The Official Reason: USDA Regulations and the 1971 Ban
At the core of the prohibition against selling cow lungs for human consumption in the United States lies a specific piece of legislation: rule 9 CFR 310.16(a), which explicitly states, "Livestock lungs shall not be saved for use as human food". This rule was established following studies conducted around 1969 where USDA pathologists performed intensive examinations of animal lungs. During these inspections, they found a variety of contaminants deep within the lung tissue, including:
- Dust and dirt
- Fungal spores and pollen
- Aspirated contents from the animal's stomach
While critics, like physician Dr. Jonathan Reisman, have argued that these inhaled particulates are also swallowed daily by both animals and humans without significant harm, the USDA's position was that these impurities rendered the lungs unfit for commercial sale as human food. This blanket ban was a more straightforward regulatory approach than attempting to enforce complex and unreliable cleaning procedures for a low-demand product.
Food Safety and Processing Challenges
The anatomical structure of the lungs presents significant food safety challenges during processing that other organ meats do not. Unlike the stomach or intestines, which are essentially hollow tubes that can be flushed, the lungs have a complex, sponge-like structure of air sacs and passages. This makes them incredibly difficult, if not impossible, to thoroughly clean and sanitize. As a result, contaminants and blood can become trapped, leading to several issues:
- Rapid Spoilage: The porous nature and air content mean lungs can spoil very quickly after slaughter, increasing the risk of bacterial overgrowth.
- Cross-Contamination: During the slaughtering process, there is a risk of gastrointestinal fluids, containing potential pathogens, entering the lungs. The USDA has a zero-tolerance policy for this kind of contamination in meat products.
- Cooking Difficulties: Some offal experts note that lungs have a tendency to turn hard when cooked thoroughly, which might lead to undercooking and an increased risk of ingesting pathogens.
Cultural Context: Where Lungs Are Eaten and Where They Are Not
While the American and Canadian bans on selling lungs may seem absolute, many other cultures around the world regularly consume and value lung meat. This highlights the role of cultural norms in determining which parts of an animal are considered edible.
- In some Asian cuisines, particularly in Indonesia, dishes like Paru goreng (fried cow lung) are popular.
- In parts of South America, such as Peru, cow lung (known as bofe) is used in stews like chanfanita.
- Across various European and North American Indigenous cultures, ancestral nose-to-tail practices included consuming lungs, although this tradition has faded in many modern societies.
This discrepancy is famously illustrated by haggis. Traditional Scottish haggis contains sheep lungs, but imported versions must exclude this key ingredient to comply with U.S. law.
A Comparison of Offal Regulations
To understand why cow lungs are singled out, it is useful to compare them to other offal that is legally sold in the U.S. The following table contrasts regulatory considerations for lungs with those for heart and liver.
| Feature | Lungs | Heart | Liver |
|---|---|---|---|
| US Legality (Sale) | Banned | Legal | Legal |
| Ease of Cleaning | Extremely Difficult (sponge-like) | Easy (muscle tissue) | Easy (glandular tissue) |
| Spoilage Risk | High (porous, air-filled) | Lower (dense muscle) | Moderate (dense tissue) |
| Key Contaminant Risks | Inhaled particles, aspirated fluids | Blood (removed during processing) | Blood, potential for disease retention |
| Common Global Use | Varies by culture | Widespread | Widespread |
Modern Attempts to Overturn the Ban
Despite the longstanding ban, not everyone agrees with the USDA's decision. Dr. Jonathan Reisman, an advocate for nose-to-tail eating, formally petitioned the FSIS to overturn the ban in 2023. He argues that the rule lacks a legitimate scientific basis and points out the irony that pets are still allowed to consume dried lung treats. He suggests that the ban is largely a result of regulatory inertia and a cultural distaste for offal, rather than actual public health risk. As interest in sustainable eating grows, some hope that outdated regulations might be reconsidered.
Conclusion
In summary, the inability to purchase cow lungs in the U.S. is not due to them being inherently inedible but rather a result of a specific 1971 USDA regulation. This ban was implemented due to perceived food safety risks associated with the difficulty of properly cleaning the porous lung tissue and preventing cross-contamination from aspirated stomach contents. While many cultures around the world continue to prepare and eat lung meat, this regulatory decision, along with changing cultural preferences, has removed it from the American food supply. Despite recent challenges to the ban's scientific merit, the rule remains in place, making cow lungs a part of the animal that is relegated to non-human uses.
For more on the history and arguments surrounding the ban, you can read the article on the topic published by Eater.