Protecting families from contaminated food and water
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Protecting families from contaminated food and water
Posted in Our Blog,Outbreaks & Recalls,Salmonella on March 11, 2026
The U.S. Food and Drug Administration (FDA) issued a Black Sheep Egg Company Warning Letter. Last year the egg producer issued a massive recall to the tune of around six million eggs. It also created a downline recall for those using their product under private labels.
The reason for that recall is the subject of the recently issued FDA enforcement action.
What is an FDA Warning Letter, and why has Black Sheep Egg Company received one?
Let’s explore!
An FDA Warning Letter is an official notice to a company “regarding significant, documented violations of federal regulations, typically following an inspection.”
These letters are issued for things like:
Warning Letters have a ticking clock. A response on what has been done to correct the deficiencies or a timeline on correcting them is required. Without resolution additional consequences up to and including suspension, seizure, and financial penalties are pursued.
So, what happened at the Black Sheep Egg Company to warrant such attention?
During a routine facility visit between August 20, 2025 and September 12, 2025 at Black Sheep Egg Company’s egg processing facility in Walnut Ridge, Arkansas, the FDA made certain concerning observations and took environmental samples. This type of inspection is not unusual and is part of the FDA’s role in protecting the nation’s food supply.
In addition to those observations, 40 of the environmental samples collected tested positive for at least seven different strains of Salmonella bacteria. Some of which are known to cause human illness.
As a result, a large-scale recall was initiated. Including a recall for a private label company out of the Houston, Texas area.
According to the advisory, “FDA does not have information available at this time to suggest that this firm is the source of an ongoing outbreak.” However, significant contamination risk cannot be ignored.
The basis for the Warning Letter, according to the document, was that the FDA determined that the shell eggs produced at the facility were “adulterated.” According to the Federal Food, Drug, and Cosmetic (FD&C Act), this definition fits because the eggs were “prepared, packed, or held under insanitary conditions whereby they may have become contaminated with filth or whereby they may have been rendered injurious to health.”
In addition to the FD&C authority, shell egg producers must also comply with the “Prevention of Salmonella Enteritidis in Shell Eggs During Production, Storage, and Transportation regulation,” also known as the Shell Egg Regulation.
An initial findings report was submitted to the firm on September 10 and 18, 2025.
Written responses were received by the FDA on September 19, 2025, September 22, 2025, and October 1, 2025 “describing corrective actions taken and planned” by Black Sheep Egg Company.
However, the FDA did not deem the responses adequate. As such, they issued this Black Sheep Egg Company Warning Letter to ensure sufficient and timely response.
What all did it entail?
Pest control issues were observed, along with “flies too numerous to count” within the processing facility. Among the contributing factors were overhead rolling doors left open. Which allowed insects access to the processing area during shell eggs washing activities.
Both live and dead insects were observed around the equipment and around the dehydrator shed along with residue that attracts them.
Black Sheep Egg Company has documentation from their pest control company that applied parasitic wasp treatments that naturally control the pest population. However, the FDA understands that that “these large-scale applications indicate a severe fly infestation.”
In their written responses, Black Sheep Egg Company indicated that they cleaned and sanitized the dehydrator. They also indicated a plan to add more gravel, and began installing insect curtains along with large ceiling fans to help control the processing room temperature and discourage staff from opening the large bay doors.
The FDA seemed satisfied with that response. However they indicated they would be verifying the effectiveness of those corrective actions in the next inspection.
In addition to broken eggs and egg residue observed on equipment over multiple days of the inspection, no detergents were used to sanitize equipment on the washing and packing lines.
Washed eggs and packages come into contact with broken egg residue, leading to potential cross-contamination.
A power washer was employed to clean the packaging lines. However, this method generates overspray from the floor to equipment surfaces, introducing additional cross-contamination risk.
The FDA indicated that in addition to the “extensive presence of Salmonella” species found at the facility, these observations further demonstrate the inadequacies of the established cleaning and sanitation procedures.
During the close of the inspection, the firm stated that a “new post-operational sanitation check” will be complete by the sanitation manager instead of relying on the pre-operational sanitation check. The initial written response on this involved a promise to update the sanitation standard operating procedures and other activities to remedy the contamination risk.
The FDA is requesting supporting documentation for review.
Certain refrigeration requirements must be met for holding or transporting shell eggs.
Under the Shell Egg Regulation, if the eggs are not processed for the ultimate consumer within 36 hours (and come from a farm with 3,000 or more laying hens), eggs must be kept below 45 °F.
During the inspection, documented air temperatures were between 78 °F and 87 °F. Additionally, required temperature records were not being maintained.
In response to these deficiencies, Black Sheep Egg Company created a new form to document egg temping and plan to implement its use.
The FDA indicated that they would verify the accuracy of the corrective actions during the next inspection.
This Black Sheep Egg Company Warning Letter is an example of what goes on behind the scenes at the FDA. Just because the recall has been completed or the outbreak investigation has ended, does not indicate the process is complete.
Additional activities like corrective actions (and FDA approval of corrective actions) and follow-up inspections are performed to help prevent the situation from repeating.
If you became sick after consuming Black Sheep Egg Company eggs, you may have a legal case. It is a good idea to consult with an experienced Salmonella Lawyer to understand your rights.
The Lange Law Firm, PLLC can help!
The experienced Salmonella Lawyers at The Lange Law Firm, PLLC have successfully represented cases just like yours and won millions of dollars in food poisoning and products liabilities lawsuits.
Reach out by calling (833) 330-3663 or send us an email for a free, no obligation consultation.
Don’t wait. Call today!
By: Heather Van Tassell (contributing writer, non-lawyer)