Rebuttal of The Country HenAugust 29th, 2014
The Real Chicken Poop
On May 19, 2014 The Country Hen, a vertically integrated egg producer based in Hubbardston, Massachusetts, wrote a letter to a customer explaining their animal husbandry and egg production practices while also attempting to discredit The Cornucopia Institute’s Egg research and Scorecard project. Here we share with you what The Country Hen said and what The Cornucopia Institute believes to be the facts. Points of clarification will be in italic.
“In their [Cornucopia Institute] pursuit to promote small family farming, they target the commercially sized operations that are able to provide the quantities of organic foods necessary to meet consumer demand and remain reasonably priced in the retail market.”
- The Cornucopia Institute looks at the enforcement of federal organic standards as “scale neutral.” We fight for economic justice for family farmers. Some family farmers operate large operations while others operate very small operations along with everything in between. If operated in compliance with the spirit and letter of the law, are all valid and important to the organic community.
- Small- and mid-scale egg producers can certainly be considered “commercially sized” operations if they earn a profit. It is not true that only large and very large egg operations are commercially viable. The Cornucopia Institute does not “target” commercial operations; rather, we hope that all farms can be profitable and operated in accordance to the law. Large corporations try to portray family-scale farms as having 20-100 chickens scratching around in the barnyard. And although some are on that small scale (producing wonderful eggs for their local community), we would not consider those commercial operations in the wholesale marketplace.
- Hundreds of smaller-scale farms can provide the same number of eggs as a handful of very large ”factory farms.” For illustration, 300 farms with 3,000 hens each (the maximum legal size in Europe for organic production) could produce over 18 million dozen eggs or the same could be said for one very large CAFO (concentrated animal feeding operation) that raises 900,000 hens in confinement. If the organic regulations were enforced, particularly the requirement for outdoor access for laying hens, then many of these very large operations would not be able to legally operate as certified organic.
“George Bass [company owner]…determined that the hens needed to have 1.5 square feet of floor space, per bird, in order to provide optimal comfort and room for stretching wings.”
- While 1.5 square feet of space per bird is slightly better than the industry standard of 1.2 square feet for floor birds, Animal Welfare Approved and European Union organic standards both require 1.8 square feet per hen.
- Since The Country Hen does not provide outdoor access for their hens, birds don’t really get to exhibit their natural behaviors, such as foraging and stretching their wings outside, as they would like to do. So 1.5 square feet gets a little cramped when there is no outdoor access.
“The only significant differences between the ideal stated by the “Scrambled Eggs” report by Cornucopia and what The Country Hen offers are: # of hens in operation, and outdoor access. With regard to the size of the operation, we believe that it is not the size of the operation that matters—it is the way the hens are treated and the ability to produce quality, safe, organic product, in a manner that meets the new FDA Salmonella testing requirements.”
- The Scrambled Eggs report makes no distinction based on number of hens in an operation, but rather the number of hens kept in a single flock or barn. Animal welfare experts from around the world have determined that large flock sizes are detrimental to laying hen health and their egg laying productivity. Animal Welfare Approved recommends flocks no larger than 500 birds, and European Union organic rules stipulate flock sizes no larger than 3,000. The Country Hen could choose to put dividers in their barns or build more barns so that flock sizes could be reduced and hen health improved, but they choose not to, despite the best science. Currently their hen houses hold tens of thousands of birds each.
- The FDA’s new Salmonella guidance was implemented many years after The Country Hen decided to deny outdoor access to their laying hens, so they are using this as an excuse. Furthermore, the new Salmonella guidance does not prohibit outdoor access. It merely states that wild birds and rodents must be managed so as to not come into contact with the laying hens. This is achievable with good outdoor management.
“Cornucopia’s report not only implies, but actually comes right out and states that the small farm with hens out on the pasture with other animals are the way to go.”
- The National Organic Program (NOP) regulations CFR 205.239 stipulate “Year-round access for ALL animals to the OUTDOORS, shade, shelter, exercise areas, fresh air, clean water for drinking, and DIRECT sunlight, suitable to the species, its stage of life, the climate, and the environment.” It goes on to say that “Continuous total confinement of any animal indoors is prohibited.” Therefore, yes, The Cornucopia Institute would like to see all organic egg producers provide genuine outdoor access and direct sunlight as required by the organic regulations.
- The National Organic Program requires certain methods of agricultural production. These methods integrate cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity. The practice of rotating laying hens on pasture with other livestock is an example of integrating cultural and biological practices while cycling nutrients, promoting ecological balance, and encouraging biodiversity. Keeping tens of thousands of hens locked up in a cramped barn is the exact opposite of the true organic philosophical approach and legal mandates.
“The other discrepancy between Cornucopia’s “ideal” and The Country Hen is our position on outdoor access. We firmly believe that the only safe outdoor access for our hens is via protected porches.”
- Again, the USDA’s National Organic Program requires outdoor access and direct sunlight for all animals. Continuous confinement is prohibited. A roofed, floored, screen walled space is not the “outdoors,” but rather an extension of the building. They are akin to sunporches that you may have attached to your house for summer sleeping. But they are not the outdoors. This practice is in violation of the National Organic Program regulations.
“We stand behind porches for several reasons. First, out on the range, the hens are at risk of developing Avian Influenza and other diseases that can be passed to them via wild birds and migrating waterfowl. Second, the hens would be exposed to predators, such as coyotes, foxes, and raccoons that could invade and devastate a flock of hens. Third, if not ranged properly, the ground they occupy will be stripped to bare soil, which increases the risk of them being exposed to worms and parasites.”
- Highly Pathogenic Avian Influenza (HPAI) in domesticated poultry has only been recorded once in the United States since 1997 (not an organic farm with outdoor access). Only a handful of Low Pathogenic Avian Influenza (LPAI) outbreaks have been recorded in the U.S., most of them on turkey farms or broiler breeding operations, not laying hen operations. Therefore, the risks of U.S. laying hens contracting pathogenic strains of Avian Influenza are very rare. Using this as an excuse to confine hens is like telling people not to go hiking because of the risk of getting struck by lightning.If the USDA determined that an outbreak of HPAI was occurring, the organic standards do permit for the “temporary” confinement of livestock to accommodate such situations.
- All organic egg farmers that we surveyed had low predation rates, even those that pasture their birds. They all use a variety of management practices to prevent predation, including electrified fencing, guard animals, noise cannons, red night lights, and other practices (and generally, temporarily, confining their birds in a henhouse at night). The risk of predation should not be used as an excuse to justify continual confinement.
- Since the National Organic Program rules require soil conservation, recycling of nutrients, and properly managing manure, it would not make sense for organic poultry producers to allow their chickens to destroy their pastures since that would be in conflict with the organic regulations. Good management practices such as appropriate animal stocking densities, rotational grazing, reseeding, and irrigation can maintain the outdoor areas in good condition. They also reduce the incidence of parasite build-up. Confined birds with higher stocking densities, such as those at The Country Hen, suffer from higher rates of coccidiosis, a parasite that causes internal bleeding, and they also suffer from higher rates of Salmonella due to stress. Close quarters also promote aggressive behavior, seriously injuring birds, and sometimes even cannibalism.
“We were denied [organic] certification by NOFA/Mass because they did not consider our porches acceptable outdoor access. As we explained earlier, we do feel that they are, and filed an appeal with NOP. NOP sustained the appeal, and required NOFA/Mass to certify us as organic, but NOFA/Mass refused. It became obvious that we were not going to be able to have a working relationship with them when they refused to accept the decision of the National Organic Program. As such, we decided we needed to move on to a different certifying agency.”
- Massachusetts Independent Certifiers Inc. (MICI) rightly did not believe that porches constituted outdoor access—because they don’t! They were upholding the National Organic Program regulations CFR 205.239 Livestock Living Conditions.
- The then director of the National Organic Program decided to favor The Country Hen by misinterpreting the organic regulations to allow screened-in porches as “outdoor access” and dictated that MICI certify the operation over their objections. It was not an “appeals process” since he instructed them to certify The Country Hen exactly one day after MICI rejected their application for certification.
- The former NOP director, after his retirement from the USDA, then went on to work for The Country Hen, as a consultant. Some would consider this a perfect example of the “revolving door” between government and private industry.
“We believe that firm guidelines need to be established, and once established, they need to be adhered to by producers, and enforced by certifiers.”
- The guidelines are clear. CFR 205.239 Livestock Living Conditions stipulate “year-round access for all animals to the outdoors, shade, shelter, exercise areas, fresh air, clean water for drinking, and direct sunlight, suitable to the species, its stage of life, the climate, and the environment.” It goes onto say that “continuous total confinement of any animal indoors is prohibited.” The rules are clear and, in our opinion, it appears The Country Hen is breaking them by: 1) not providing year-round outdoor access (weather permitting): their website states that their porches are only open from May 15-October 15 due to weather. Other producers in the Midwest and Northeast restrict outdoor access more temporarily on the basis of the weather, not merely the calendar. 2) They also appear to be breaking the organic rules by not offering DIRECT SUNLIGHT, which can only happen when an animal is directly under the light of the sun (i.e., outdoors). Depending on the orientation of the building, and the location, size and number of windows, many of their birds will never have exposure to sunlight. 3) Having their birds confined to the indoors from October 16-May 14 is seven months long. That is not exactly “temporary confinement.”