Even the petitioner, Dr. Jonathan Reisman of Philadelphia, acknowledged that his is an “unusual request.” It was 2023’s first petition to USDA’s Food Safety and Inspection Service (FSIS) for a policy change.

The medical doctor’s petition requests that FSIS amend the 9 CFR 310.16(a) regulations to remove the prohibition on using livestock lungs for human food.  Since it was filed, the Reisman petition has generated a half dozen favorable comments.

“Hello, please accept the petition by Jonathan Reisman MD to allow the lung to be sold and consumed by people,” writes the most recent commenter on Dec. 6.  “Organ meat is a simple way to make inexpensive, nutrient-dense food available. I want to eat nose to tail and make the most of my meat consumption. There isn’t any good reason to ban lung meat.”

In the Jan. 10 petition, the author wrote:  “I am writing as a medical doctor, author, and food writer, and I believe there is no legitimate scientific basis for this rule. Of course, diseased livestock lungs should be appropriately condemned, but this rule is not based on concern over actual lung pathology in animals. 

“Instead, the rule is based on studies done by the USDA around the year 1969 in which scientists examined animal lungs and found contaminants in the airways, specifically fungal spores, dust, pollen, and aspirated rumen contents. These lungs were generally pathology-free, and it was solely because of these supposed contaminants that the rule was amended to declare lungs unfit for human consumption.

“I do not doubt that many people at the USDA, as well as in the general public, would feel squeamish when faced with the prospect of eating these substances, but food being ‘gross’ is not the same as it is unsafe. There is no medical reason to suspect that eating the tiny amount of these contaminants in animal lungs would pose any health risk to people of any age or baseline health status. While, to my knowledge, no studies prove that lungs are safe to eat, we can look at developed countries wher lungs are regularly eaten (the UK, for example) and see no ill health effects resulting from it.”

FSIS’s Office of Policy and Program Development was assigned the job of reviewing the petition, assigned the number 23-01.

One opposition commenter challenged Reisman’s use of the statement that lungs are “generally” pathology-free without offering any proof of that statement.

Dr. James E. Chlebowski said he has never seen any illness related to the practice as a family doctor for 30 years in rural Pennsylvania, wher lung consumption is not unusual in Amish and Mennonite communities.

In his petition, Reisman admits “that there does not appear to be widespread enthusiasm among the American public in overturning this rule. The large majority of Americans probably know nothing about this rule and have never thought about why lungs do not often appear in butcher shops

“The lack of mass public mobilization clamoring for the USDA to overturn this rule should not be a legitimate reason to keep it in the federal register through regulatory inertia,“ he adds. “Food policy should be evidence-based and scientific, and this rule is neither. Food policy should aim to maintain or improve the population’s health, and this rule does not contribute to that mission.”