracking of Cyclospora cayetanensis, why was it terminated, and where do the investigations stand — and gave HHS seventy-two hours. That window closed on July 19. HHS told reporters his criticism was inaccurate and that CDC never stopped monitoring cyclosporiasis.

Four members of the Michigan delegation — Debbie Dingell, Kristen McDonald Rivet, Hillary Scholten and Rashida Tlaib — wrote to both acting agency heads on July 17 under the headline “Cut the Crap.” Theirs is the longest and, for my money, the best of the seven, because it is the only one written from inside the outbreak. It asks what CDC’s actual assessment of the scope is by state and what is limiting the count. It asks whether CDC and FDA have met with the Michigan health department at all. It asks whether the federal agencies agree with Michigan’s own investigators that lettuce or salad greens are the source — a question they had to ask because on July 17 the federal government had not yet said so. It asks what barriers are preventing the agencies from acting on leads Michigan investigators had already developed, how many federal personnel are on this outbreak compared with comparable outbreaks over the past five years, and whether there is any plan to restore mandatory FoodNet participation. They asked for a response by July 24. Their letter cites Michigan at more than 3,700 cases. The state is at 9,253 today. Michigan’s two senators, Gary Peters and Elissa Slotkin, did not sign it, and I could not find a separate letter from either one.

Rep. Josh Gottheimer of New Jersey announced three things at a hospital in Teaneck on July 20: a letter to CDC demanding FoodNet be restored to mandatory active surveillance, a bipartisan bill with Rep. Don Bacon of Nebraska — the Foodborne Illness Rapid Response Act, which would bar staff cuts and hiring freezes at CDC’s foodborne-illness divisions for a full year after an outbreak is detected — and his support for the Federal and State Food Safety Information Sharing Act, which would let FDA hand unredacted inspection findings to the state and local inspectors who do roughly sixty percent of the food-processing inspections in this country. That last bill is the one nobody is covering and the one that would change the most. Neither has a bill number yet. His release that day put the outbreak at about seven thousand cases across thirty-four states; Michigan alone passed that figure inside of a week. One caution on his remarks: he told the room that because FDA’s positive sample turned out to be a false positive, “we don’t even know where it’s coming from.” FDA has said the opposite, in capital letters, on its own page — the retracted sample does not change the basis of the investigation or the overwhelming epidemiological data behind the recall.

Sens. Richard Blumenthal of Connecticut and Cory Booker of New Jersey wrote to CDC the same week, asking for a briefing on how the outbreak was tracked and whether federal staffing cuts caused the delay. Blumenthal put it to Connecticut reporters as a demand to know about “the apparent incompetence in tracking and tracing.” They asked for answers by the end of the following week.

Which brings the file back to Monday, and to Rep. Garcia. What he wants by August 10 is five categories of documents and five written answers: every communication with FDA, CDC and USDA about cyclospora since May 1; every communication with the White House since January 21, 2025; all internal cyclospora communications; everything on the July 17 recall; and every inspection, audit or contamination record for the Taylor Farms de Mexico facilities going back to January 1, 2013 — 2013 being the year the same Guanajuato operation was tied to a Cyclospora outbreak that sickened more than six hundred people in twenty-five states. The written questions are the plainest anybody has put to this company in three weeks, starting with the full list of retailers and restaurants that received recalled produce.

The paragraph in his letter that will travel farthest is about timing. Taylor Farms gave $1 million to MAGA Inc. in March 2025, and Garcia writes that the donation landed less than one week after the administration agreed to delay FSMA 204, the lot-level traceability rule that would make it possible to trace a bag of shredded lettuce back to the field in twenty-four hours instead of three weeks. FDA announced that thirty-month delay on March 20, 2025, and Congress made it binding that November. Two figures in the letter need checking before anyone repeats them — it says Taylor Farms spent over $810 million on lobbying, which is off by orders of magnitude against the Wired reporting it cites, and the footnote behind the $1 million contribution is dated March 2024 while the text says March 2025. A Taylor Farms spokesman told CBS News the safety of its food is paramount and pointed again to the absence of any confirmed positive product test. White House spokesman Kush Desai called the notion that this administration would compromise on public health “absolutely false,” and defended FDA, saying the agency has never walked back the epidemiological evidence pointing at the Taylor Farms de Mexico shipment. People ate the evidence, which is the answer to the no-positive-sample point: shredded iceberg has about a two-week shelf life, and the first illnesses began in mid-May.

There is one more piece of congressional pressure that is not a letter. On July 15 the Senate health committee held the confirmation hearing for Dr. Erica Schwartz, the nominee to run CDC. Sen. Patty Murray of Washington asked her whether there was any “scientific or medical justification” for eliminating mandatory reporting of the parasite and asked her to commit to reinstating it. Schwartz would not commit; she offered instead to work with Murray’s staff and CDC scientists to understand what happened and what could be done. Chairman Bill Cassidy of Louisiana named the outbreak in his opening statement as one of the things the nominee would have to rebuild public trust on. Schwartz is still awaiting a vote. CDC has had no confirmed director since Susan Monarez was fired after twenty-nine days last August.

Against seven letters and a confirmation hearing, here is everything the top of this administration has said. On July 16, press secretary Karoline Leavitt said the administration “has a handle” on it and that CDC and FDA have the resources they need. On July 21, at a health care fraud briefing, Secretary Kennedy said “We do have the outbreak under control”and, of the surveillance criticism, that “those criticisms are invalid.” On July 24, asked at a press conference when it would be safe to eat lettuce again, President Trump said, “I don’t know, I haven’t thought about it,” said it was the first time he had been asked, and then proposed a tariff on Mexico over the lettuce. On July 27, the White House called the collusion claim absolutely false. That is the complete list.

The career staff have been more useful than the principals. Acting FDA Commissioner Kyle Diamantas stressed on July 20 that the investigation continues, including into other potential sources and commodities. Kari Irvin, deputy director of FDA’s outbreak response network, told NBC News on July 24 that FDA has multiple Cyclospora investigations open. Gwen Biggerstaff, a deputy director at CDC, has been the only person at that agency speaking publicly through the entire outbreak. I searched for a public statement on this outbreak from Jay Bhattacharya, who has been performing the duties of CDC director since February while also running NIH, and could not find one.

Three things about this record are worth saying plainly. The first is that all seven letters were written by Democrats. The only Republican names anywhere in this file are Don Bacon, who cosponsored Gottheimer’s bill, and Bill Cassidy, who mentioned the outbreak in a hearing he was chairing. Nobody in the majority has sent a letter.

Foodborne illness has historically been the least partisan subject in Washington — the Food Safety Modernization Act passed a Democratic House and was signed by a Democratic president after being written with Republican senators, and the program whose destruction everybody is now writing about, the USDA Microbiological Data Program, was killed under President Obama.

The second is that six of the seven letters are aimed at FoodNet, and FoodNet is not the instrument that finds outbreaks. It is a ten-state active surveillance network built to measure trends. NNDSS and PulseNet are the detection systems. My friend Barbara Kowalcyk has made this point publicly and she is right: the FoodNet cut did not cause this outbreak. What it cost is the trend data you would need to say how bad this year is compared with last year, which is exactly the argument everybody is now having without the data to settle it. The FoodNet cut belongs on the list. It is not the list. Garcia’s letter is the first of the seven to name the traceability rule, which is the thing that would actually have shortened this month.

The third is that not one of these letters has been publicly answered. Ossoff’s seventy-two hours expired on July 19. The Michigan delegation’s deadline expired on July 24. Stanton’s expires next Monday and Garcia’s two weeks after that. The administration has responded to the letters the way it has responded to the outbreak, which is through spokespeople, in the past tense, and to reporters rather than to Congress.

None of this is new. The Senate Permanent Subcommittee on Investigations held a hearing on Cyclospora and imported raspberries in July 1998 and called a CDC epidemiologist and a patient to testify about it. Rosa DeLauro wrote to FDA and CDC in August 2013, during the outbreak that traced to this same Mexican facility, asking whether the agencies considered it acceptable to identify the source of an outbreak and withhold that information from the public. She wrote again in August 2018, about the Fresh Express outbreak, complaining that the timeline did not instill confidence that FDA had acted in consumers’ interest. Thirteen years and eight years later, the questions in the mail this month are the same questions.

There is a version of this where the letters are theater, and I have watched enough of them to know it happens. This is not that. Stanton is asking who signed the decision. The Michigan delegation is asking why the federal government would not act on leads its own state investigators had already developed. Garcia is asking for the emails. Those are answerable questions with documents behind them, and the reason to answer them is not that a member of Congress asked. It is that 9,253 people in one state are sick, the count is still climbing past 16,000, and the government cannot yet tell anybody how the parasite got into the lettuce.

Hello from IAFP in NOLA.

Susan Mayne ran the FDA’s Center for Food Safety and Applied Nutrition from 2015 to 2023 — eight years running the center that regulates nearly everything on the produce aisle. On Thursday she published a piece at STAT, first posted on her own Substack, and it is the most useful thing anyone who has actually held that job has written about this outbreak. Go read it.

Her argument fits on a bumper sticker and is serious enough to organize an agency around. Nutrition and food safety are not two programs. They are one. You cannot tell the country to eat more fresh produce while thinning out the machinery that keeps produce from making people sick, because the foods on FDA’s own Food Traceability List — leafy greens, herbs, melons, tomatoes, cucumbers, peppers, sprouts, fresh-cut fruit — are the same foods on the Eat Real Food poster. She lands it in six words. Real foods are vulnerable to real pathogens.

She names the reaction that worries her, and it worries me too. Ten minutes on social media will find people switching to pizza, insisting Oreos never gave anybody explosive diarrhea, saying they would sooner eat a bag of Doritos than a salad. I have watched this after every leafy green outbreak for thirty years. Nobody wins that trade. The person who quits vegetables over a Cyclospora headline is not safer, just differently sick on a longer timeline, from something that will never make the news.

What makes the essay worth more than a share button is the list. Mayne sets out six things done over the past eighteen months that undercut microbial food safety, and makes a point worth reading back to every official who answers for one of them in isolation: no single item explains what is happening. It is the accumulation. She names the loss of experienced career staff — and in Oakland County, Michigan, seven people, four communicable disease nurses and three epidemiologists, are working 710 cases in interviews that run up to forty-five minutes each. She names budget cuts that cascade to the states — and Michigan is down twenty-three infectious disease workers and one hundred twenty-three county health staff, borrowing people and recruiting volunteers. With less money, she adds, FDA also does less proactive sampling. Fewer samples look exactly like a cleaner food supply, right up until somebody counts the sick.

She names what was done to FoodNet, which tracked eight pathogens until six were dropped from federal surveillance, Cyclospora among them, effective July 1, 2025 — so when you hear this is the largest cyclosporiasis outbreak in American history, the instrument built to measure that question was switched off ten months before the first person got sick. She names the food traceability rule, in force today on paper, pushed to July 2028 in fact. She names the closed Beltsville laboratories that worked on a parasite with no cell culture system and no animal model. And she names the disbanded advisory committee that would have told FDA whether a wash step can be validated against it — exactly what FDA told Taylor Farms de Mexico to re-evaluate in its 2013 environmental assessment, after the last outbreak traced to the same company in the same Mexican growing region.

Put the numbers next to her list. CDC counts 1,947 people in nine states. Its surveillance page separately carries 4,173 laboratory-confirmed domestically acquired cases with more than 7,400 awaiting confirmation. The states themselves report better than 16,600 sick. Michigan alone went from 8,176 to 9,253 between Friday and this morning. And FDA is running six separate Cyclospora investigations, only one tied to the iceberg lettuce.

That gap is exactly what Mayne is describing. A weakened food safety system does not produce fewer illnesses. It produces fewer counted illnesses. The parasite does not care about a hiring freeze. The only thing that changes is how many of the people it sickens ever appear in a number a federal agency is willing to stand behind.

Thank you, Dr. Mayne. A lot of us on the outside have been saying some version of this for a year, and it lands differently coming from the person who actually ran the center — about agencies she used to lead, with her name on it, in public. That costs something, and it is worth considerably more than another press release from a plaintiff’s lawyer, including mine.

She spent eight years building the part of this system that watches produce, and she has now spent a week telling the public what it looks like coming apart. That is not a complaint from the sidelines. That is testimony. Read her piece, thank her for writing it, and then ask the people who made every item on her list which one they intend to reverse first.

The map below crosses two questions against each other for all fifty states. Did the state receive iceberg lettuce that Taylor Farms de Mexico recalled on July 17? And does the state publish a 2026 Cyclospora case count of its own? Those two questions produce four groups, and the four groups do not line up the way a single-source outbreak would predict.

State totals are each state’s own published 2026 figure as of July 27, 2026. Distribution follows FDA’s two recall lists, which cover the recalled lots only. Full provenance for every number is in the table at the end of this post.

Twenty-five states in green received the recalled lettuce and report cases. Together they report 15,666. Three states in yellow received the lettuce and publish no case count at all. Ten states in blue report cases and received none of the product, and they report 1,014 between them. Twelve states in grey received none and publish nothing. Add the two figures that exist and fifty states report 16,680 people sick, against the 1,947CDC counts in the outbreak itself.

Those figures moved while I was writing them, which is the point of putting a date on everything. On Monday, July 27, Michigan went from 8,176 cases to 9,253 — 1,077 more in three days, its sharpest jump yet. Pennsylvania, where cyclosporiasis is not a reportable condition and physicians report voluntarily, went from 28 to 48. And Virginia nearly doubled, from 79 to 126, with its domestic count rising from 38 to 66 while its travel-acquired count went from 27 to 31. The fifty-state floor rose by more than eleven hundred people in three days. CDC’s outbreak count did not move at all.

Green holding roughly ninety-four percent of the counted illness in this country looks, at first glance, like the recall explaining the outbreak. Then you look at what is inside green. Michigan alone is 9,253 of that 15,666 — more than half of every counted case in the United States, and it added 1,077 of them in the three days to Monday. Take the nine outbreak states out and the sixteen remaining green states hold about 1,410 illnesses, which is the same order of magnitude as blue’s 1,014. One of those two groups received the recalled product and one did not, and they are reporting comparable numbers.

Blue is the group worth sitting with. Ten states that received none of this lettuce report better than a thousand illnesses, and New York alone is 666 of them. Whatever made those people sick did not come off Taylor Farms’ recall list.

The three yellow states are Alabama, Mississippi and South Carolina. All three appear on FDA’s distribution list. None of them publishes a case count. Their zero on this map is a reporting fact and not an epidemiological one, and I want to be as clear about that as I can be: it does not mean nobody in those states is sick. It means nobody outside those health departments can find out.

Here is how the map was built, because a map is only as good as what went into it.

The distribution side comes entirely from FDA’s nine-state investigation page, which publishes two separate lists. Recalled foodservice product went to twenty-seven states between June 29 and July 16. Marketside-brand iceberg salad and shredded lettuce went to Walmart stores in fifteen states. Fourteen states appear on both lists, thirteen received product through foodservice only — including Michigan, Ohio, Illinois and Pennsylvania, so the two hardest-hit states in the country got this lettuce through a distributor and never off a shelf — and West Virginia appears on the retail list alone. Combined, the footprint is twenty-eight states. FDA carries its own caveat on that page, and it belongs here too: distribution is confirmed only for the states named, and product may have reached others.

The case-count side is each state’s own published number rather than CDC’s, because state health departments sit closer to the illnesses and update more often. That choice has a cost, and the cost is that the numbers are of different ages. Michigan and Indiana post on weekdays, West Virginia on Tuesdays and Fridays, Virginia on Mondays at 10 a.m. with data through the previous Thursday, Ohio and Kentucky weekly, CDC weekly. Any national total assembled from them blends figures stamped on different days. Five states publish bands rather than numbers, and for those I used the low end. Ohio has still not posted a statewide figure of its own, so its number is CNN’s 2,574 — NBC reports 2,596 for the same date, and the map footnotes both.

Three limits on this map are worth stating plainly rather than burying, and a fourth one after them. The first is the one above about the yellow states, and it applies to the twelve grey states too: fifteen states publish nothing, and silence is not zero. The second is that CDC reports 41 states with at least one domestically acquired case this season but does not publish which forty-one, so this map uses published state counts as its proxy and says so in its legend rather than claiming to show domestic acquisition. The third is that every total here is a floor. It counts only laboratory-confirmed and state-reported illness, which for a parasite most people never get tested for is a fraction of the real number.

There is a fourth limit, and it is the one that matters most for how the distribution side of this map should be read. What FDA published is a recall footprint, not a product footprint. The foodservice list covers lettuce shipped June 29 through July 16. The retail list covers Marketside bags with Best if Used By dates running July 18 to August 3. Taylor Farms de Mexico was not shipping iceberg for the first time on June 29. Whatever left that plant in May and the first three weeks of June went somewhere too, and none of it appears on any list — because by the time the recall issued on July 17, it was gone. Shredded iceberg runs about two weeks of shelf life. The lettuce that made the earliest people in this outbreak sick had passed its date and gone into a dumpster weeks before anybody drafted a notice.

Which means a state shaded blue on this map received none of the recalled lots. It does not mean it received no Taylor Farms lettuce. Those two things are not the same, and the map cannot tell them apart, and neither can FDA’s lists — the only way to establish that a state got contaminated product on an earlier shipment is a lot-code traceback, and nobody has published one. The limit cuts at green as well: a green state received recalled product, which is not the same as saying recalled product is what made anybody there sick.

This is the oldest problem in a foodborne case, and it is worth naming plainly. The people who get sick first eat the evidence. There is no bag left in a walk-in to swab, no pallet sitting in a warehouse to hold, no lot code on anybody’s plate. A recall can only ever reach forward from the day somebody notices, and every illness that happened before that day is outside its reach by definition. That makes the recall footprint on this map a floor too, in exactly the way the case counts are.

And one thing this map cannot do, which no map can. It shows where product went and where illnesses were counted. It does not show causation. A green state is not a state where the lettuce is proven to have made anybody sick, and a blue state is not a state where it is proven not to have. What the map does show is that the recall footprint and the illness footprint are not the same shape — and that the difference between them is about a thousand people in states that never received the product at all.

The full provenance is below. Every case number on the map, the color it produced, and a link to where it came from.

State2026 cases reportedMap colorWhere the number comes from
AlabamaNo count publishedYellowFDA distribution list
Alaska5 (Jul 16)BlueAlaska DOH health advisory
Arizona19BlueAZ DHS, via roundup
Arkansas26 year to dateGreenAR DOH, via roundup
California41 provisional (Jul 14)BlueCDPH news release NR26-024
Colorado150BlueCDPHE, via roundup
Connecticut35GreenCT DPH press release
DelawareNo count publishedGreyCDC surveillance
Florida106GreenFL DOH, via roundup
Georgia11–30 since May 1GreenGA DPH, via roundup
HawaiiNo count publishedGreyCDC surveillance
IdahoNo count publishedGreyCDC surveillance
Illinois513 (Jul 24)GreenCNN / CBS Chicago
Indiana710 (Jul 24)GreenCNN
Iowa57GreenIowa HHS, via roundup
Kansas289 (Jul 22)GreenKDHE newsflash
Kentucky468 (Jul 24)GreenCNN
Louisiana1–10GreenLA DOH, via roundup
MaineNo count publishedGreyCDC surveillance
Maryland69GreenMD DOH, via roundup
Massachusetts18GreenMA DPH, via roundup
Michigan9,253 (Jul 27)GreenMDHHS outbreak page
Minnesota41 since May 1BlueMDH, via roundup
MississippiNo count publishedYellowFDA distribution list
Missouri216 (Jul 19)GreenKBIA
MontanaNo count publishedGreyCDC surveillance
Nebraska49BlueNE DHHS, via roundup
NevadaNo count publishedGreyCDC surveillance
New Hampshire1–10GreenNH DHHS, via roundup
New Jersey46 (May 1–Jul 11)GreenNJDOH news release
New MexicoNo count publishedGreyCDC surveillance
New York666 incl. NYC (Jul 25)BlueOutbreak News Today
North Carolina561 (Jul 21)GreenNCDHHS / NBC
North DakotaNo count publishedGreyCDC surveillance
Ohio2,574 or 2,596 (Jul 24)GreenCNN / Lucas County
Oklahoma172 (Jul 21)GreenCNN
OregonNo count publishedGreyOHA advisory
Pennsylvania48 (Jul 24)GreenPA DOH, via roundup
Rhode Island4 since May 1BlueRI DOH, via roundup
South CarolinaNo count publishedYellowFDA distribution list
South DakotaNo count publishedGreyCDC surveillance
Tennessee11–30GreenTN DOH, via roundup
Texas68 (Jul 13)GreenTexas DSHS
Utah1–10BlueUT DHHS, via roundup
VermontNo count publishedGreyCDC surveillance
Virginia126 confirmed (Jul 23)GreenVirginia DH
Washington38 (May 1–Jul 17)BlueWashington DOH
West Virginia226 (Jul 24)GreenWV OEPS
Wisconsin61 (May 1–Jul 15)GreenWI DHS, via roundup
WyomingNo count publishedGreyCDC surveillance

Phyllis Entis published something at eFoodAlert on Sunday that anyone covering this outbreak should read before they write another word about it. She looked at the epidemic curve CDC finally posted on July 24 and saw two things nobody else had said out loud. The curve begins right at a peak. And it has twin peaks. Then she asked the question that matters, which is why.

She also did the work that makes the question answerable. She set CDC’s new curve beside the agency’s own Cyclospora curves from 2019 and 2020, both from leafy green outbreaks, and both of them behave the way outbreak curves behave: a few cases, then acceleration, then a peak, then a fall. Her sentence about it is the one to keep. “An outbreak does not burst onto the scene at the peak of its strength.”

Start with the shape. Read the bar heights off CDC’s chart and they sum to 1,946 against the agency’s stated 1,947, so the numbers below are essentially the published ones. The first peak crests on Wednesday, June 24, at 157 cases. The curve falls to 19 on Thursday, July 2. It climbs back to 152 on Thursday, July 9. Split it at the trough and this outbreak divides into 946 cases and 1,000 — a near-even halving of the total, fifteen days apart.

Phyllis offers three possibilities for the twin peaks: a lag in state reporting, a lag in collation at CDC, or the peaks are real. Here is what narrows it. In most outbreaks of intestinal illness, a second hump is secondary transmission — the first wave of sick people infects a second. Cyclospora cannot do that, and Phyllis explains exactly why in her own opening paragraphs. The oocysts come out of a sick person in an inactive form and need days in the environment before they can infect anyone, and the human gut is the only place this parasite lives. Nobody in this outbreak caught it from another person. A second wave therefore requires a second exposure. There is no third possibility.

Then there is the front of the curve, and this is where her reporting and my complaining meet. CDC’s first notice on July 14 put the earliest illness onset on June 22. On July 17 the agency moved it to May 13. On July 24 it moved back to June 22. Out forty days and back again, with no explanation attached to either move.

In that same July 24 update, the confirmed count went from 1,644 people in five states to 1,947 in nine, and Michigan fell from 1,141 cases to 931. At least 210 people who were part of this outbreak on July 17 were not part of it on July 24. Since the national number rose by 303 while four states were added, the gross additions were at least 513. None of those Michigan patients stopped being sick. They stopped being counted.

And here is the point Phyllis makes almost in passing, which I think is the sharpest thing written about this outbreak in a week. We cannot see what was removed. CDC had no epidemic curve on July 17, when the range still began May 13. It published its first one on July 24, by which time the range began June 22. The only document that would let anybody count the removed cases starts the day after the removed period ends. The missing ascending limb she noticed is not missing from the outbreak. It is missing from the chart.

CDC’s 1,947 cases with the removed period shown, the two waves separated at the July 2 trough, and exposure windows back-calculated against FDA’s distribution dates. Bar values read from CDC’s published curve.

The timing is why that matters. Cyclospora takes two to fourteen days to make you sick, a week on average. Work backward and the first wave was exposed around June 17 and the second around July 2. FDA says the recalled foodservice lettuce shipped from June 29 through July 16. The second wave sits inside that window. The first wave comes before it. And the May 13 illnesses CDC took out of the count were exposed somewhere around April 29 to May 11 — roughly seven weeks before the recalled lettuce ever left the plant.

One more thing about which cases went. CDC’s own caveat, printed under its curve, is that it can take six weeks to determine whether a sick person belongs to an outbreak. The May illnesses had been in the system about ten weeks by July 24. They were the most thoroughly worked-up cases the agency had. The July illnesses are still inside the lag and are the least. The revision removed the ripe cases and kept the green ones.

There is an explanation for that first wave that does not require a second supplier, and it belongs on the table. A recall reaches what is still in commerce. FDA’s June 29 to July 16 window is the window of lettuce still sitting on shelves and in walk-in coolers when Taylor Farms announced on July 17. It is not the window of contaminated production. Shredded iceberg runs about two weeks of shelf life. The lettuce that made the first wave sick was processed and shipped somewhere between late May and mid-June, and it had been eaten and thrown out long before anybody drafted a recall notice. The May illnesses CDC deleted were eaten roughly ten weeks before. No recall could have reached either one, however contaminated it was. And on July 18 Taylor Farms did not suspend one product line. It suspended all production at Doctor Mora, which is what a company does about a plant, not about a lot.

That explains the front of the curve. It does not by itself explain the trough. Contamination running steadily through a season produces a long plateau, not two peaks with a hole between them. To get twin peaks fifteen days apart out of a single supplier, you need contamination that arrives in pulses — separate fields, or separate harvest blocks, moving through the same plant at intervals.

Which is exactly what happened the last time. We have seen a Cyclospora curve with two humps turn into two outbreaks before, and the same company was in the middle of it. In the summer of 2013, 631 people in 25 states looked like one event and resolved into at least two. The clusters at Olive Garden and Red Lobster in Iowa and Nebraska were traced to bagged salad mix from Taylor Farms de Mexico in Doctor Mora, Guanajuato. Texas reported 278 cases, and at least 25 of those — a cluster at one Fort Bend County restaurant — were linked to cilantro out of Puebla, from a different producer, with no connection to Taylor Farms.

Now look at what the traceforward investigation found inside the salad-mix half of it. Romaine shipped on June 2 through 6 from a single Mexican field likely caused 189 illnesses across seven states. And a presumably adjacent field, carrying a sequential lot number, was the plausible source of sixteen earlier cases. Two fields side by side, harvested days apart, producing two pulses of illness out of one supplier. The regional investigation found the same thing from the other direction: the implicated salad mix drew its romaine from two separate single-grower fields plus at least one more field from another grower. When this parasite produces a curve with two humps, the historical answer has been more than one vehicle — and sometimes more than one field inside a single vehicle.

The 2013 and 2026 windows side by side. The 2013 bands are the documented onset and shipping ranges from MMWR and the two published investigations, not case-count curves; CDC’s own 2013 epi curve by week of onset is the Figure in MMWR 62(43):862.

If that is what happened again, then this recall was under-inclusive by construction. It could only ever remove what was still on the shelf. And CDC’s June 22 cutoff then excludes precisely the people whose lettuce was never recallable in the first place. The case definition and the recall window now agree with each other, and both of them sit downstream of the date a company chose to make an announcement.

Phyllis found something else in the same post that deserves its own week of attention. CDC’s surveillance tablegives Ohio a range of 301 to 500 cases while the outbreak notice credits Ohio with 639. West Virginia gets 11 to 30 in the surveillance table and 42 in the outbreak. The outbreak is a subset of the surveillance total. A subset cannot be bigger than the thing it is part of. She also asks why an agency that adds up state counts to produce a national figure is publishing those state counts as ranges instead of numbers. I would like to hear the answer to that one too, and I would like to hear it alongside an explanation of why Cyclospora reporting through FoodNet went from mandatory to optional on July 1, 2025.

Meanwhile Michigan reported 71 new cases in the week ending June 27, then 496, then 1,329, then 3,593 in the week ending July 18 — its biggest week of the outbreak — during the same days CDC’s curve drops to single digits. Those are different clocks, and it is only fair to say so: Michigan counts by the date a case is reported and CDC by the date somebody got sick. But only 1,947 of the roughly 15,500 cases the states are reporting are inside CDC’s outbreak count at all.

Five questions, and every one of them has an answer sitting in a federal database right now. How many cases in total came out when the earliest onset moved back to June 22, and what were their onset dates? Will CDC publish the curve for May 13 through June 21 that it never published in the first place? What changed in the case definition between July 17 and July 24, and was the change applied backward to people already counted? And have the two peaks been compared by genotype? CDC has been running targeted sequencing on Cyclospora since 2018 for precisely this purpose — to pull apart clusters that look like a single outbreak. If those two humps carry different genotypes, they are not two waves. They are two outbreaks. And fifth, has anybody run the first wave back to a lot code? If a single one of those cases traces to Doctor Mora product shipped before June 29, then the recall never covered the first half of this outbreak.

Phyllis ended by saying we will have to wait and see. I understand why she wrote it that way, and she is more patient than I am. The people in that grey box on the chart above have been waiting since the middle of May, and somebody at CDC already knows how many of them there were. Read her post. She saw it first, and she asked the right question.

I am writing this on a plane from Seattle to New Orleans, headed to the IAFP annual meeting, where I expect this outbreak will be the subject of a great many hallway conversations. Here is where it stands as we are about to land. CDC’s outbreak page, stamped Friday, counts 1,947 people infected with Cyclospora across nine states, at least 98 hospitalized, no deaths, with onsets from June 22 through July 20. CDC’s surveillance page, a different instrument measuring a different thing, is current through July 21 and counts 4,173 laboratory-confirmed domestic cases in 41 states, 308 hospitalizations, and more than 7,400 additional cases not yet confirmed.

The states report something else. Michigan is at 8,176 with 160 hospitalized. Ohio is at 2,596, New York 666, Indiana 684, North Carolina 561, Illinois 513, Kentucky 468. Pennsylvania reports 28, and cyclosporiasis is not on Pennsylvania’s reportable-conditions list, so that number measures how many doctors chose to pick up a phone. The fifty-state floor is somewhere near 15,500.

One of the best pieces of journalism this outbreak has produced ran Saturday, when almost nobody was looking. The Associated Press asked the question everyone covering the case counts has skipped: who is left to do the counting. It ran at HuffPost and on Yahoo, and The Hill picked it up. Tip of the pen to the AP.

Michigan has 23 fewer infectious disease workers and 123 fewer county health staff than it had before the administration canceled roughly $12 billion in COVID-era grants to the states in 2025. Health departments there are now borrowing staff and recruiting volunteers to chase causes beyond the recalled lettuce. In Oakland County — 1.3 million residents, 710 cases as of July 24 — the entire interviewing operation is four communicable disease nurses and three epidemiologists. That department had twelve more people for this work during the pandemic, including four nurses let go this past spring. Because Cyclospora cannot be fingerprinted the way E. coli and Listeria can, the patient interview is the only real investigative tool, and each one runs as long as forty-five minutes.

Do that arithmetic. Seven people. Seven hundred ten cases. Forty-five minutes apiece. One county, in one state, eleven weeks into an outbreak.

The Wall Street Journal has the other half of it. Jennifer McEntire, a food safety consultant whose clients include Taylor Fresh Foods, told the Journal that investigators are “looking for a needle in a haystack,” and named the difference that matters – with E. coli and Salmonella you can grow the organism in a laboratory and make the needle bigger, and with Cyclospora you cannot. No enrichment step, no animal model, and by the time anyone is sick enough to be interviewed, the lettuce has been eaten. Put that next to the AP and you have the whole problem in two sentences. The patient interview is the only instrument this outbreak can be measured with and the people who conduct the interviews were laid off last spring.

There has been much discussion on the politics surrounding our new found obsession with diarrhea and Taylor Farms roll in it. On the money, and I want to be precise about it. The lobbying campaign that killed the USDA’s Microbiological Data Program in 2012 was run by the United Fresh Produce Association, and the push to delay the Food Traceability Rule came from trade associations. Taylor Farms did not sign those letters under its own name. What it did do is documented: Zeteo reported Friday, with FEC filings attached, that the company gave $1 million to a pro-Trump super PAC six days after FDA announced the traceability delay, and another $1 million to the House Republican super PAC that summer. Bruce Taylor said Friday the company already complies with the rule and the donation had nothing to do with it. Funding an association is not the same thing as being one, and I am not going to blur the two.  But, in my view if the MDP still existed and the Traceability Rule in place, Taylor Farms my likely not be the center of all this unwanted attention. And, it is about to spend a lot more that $2 million.

One closing note, on the language, since it will come up in New Orleans. CDC has only ever called the symptom watery diarrhea. The internet went with “explosive diarrhea” and from there came the explosive diarrhea parasite, the diarrhea parasite, poopy pants parasite, diarrhea lettuce, evil vegetables and Diarrhea Summer, and Know Your Meme’s Diarrhea Forever. Somebody landed on “lettuce spray”, which I concede is very good. The jokes filled a space the counting left empty.

Today I fly to New Orleans for IAFP 2026, the annual meeting of the International Association for Food Protection, July 26 through 29 at the Ernest N. Morial Convention Center. It is the largest food safety conference in the world — thousands of microbiologists, regulators, quality assurance directors and academics from more than sixty countries. I am going with one message, and it is about Cyclospora.

Start with the numbers. CDC’s surveillance page, now updated weekly, counted 4,173 laboratory-confirmed domestically acquired cases as of July 21, across 41 states, with 308 hospitalizations. CDC is aware of more than 7,400 additional cases that are not yet laboratory confirmed, most of them from Michigan and Ohio, which puts the national figure above 11,500. The median illness onset is June 26. CDC assumes a six-week reporting lag between onset and reporting, so every one of those numbers is going to grow.

Now the comparison. Over the comparable window last year — May 1 through mid-July — CDC recorded 249 domestically acquired cases. For all of 2025 it had 1,180, with 105 hospitalizations. For all of 2021 it had 1,024. Counting every reported case, including travel-associated illness, CDC’s full-year totals were 2,707 in 2022, 4,200 in 2023, 3,719 in 2024 and 3,955 in 2025. This year’s laboratory-confirmed total, domestic plus travel, was already about 4,940 on July 21. We passed a normal full year in early July with the season still running. Michigan alone has reported 8,176 cases and 160 hospitalizations. Michigan normally sees about fifty a year.

The nine-state outbreak that CDC and FDA have named — the Taco Bell cluster traced to Taylor Farms de Mexico shredded iceberg — accounts for 1,947 of those illnesses and 98 hospitalizations. Add up what the fifty states are reporting on their own dashboards tonight and the floor is somewhere near 14,800. The named recall does not describe the outbreak.

There will be a great deal of good science presented in New Orleans this week on interventions, wash-water chemistry, sanitizer efficacy and process validation. Here is what I have found the published science says about Cyclospora.

Washing does not do it. Ortega and Sanchez wrote in Clinical Microbiology Reviews that washing and sanitizing may reduce but would not be expected to eliminate the risk, and that these practices have been demonstrated not to completely remove oocysts from contaminated produce. The best consumer-level data is a 2021 study in Foods that contaminated raspberries and blueberries with three parasites and washed them three ways. A minute under cold running water removed at least eighty percent of the other two parasites. For Cyclospora on raspberries it removed thirty-nine percent. A vinegar soak or a salad spinner brought that to roughly eighty-five percent. Nothing removed all of it. These oocysts are stickier than Cryptosporidium and Giardia.

Chlorine does not do it, and that is not my opinion. It is FDA’s, in a fact sheet the agency wrote for farmers: chlorine and other common anti-microbial chemical treatments are not effective against C. cayetanensis. The field evidence is thirty years old. In Pokhara, Nepal, an outbreak among British soldiers was traced to drinking water that was chlorinated and filtered and carried a normal residual, and the parasite came through anyway (Rabold, Lancet, 1994). Gaseous chlorine dioxide at 4.1 milligrams per liter for twenty minutes produced no reduction in sporulation at all.

Municipal wastewater treatment is no guarantee. FDA’s own language is that treatment may render the parasite inactive, that conflicting evidence suggests it may remain viable after treatment, and that little conclusive data exists either way. What we do have is this. Cyclospora was detected in wastewater in 1998. Charles Gerba’s group sampled two Arizona treatment plants monthly for a year and concluded that conventional treatment’s ability to remove oocysts is limited. A two-year study in southeastern Georgia found the parasite confirmed by sequencing in nine percent of municipal wastewater sludge samples. Conventional treatment was never designed against this organism and has never been validated against it. That is the accurate sentence, and it is bad enough.

There is no validated kill step for Cyclospora on ready-to-eat produce. The parasite cannot be grown in culture. Heat works — seventy degrees Celsius for fifteen minutes prevents sporulation — and heat also destroys lettuce and raspberries. Every control this industry has built for leafy greens points at bacteria and ends in a chemical intervention. This parasite swims through it. Cyclospora has one reservoir and it is the human gut. When it turns up on lettuce, human feces reached that lettuce or the water that grew it. Nothing that happens after harvest changes that.

A retired FDA food safety director said the quiet part out loud this week. Mark Moorman, until recently the director of FDA’s Office of Food Safety, told CNN that investigators have never definitively identified the cause of a Cyclospora outbreak. Not one, in thirty years. Asked whether anyone is obliged to look, he was blunt: no law or rule requires a farm to test its irrigation water or its produce for this parasite. It is voluntary, and he said FDA does not have that lever. He suggested the big buyers could pull it — he named Kroger, Food Lion and Costco — and that Congress could write the requirement and fund the research. In the same piece Jennifer McEntire, the microbiologist, put the mechanism plainly. “Water is number one,” she said, and the open question is how human waste gets into it. Her candidates are the ones you would expect. Waste emptied from portable toilets. A septic tank that leaked. A sewer that overflowed after heavy rain.

One disclosure before the next paragraph. My firm represents people sickened in this outbreak, and we have filed cases naming Taylor Farms entities as defendants. The record below is public either way. You should still know where I sit.

And the 2013 investigation found something worth sitting with. Goodman reports a detail from FDA’s investigation of the 2013 Cyclospora outbreak traced to salad mix from Taylor Farms de Mexico: when investigators pulled the medical records of harvesting workers, they found antidiarrheal medications and the combination antibiotic used to treat cyclosporiasis. No diagnoses were recorded in the records FDA inspected, and those drugs are prescribed for other things, so it proves nothing on its own. But the plant is at Doctor Mora, in Guanajuato — the same facility at the center of this summer’s outbreak. And roughly eight hundred feet from that processing building sits Balneario Las Fajanas, a public thermal-water bathing complex with pools, slides, showers and changing rooms, open every day of the year and listed by the state of Guanajuato’s own tourism office. Google Earth imagery shows it built and operating in March 2010, more than three years before FDA and COFEPRIS conducted their environmental assessment at the plant. That published assessment covers the processing facility and five ranches. Its second recommendation told the firm to determine whether Cyclospora is a reasonably likely hazard in that growing region and, if so, to re-evaluate the wash step. Thirteen years later, no one has produced a document showing that determination was ever made — and the whole of this post is the reason the wash step was never going to be the answer.

None of this is news to the government, or to the industry. In 2021 FDA released a Cyclospora Prevention, Response and Research Action Plan, written by a task force the agency created in 2019. In 2023 the National Advisory Committee on Microbiological Criteria for Foods delivered FDA a full report on Cyclospora cayetanensis in produce, with sections on preventive measures, surrogates, the maintenance and conveyance of wastewater, and prevention in food. That report states that the oocysts are resistant to many of the common chemical treatments used against bacterial pathogens in the produce production environment and in agricultural inputs, agricultural water among them. Its subcommittee was co-chaired by Peggy Cook and by Max Teplitski, now the chief science officer of the International Fresh Produce Association. None of the science in this post is contested. It has been sitting in a federal advisory committee report for three years.

Which is why the fix is upstream, and it is not mysterious. Treat the water. FDA says so in the same fact sheet: in regions where cyclosporiasis is endemic, microfiltration, ozone or ultraviolet treatment may be necessary to decrease the parasite in irrigation water. Read the footnote listing which regions those are and you find a roster running from Bangladesh to Zimbabwe with Puerto Rico sitting in the middle of it. The data behind the interventions is real, with one caveat that matters: because the parasite cannot be propagated in a laboratory, most of this work uses a poultry coccidian, Eimeria acervulina, as a surrogate. Ozonated water acidified with citric acid inactivated ninety-three percent of sporulation in that surrogate. Ultraviolet light at 222, 254 and 282 nanometers each cut sporulation and produced close to a three-log reduction in its infectivity. Zero-valent iron sand filtration — tested on actual C. cayetanensis oocysts rather than a stand-in — retained ninety-seven percent of them.

Water treatment is already mandatory. It is just aimed at the wrong organism. The California and Arizona Leafy Greens Marketing Agreements, which cover better than ninety percent of the leafy greens grown in this country, require growers who use surface water for overhead irrigation to treat that water in the twenty-one days before harvest. Then read what the requirement asks for. An EPA-registered antimicrobial, validated and verified, with success measured by generic E. coli. That is chlorine-family chemistry, selected for bacteria and scored by a bacterial indicator — the exact chemistry FDA says does not work on this parasite. The mandate exists and it points at the wrong organism. Microfiltration, ozone and ultraviolet are required of no one. And the field at the center of this outbreak is in Guanajuato, which no LGMA metric reaches at all.

Test for the right thing. FDA states plainly that testing for generic E. coli and fecal coliforms will not identify C. cayetanensis. Human-specific markers will. That same Georgia study found the human fecal marker HF183 in thirty-three percent of irrigation pond samples. If your irrigation water carries a human sewage signal, you have a Cyclospora exposure whether or not anyone ever finds an oocyst. The Center for Produce Safety has spent more than $1.6 million since 2014 establishing that this parasite is endemic in the United States and recoverable from wastewater and irrigation water, and it published a Cyclospora resource page this week collecting the literature on agricultural water monitoring and mitigation. The industry funded the finding. It needs to act on it.

Write the parasite into the rule that already exists. The pre-harvest agricultural water rule became final on May 6, 2024 and requires covered farms to conduct an annual systems-based assessment of their water — the system, the practices, the crop, the environment, and adjacent land uses including sewage. The only numeric microbial criterion in Subpart E is generic E. coli, the same indicator FDA says will not identify this parasite. For leafy greens and berries the rule should name Cyclospora outright, and the Foreign Supplier Verification Program should require importers to document treatment that works on protozoa rather than chlorination that does not.

Fix field sanitation. OSHA’s standard has required agricultural employers to provide one toilet and one handwashing station for every twenty hand laborers, within a quarter mile, since 1987. Operations with fewer than eleven workers are exempt outright. Inspectors are thin on the ground. Workers paid by the piece and worried about their immigration status do not file complaints. For an organism whose only reservoir is a human being, that exemption is the hazard.

And count it, trace it and test for it. Cyclospora came out of FoodNet last July. The Food Traceability Rule that would have put lot-level records in FDA’s hands within twenty-four hours was supposed to be in force this January and now cannot be enforced before July 2028. The methods to watch for this parasite in wastewater have been published for more than a decade. CDC built a National Wastewater Surveillance Systemthat takes data from about fifteen hundred sites and covers roughly half the country. It reports SARS-CoV-2, influenza A, RSV, mpox and measles. Cyclospora is not among its targets, and it is not on the academic WastewaterSCAN panel either. Meanwhile a diagnostics company watching its own clinical panels reported national positivity jumping from one or two percent to ten or twelve this spring. Frank Yiannas, who ran FDA’s foods program under two administrations and is a past president of this association, told POLITICO this week that the federal response is approaching a catastrophic level of mismanagement and should get an independent review. He has been proposing an NTSB-style board for foodborne outbreaks since last November. Restore the Microbiological Data Program, which for eleven years pulled high-risk produce off the shelf and tested it, and which the industry lobbied to death in 2012.

A tip of the pen. The Moorman and McEntire interviews and that 2013 record are Brenda Goodman’s reporting for CNN. She has been on this story for weeks. It was also her July 20 piece that carried Frank Yiannas on the withdrawn laboratory result — he called it unfortunate and consequential, warned that consumers would wrongly read a false positive as proof the recall was unnecessary, credited FDA for disclosing the error promptly, and then said the thing that matters: “transparency alone is not enough.” The agency still owes the public a root cause for the laboratory failure and the corrective actions that follow from it. Goodman went and asked the people who actually ran these investigations the one question the trade press has spent a month stepping around — how does human waste get into the water in the first place — and got them to answer on the record. It is the piece I wish had run three weeks ago.

See you in the “Big Easy.” I will be in New Orleans Sunday through Wednesday. If the honest sentence is that we cannot make contaminated lettuce safe, then the whole of the answer is keeping it from being contaminated — and what we require today is aimed at a different organism.

CDC currently reports 4,173 laboratory-confirmed, domestically acquired Cyclospora cases since May 1.[1] The federal government’s own published model for foodborne illness burden — Scallan and colleagues, 2011, still the only Cyclospora-specific burden estimate ever published in this country that I could find — carries a credible interval whose upper bound implies that roughly 272 people are infected for every 1 a laboratory confirms.[2] Multiply it out and this outbreak has infected at least 1,135,056 Americans.

I do not believe that number, and I would not publish it as a finding. The top of an interval is not an estimate; it is the edge of what the model cannot rule out, and in this case the model is fifteen years old and the interval is enormous — the same table’s lower bound implies a multiplier of 1.0, which would mean every single Cyclospora infection in America gets laboratory-confirmed, which is plainly false. When the honest range on a parameter runs from 1 to 272, the honest thing to say is that we are guessing.

Scallan’s central estimate for the underdiagnosis multiplier is 83.1. Applied to 4,173 laboratory-confirmed cases, that is 346,776 people. That figure is not the edge of anything. It is the middle of the published distribution, produced by CDC’s own epidemiologists and used by CDC ever since to describe how much foodborne illness this country actually has.[3]

Walk it down, because even 346,776 is built on generous assumptions. The 83.1 was derived from data collected in the 2000s, when finding this parasite required a clinician to specifically request an unusual stain because the routine ova-and-parasite exam misses it entirely.[4] The first FDA-cleared molecular gastrointestinal panel with a Cyclospora target did not exist until 2014, and by 2018 and 2019 a survey of roughly seven hundred American clinical laboratories found 62 percent of panels included one.[5] Detection is far better now than when that multiplier was built. On top of that, an outbreak this size creates its own surge — physicians in Michigan and Ohio are testing for this parasite in July of 2026 in a way nobody does in an ordinary March. Both effects push the real multiplier down.

There is one more number that belongs on the table because it does not come from the government. bioMérieux, which makes the most widely used molecular gastrointestinal panel in the country, publishes surveillance drawn from its own installed base of instruments, and between June 26 and July 5 of this year it recorded Cyclospora detections running 10.8 percent above the same stretch of 2025 nationally, and 27.5 percent above it across the Midwest.[6] Those are not the numbers you would expect underneath a national count running many times last year’s at the same point in the season.[7] I think the window explains most of the gap — that stretch closes before this outbreak turned steep, and Michigan’s newly reported cases over the four weeks that followed ran 71, then 498, then 1,331, then 2,408 — and the platform sees only the laboratories that bought one manufacturer’s machine. 

Hospitalizations are the least-undercounted thing in any outbreak. People sick enough to be admitted get tested. Scallan’s companion table put roughly 20 Cyclospora hospitalizations a year against 19,808 total annual illnesses — a hospitalization rate of about one tenth of one percent of all infections, not of confirmed cases.[8] There are 308 hospitalizations in the national count. Divide 308 by 0.001 and the implied number of infections is roughly 305,000.

What the hospitalization figure actually tests is whether this outbreak looks like the outbreaks the model was built from, and it does: Scallan’s table implies roughly 8.4 hospitalizations for every hundred laboratory-confirmed cases, and this outbreak is running 7.4. A model assembled from 2000s data is describing a 2026 illness with about the severity it predicted, which is exactly what you would want to check before applying a fifteen-year-old model at all. 

Now cut it to the bone. Suppose the multiplier has fallen by a full order of magnitude since 2011 — from 83.1 down to 8.3. That is a more aggressive haircut than the arrival of PCR panels plausibly justifies, and it concedes essentially the entire argument to anyone who wants to say the old number is stale. It still puts this outbreak at about 35,000 people. That is more than twice what every state health department in America has managed to count between them, and it is roughly ten times the number of cyclosporiasis cases this country reports in a normal full year.[9]

Whatever you believe about the multiplier, every rung of that ladder sits above what is being counted. The disagreement is only about how far above.

Michigan offers a check on all of it. The state has reported 8,176 cases and 160 hospitalizations.[10] That is a hospitalization rate of 2.0 percent against the 6.5 percent Scallan found — though the comparison is not quite like for like, because Michigan’s total includes probable cases while Scallan’s rate was calculated among laboratory-confirmed ones, which pushes Michigan’s true rate somewhat higher than 2.0. Even allowing for that, the direction is unmistakable. A falling hospitalization rate means a state is catching the mild end of the illness spectrum, which means Michigan’s own undercount multiplier is far smaller than 83. Michigan is looking hard. Run the hospitalization arithmetic on that one state anyway and you get roughly 158,000 infections, which works out to a multiplier of about 19. That is the number I would defend. And then consider Pennsylvania, which has reported 28 cases in a nine-state outbreak and where reporting cyclosporiasis to the health department is voluntary. Nobody can calculate Pennsylvania’s multiplier, because Pennsylvania is not measuring anything.[11] That is the actual shape of the undercount: small where somebody is looking, unknowable where nobody is.

Against every one of those figures, here is what is actually counted. CDC’s outbreak investigation — laboratory confirmation plus a documented exposure — stands at 1,947 people in nine states, 98 hospitalized.[12] CDC’s national surveillance count of laboratory-confirmed domestic cases is 4,173, with more than 7,400 additional reported illnesses awaiting the analysis that would confirm them, upward of 11,500 cases in all across 41 states, and 308 hospitalizations. Add up what the individual state health departments have posted and the floor is near 15,500.[13] Every one of those is a floor, and every one of them describes a week ago or more, because CDC has said it can take as long as six weeks to determine whether a sick person belongs to an outbreak.

It is worth pausing on how large those floors already are. CDC’s outbreak reporting system holds 181 Cyclospora outbreak records covering 1990 through 2023 — thirty-three years — and together they account for 6,251 illnesses.[14] The 11,500 reported this summer is nearly twice the entire outbreak-associated total that system logged in three decades. The outbreak that taught this country the parasite existed, the 1996 Guatemalan raspberry outbreak, produced 1,465 reported cases and 978 laboratory-confirmed ones across twenty states, the District of Columbia and two Canadian provinces, and it is the reason cyclosporiasis became a nationally notifiable disease in 1999.[15] The confirmed cluster alone in this outbreak is larger than that.

The last question is why a plaintiffs’ lawyer (and his Epi and Nurse) is doing this arithmetic at all, and the answer is that nobody with a federal badge is. There has been no updated Cyclospora burden estimate since 2011. The 2025 revision of the federal foodborne illness estimates covers seven pathogens and this one is not among them.[16] And on July 1 of 2025, CDC narrowed FoodNet — the active surveillance system that generated the 239-cases-a-year denominator underneath every figure above — from eight pathogens to two, keeping Salmonella and Shiga toxin-producing E. coli and dropping CyclosporaCampylobacterListeriaShigellaVibrio and Yersinia, citing inadequate funding.[17] Ten months later the first people in this outbreak got sick.

The realistic range in this post runs from 35,000 to 347,000. It is embarrassingly wide, and that width is not my doing. It is the width you get when a country decides that counting sick people is a discretionary expense. There may be a final official number for this outbreak eventually. It will be tidy, it will be footnoted, and it will be smaller than the truth.


[1]CDC, Cyclosporiasis Surveillance, cdc.gov/cyclosporiasis/php/surveillance/index.html (4,173 laboratory-confirmed domestically acquired cases; 7,400+ awaiting analysis; 11,500+ total; 41 states; 308 hospitalizations; data as of July 21, 2026).

[2]Scallan E, Hoekstra RM, Angulo FJ, Tauxe RV, Widdowson MA, Roy SL, Jones JL, Griffin PM. Foodborne Illness Acquired in the United States — Major Pathogens. Emerg Infect Dis. 2011;17(1):7–15, Table 2. doi:10.3201/eid1701.p11101. The Cyclospora cayetanensis row reports 239 laboratory-confirmed cases annually and 19,808 estimated total illnesses, 90% credible interval 239–65,135 — implying a multiplier ranging from 1.0 to approximately 272.5. Expanded tables at cdc.gov/foodborneburden/pdfs/major-pathogens-expanded-tables.pdf.

[3]Id. (underreporting multiplier 1.0; underdiagnosis multiplier 83.1; 11,407 domestically acquired foodborne illnesses, 90% CrI 137–37,673). The domestically acquired foodborne interval is a 275-fold spread and should not be presented as precise.

[4]Mathison BA, Pritt BS. Cyclosporiasis — Updates on Clinical Presentation, Pathology, Clinical Diagnosis, and Treatment. Microorganisms. 2021;9(9):1863. doi:10.3390/microorganisms9091863. See also American Society for Microbiology guidance that a normal ova-and-parasite examination does not rule out Cyclospora, and CDC guidance recommending three or more stool specimens collected more than 24 hours apart owing to intermittent shedding.

[5]Evaluating Foodborne Cyclosporiasis Using Foodborne Diseases Active Surveillance Network and Foodborne Disease Outbreak Surveillance System Data, 2015–2019. Am J Trop Med Hyg. 2025;112(2):319 (1,376 FoodNet cases; 21.1% travel-associated; 90.9% summer onset; 71.7% outbreak-associated). The 62 percent figure appears in that paper, which cites an underlying survey of approximately 700 U.S. diagnostic laboratories; it is not the authors’ own finding.

[6]bioMérieux, Tracking the Cyclospora cayetanensis Outbreak in the United States (July 2026), reporting BIOFIRE FIREWORKS surveillance data drawn from its installed base. The same post states that several FDA-cleared multiplex panels available for clinical diagnostic testing do not include Cyclospora as a target.

[7]CDC Health Alert Network Advisory No. 00531, Domestically Acquired Cyclosporiasis Cases in Multiple U.S. States, 2026 (July 14, 2026) (249 cases reported nationally May 1–July 16, 2025). The 2026 and 2025 reporting windows are not precisely aligned.

[8]Scallan et al., supra note 2, Table 3 (approximately 20 Cyclospora hospitalizations annually, 90% CrI 0–190; 6.5% hospitalization rate; zero deaths). CDC’s expanded tables note that hospitalization and death rates were doubled to adjust for underdiagnosis before being applied to the number of laboratory-confirmed cases — so the hospitalization estimate does not run through the 83.1 underdiagnosis multiplier, while the illness estimate does. Twenty hospitalizations against 19,808 estimated illnesses yields approximately 0.101% of all infections. The upper bound of 190 hospitalizations would imply 0.96%, and a correspondingly smaller total near 32,000.

[9]CDC cumulative reported cases through report week 53: 2,707 (2022); 4,200 (2023); 3,719 (2024); 3,955 (2025) — an average of roughly 3,645 per year, inclusive of travel-associated cases.

[10]Michigan Department of Health and Human Services, reported case total as of July 24, 2026; hospitalizations as of July 23, 2026. The state total includes probable as well as laboratory-confirmed cases.

[11]Casillas SM, Hall RL, Herwaldt BL. Cyclosporiasis Surveillance — United States, 2011–2015. MMWR Surveill Summ. 2019;68(SS-3):1–16. doi:10.15585/mmwr.ss6803a1 (cyclosporiasis not reportable in Alabama, Idaho, Maine, Mississippi, Nevada, North Dakota or Pennsylvania during the surveillance period; reporting to CDC voluntary even where the condition is reportable by law).

[12]CDC, Cyclosporiasis Outbreak Investigation, cdc.gov/cyclosporiasis/outbreaks/07-26/investigation.html, and Where People Got Sick, cdc.gov/cyclosporiasis/outbreaks/07-26/locations.html (nine states; at least 1,947 cases; at least 98 hospitalizations; no deaths).

[13]State-by-state totals compiled from individual state health department postings; see also CNN’s running case tracker, cnn.com/2026/07/21/health/cyclospora-cases-count (refreshed July 24, 2026). Michigan and Ohio figures per MDHHS and CNN, July 24, 2026; NBC News reported 2,596 Ohio cases the same day and the Ohio Department of Health has not posted the figure itself.

[14]CDC National Outbreak Reporting System public data file, 181 Cyclospora outbreak records covering 1990 through 2023, totaling 6,251 illnesses and 198 hospitalizations.

[15]Herwaldt BL, Ackers ML; Cyclospora Working Group. An outbreak in 1996 of cyclosporiasis associated with imported raspberries. N Engl J Med. 1997;336(22):1548–56 (1,465 cases reported by 20 states, the District of Columbia and 2 provinces; 978 laboratory-confirmed). Cyclosporiasis became nationally notifiable in 1999.

[16]Scallan Walter EJ, et al. Foodborne Illness Acquired in the United States — Major Pathogens, 2019. Emerg Infect Dis. 2025;31(4). Cyclosporais not among the seven pathogens re-estimated.

[17]CDC reduced FoodNet’s pathogen panel to Salmonella and Shiga toxin-producing E. coli effective July 1, 2025. The CDC quietly scaled back a surveillance program for foodborne illnesses, NBC News (Aug. 26, 2025), nbcnews.com/health/health-news/cdc-quietly-scaled-back-surveillance-program-foodborne-illnesses-rcna227089; CDC confirms cuts to program that tracks foodborne pathogens, Food Safety News (Aug. 2025) (quoting CDC spokesman Gabrial Alvarado). CDC told the Connecticut Department of Public Health that funding had not kept pace with the resources required to maintain FoodNet surveillance for all eight pathogens.

SSaturday, July 25, 2026

Last Saturday this column was called The Source Finally Got a Name — and Then FDA Found It on Lettuce That Was Never Recalled. This week the government caught up — to the Washington Post, to the Wall Street Journal, to state health departments that had already published what the federal pages would not. And when CDC finally moved its outbreak page on Friday, the outbreak got six weeks shorter. Here’s what moved.

The Secretary said it was under control on Tuesday. At a health care fraud briefing on July 21, Secretary Kennedy said the administration has the outbreak “under control,” that epidemiological forensics had identified the source, and that the companies involved had recalled. In the seventy-two hours that followed, Michigan went from 7,171 cases to 8,176 and from 102 hospitalizations to 160, CDC added four states to the outbreak, and FDA opened another Cyclospora investigation with no product named.

The counting gap is now CDC’s own argument. Add up every state that publishes a number and the floor is roughly 14,800. CDC’s surveillance page carries 4,173 lab-confirmed domestic cases, more than 7,400 awaiting analysis and 308 hospitalizations, against 249 cases at this point last year. That page now states that CDC’s updates exclude probable cases, that state figures run higher because states include them, and that a roughly six-week reporting lag means the counts keep climbing. That is not a critic’s characterization of the numbers. It is the agency’s.

The Post named the ninth state before CDC did. Friday morning Lena H. Sun reported that CDC had linked Illinois, Kansas, Oklahoma and Pennsylvania to the Taco Bell outbreak, while CDC’s own page still said five states. Kansas and Oklahoma had already said so themselves. Hours later the agencies caught up: 1,947 cases in nine states, 98 hospitalizations, no deaths. Note the arithmetic — adding four states raised the outbreak count by 303 and the hospitalizations by four, while those same four states report about 900 cases of their own. I wrote about that Friday.

And the outbreak got six weeks shorter. The official onset range had been May 13 through July 13. It is now June 22 through July 20, and FDA’s new nine-state page carries both dates on the same screen. On the same day four states came into the outbreak, roughly six weeks of illness went out of it.

Three things arrived with that page. The distribution list grew from 27 states to 28, and the single addition is West Virginia — the outbreak state I kept flagging as missing from the company’s own list. FDA broke retail out from foodservice for the first time: Marketside product went to Walmart stores in fifteen states, and of the nine outbreak states only Indiana, Kansas, Kentucky, Oklahoma and West Virginia appear, meaning the two hardest-hit states got this lettuce through foodservice. And a new international distribution heading discloses that recalled product was sold to consumers in Mexico — a day after Mexico’s health ministry announced its own plant sampling came back negative.

Then Friday night, the Journal. Taylor Farms called the White House to ask that the recall announcement be delayed, arguing the government had no positive laboratory test and was overstating the company’s culpability. The call was arranged by Trent Morse, a lobbyist for the company and a former senior White House personnel official. The next part matters as much as the first: the White House went back to FDA separately, asked how the traceback had been done, reviewed how the agency planned to tell the public, was persuaded, and gave FDA the green light. The same story answers a question I had been asking for a week — FDA did not name Taylor Farms on July 16 because of legal restrictions around trade secrets, which is why the advisory referred only to a single unnamed supplier. My firm represents people sickened in this outbreak and has sued Taylor Farms entities.

The President was asked about lettuce for the first time on Friday. Peter Doocy asked when it would be safe to eat lettuce again, and the answer was “I don’t know, I haven’t thought about it,” followed by a promise of a major tariff on Mexico over the lettuce. Taylor Farms is a California company headquartered in Salinas; the lettuce was shredded at its own plant at Doctor Mora in Guanajuato. A tariff does not test irrigation water, inspect a field, trace a lot code or count a sick person. It is not a food safety measure.

All of it is being run by acting officials. FDA has no confirmed Commissioner; Kyle Diamantas has been acting since May 12. CDC has no confirmed Director; Jay Bhattacharya has been performing the duties since February while also running NIH, and I have not been able to find a public statement from him about this outbreak. The nominee, Dr. Erica Schwartz, had her Senate hearing on July 15 and still awaits a vote. Klobuchar, Stanton and Ossoff all wrote with questions, two of them with deadlines. I am not aware of a substantive answer to any of the three.

And it may not all be lettuce. Kari Irvin, deputy director of FDA’s Coordinated Outbreak Response and Evaluation Network, said Friday that “We have multiple investigations of cyclospora open,” and that preliminary work on North Carolina’s 561 cases points toward parsley and cilantro rather than lettuce. North Carolina’s own read is multiple vehicles, not one product from one company. One recall did not close this.

Nineteen million eggs, and seven months of sick people. CDC posted 98 Salmonella Enteritidis illnesses in 17 states, 26 hospitalized, with onsets from November 21, 2025 to June 30, 2026. Midwest Poultry Services recalled 1,589,577 dozen shell eggs out of two Texas farms. I wrote that one up Friday — and got back a correction worth more than the post. Dr. Eric Gingerich, a poultry veterinarian in Zionsville, Indiana, wrote to tell me that American producers vaccinate their layers extensively, and that Britain’s Lion Code is an industry scheme rather than a government mandate. He is right on both counts. USDA’s own survey of 328 table-egg farms found 99 percent vaccinating, on close to the protocol he described. I have corrected the post and I am grateful for the letter. What survives the correction is the interval: we vaccinate the hens, swab the house twice in a laying hen’s life, send an inspector every three to five years, and nobody pulled a carton for seven months.

The federal table went from fourteen investigations to sixteen. Ten of the sixteen on FDA’s outbreak table have nothing in the product column, up from eight last week — including a brand-new SalmonellaJaviana investigation at 106 cases, an Oranienburg cluster up from 69 to 81, an Enteritidis cluster up from 91 to 96, and another Cyclospora investigation at 72. Both moringa leaf powder investigations ended. The table has not been updated since Wednesday, so the row for the lettuce outbreak still points at the advisory FDA superseded on Friday. Meanwhile the frozen blueberry E. coli O145:H28 outbreak, the soft cheese Listeriaoutbreak and the infant botulism outbreak — four babies, all hospitalized — all remain open. I represent families in those cases. On the recall side, Maple Leaf Foods pulled about 12,036 pounds of not-ready-to-eat smoked bacon imported from Canada without import reinspection, and Phyllis Entis has the full roundup.

I am headed to New Orleans. IAFP 2026 opens tomorrow at the Ernest N. Morial Convention Center and runs through Wednesday. It convenes while the largest cyclosporiasis outbreak in American history is still being counted, by nine different methods, in nine different states. If you are there, find me.

The answer to “when will it be safe to eat lettuce again” is not a tariff. It is three things, and all three are sitting there waiting.

  1. Restore the Microbiological Data Program, which for eleven years pulled high-risk produce off the shelf and tested it, and which the industry lobbied to death in 2012.
  2. Put the Food Traceability Rule into force. Its compliance date was January 20, 2026 — four months before the first person in this outbreak got sick — and it now sits pushed to July 20, 2028.
  3. Put Cyclospora back into FoodNet. Reporting had been mandatory since 1997; on July 1, 2025 FoodNet dropped six of its eight pathogens.

That’s the week — four states added to an outbreak that got six weeks shorter, a recall the company tried to slow down, nineteen million eggs seven months late, a federal table with ten investigations and nothing in the product column, and one veterinarian who took the time to tell me I had it wrong. Check back next Saturday.

About Bill Marler

William “Bill” Marler has spent more than thirty years as a food safety lawyer and advocate—work that began with the 1993 Jack in the Box E. coli outbreak and has never really stopped since. In the years that followed, he has represented victims in nearly every major foodborne illness outbreak in the United States. That case, and the movement it launched, is the subject of the book “Poisoned” and the Emmy Award–winning Netflix documentary of the same name. Bill’s work has been profiled in The New Yorker (“A Bug in the System”), the Seattle Times (“30 years after the deadly E. coli outbreak, a Seattle attorney still fights for food safety”), the Washington Post (“He helped make burgers safer. Now he’s fighting food poisoning again”), and many others.

Dozens of times a year, Bill speaks to industry, regulators, and universities across the United States, Canada, Europe, Africa, China, and Australia about a simple idea: outbreaks are preventable. He has testified before Congress on the Food Safety Modernization Act and teaches food safety at institutions including the Harvard T.H. Chan School of Public Health. He writes regularly about food litigation and food safety at Marler Blog, and in 2009 he founded Food Safety News, which he continues to publish.

Corrected July 25, 2026. An earlier version of this post said that the United States does not vaccinate laying hens and that the British government requires vaccination. Both were wrong. Dr. Eric Gingerich, a poultry veterinarian in Zionsville, Indiana, wrote to tell me so, and the record backs him up on both counts. The title, the last three paragraphs and the closing line have been rewritten. My thanks to him.

Ninety-eight people in 17 states. Twenty-six in the hospital. CDC’s outbreak page went up yesterday, and the illness onsets run from November 21, 2025 to June 30, 2026. Seven months of sick people before a carton came off a shelf.

Midwest Poultry Services recalled 1,589,577 dozen shell eggs on July 22 — 19 million eggs — out of two Texas farms, sold as Kroger, Simple Truth, Brookshire’s, Cal-Maine and Country Morning. FDA says laboratory, epidemiologic and traceback data point at those eggs, and it is still looking for others. Farm environmental samples matched the outbreak strain by whole genome sequencing.

Americans used to drink these on purpose. Rocky cracked five into a glass in 1976 and Stallone actually swallowed them. Vince Gironda, the Iron Guru who trained Schwarzenegger, sold raw eggs as recovery food. Fighters drank them because it beat cooking. Then the gyms quit, in the late 1980s, on the sound theory that a fighter dehydrated on a bathroom floor does not make weight. The protein math was wrong anyway — a raw egg surrenders about half its protein, a cooked one about ninety percent. The trainers figured it out before the regulators did.

What scared them had a name, and she paid for it. In December 1988 Edwina Currie, a junior health minister in Britain, said “Most of the egg production in this country, sadly, is now affected with salmonella.” Egg sales collapsed overnight. Two million hens went to slaughter, the farmers came for her, and she was gone in two weeks — the woman who wrecked an industry with one sentence.

She was right. A Whitehall report written months after she resigned and buried until 2001 found Britain in the middle of a Salmonella epidemic of considerable proportions. By her own account: 500 people a week sick enough for a hospital bed, some on dialysis, about 60 dead that year.

Then Britain vaccinated the hens — though not by law, which is the part I got wrong. The British Lion Code, 1998, is an industry scheme run by the British Egg Industry Council, and the Lion mark is a registered trademark its subscribers may use only on eggs produced to the code. To carry it: Salmonella vaccination of laying flocks against both Enteritidis and Typhimurium, hygiene and temperature controls, testing of flocks and of eggs beyond what the National Control Programme requires, traceability back to the farm, a date stamped on the shell, and independent unannounced audits. It covers more than 90 percent of British eggs. The government sets the floor. The industry built the rest. In October 2017 the Food Standards Agency took down its own thirty-year warning and told pregnant women, babies and the elderly that Lion eggs were safe raw.

Not a clean win, and I won’t sell it as one. The Bureau of Investigative Journalism found at least 100 cases over the three years after that announcement. FSA’s own risk profile shows farm detections climbing since 2017 and one stubborn Enteritidis cluster that reached 109 cases, most of them people who had eaten Lion eggs. England booked 10,406 salmonellosis cases in 2025, its worst in a decade — though Enteritidis, the serovar the Lion Code vaccinates against, went the other way, from 3,166 reports in 2024 to 3,104 in 2025. FSA weighed all of it and left the advice standing. Vaccination did not eradicate anything. It bought a reduction deep enough, and durable enough, that a government could stop warning mothers off soft-boiled eggs and hold that line when the numbers were checked again.

Now ours. Four agencies touch eggs, which is why nobody can answer this question at a dinner party. USDA’s FSIS has egg products — liquid, frozen, dried — continuous inspection, mandatory pasteurization. USDA’s AMS grades shell eggs and screens out the cracked and the dirty. USDA’s APHIS certifies hatcheries. The carton in your refrigerator belongs to FDA.

FDA’s Egg Safety Rule has been on the books since 2009. Producers with 3,000 or more hens, eggs not pasteurized: buy pullets from monitored suppliers, keep a biosecurity plan, control the rodents, disinfect after a positive, swab the house at 40 to 45 weeks and again after a molt, test the eggs if the swab comes back hot, refrigerate at 45°F starting 36 hours after lay. FDA figured it would cut egg-borne SE illness by about 60 percent, and prevent about 30 deaths a year. The farms see an inspector every three to five years We vaccinate the hens.

Twice. A laying house gets swabbed twice in a flock’s productive life, and the farm gets a visitor once or twice a decade. Midwest Poultry says its own monitoring is what caught this. Ninety-eight people got there first.

Here is what the rule has produced. Every multistate Salmonella outbreak traced to American shell eggs since FDA wrote it:

  • 2010 — Wright County Egg and Hillandale Farms, Iowa. S. Enteritidis. CDC counted 3,578 illnesses between May 1 and November 30 against a baseline of about 1,639 — roughly 1,939 illnesses likely tied to the outbreak. Half a billion eggs recalled, still the largest shell egg recall in American history.
  • 2015 and 2016 — Good Earth Egg Company, Bonne Terre, Missouri. S. Oranienburg, twice, the same strain both times. Fifty-two sick in six states, then eight sick in three states with two hospitalized, after which Missouri closed the operationWe vaccinate the hens. Nobody checks the work.
  • 2018 — Rose Acre Farms, Hyde County, North Carolina. S. Braenderup. Forty-five sick in 10 states, 11 hospitalized, 206,749,248 eggs recalled. FDA’s warning letter found the outbreak strain in the processing plant and in manure from laying house No. 9, and laying houses rife with rodents.
  • 2018 — Gravel Ridge Farms, Cullman, Alabama. S. Enteritidis. Forty-four sick in 11 states, 12 hospitalized — a 32 percent hospitalization rate against a 20 percent norm.
  • 2024 — Milo’s Poultry Farms, Bonduel, Wisconsin. S. Enteritidis. Ninety-three sick in 12 states, 34 hospitalized, onsets from May 23 to September 13.
  • 2025 — August Egg Company, Hilmar, California. S. Enteritidis. One hundred thirty-four sick in 10 states, 38 hospitalized, one death in California. Onsets February 24 to June 6. 1.7 million dozen recalled.
  • 2025 — Country Eggs, LLC, Lucerne Valley, California. S. Enteritidis. One hundred five sick in 14 states, 19 hospitalized, onsets January 7 to August 14 — seven months, again.
  • 2026 — Midwest Poultry Services. S. Enteritidis. Ninety-eight sick in 17 states, 26 hospitalized, 1,589,577 dozen recalled.

About 2,500 counted illnesses, and counted is doing the work — these are only the multistate investigations. Four of them landed in the last three years. The last two each ran seven months before anyone pulled a carton. That is not a story about bad actors. It is a story about the interval between swabs.

Vaccination is the one thing the rule does not require. FDA looked at it in 2009 and decided the efficacy data weren’t strong enough to let a vaccine stand in for any prevention measure, and that finding has never been reopened. Here is what I missed: it did not need to be, because the industry vaccinates anyway. USDA’s National Animal Health Monitoring System surveyed 328 table-egg farms across 19 states and found 89.9 percent had vaccinated their layers as pullets, another 9.1 percent as pullets and again as layers, and 1.0 percent not at all. The most common protocol, on 39 percent of farms, was two live S. Typhimurium sprays followed by an inactivated bacterin injection, with about half of those farms giving the first dose at the hatchery. USDA also found that flocks vaccinated as pullets were markedly less likely to test positive for SE. Vaccination works. We already do it.

So the ask I closed with was the wrong ask. The hens were already vaccinated. Ninety-eight people got sick anyway, across seven months, and nobody pulled a carton until the seventh.

What Britain has that we do not is not the needle. It is everything built around it. Lion producers are audited independently and without warning. Lion eggs are tested, not just the houses they came from — USDA found 96.3 percent of American farms testing their layer-house environments and 5.8 percent testing eggs. Lion eggs carry a date on the shell and a record back to the flock. Our farms swab twice in a laying hen’s productive life and see an FDA inspector every three to five years. Between the swab and the carton there is nothing but time, and this time it was seven months of it.

We vaccinate the hens. Nobody checks the work.