UPC Response to Proposed Organic Standards
Docket No. TMD-00-02-PR
National Organic Program
Room 2945-So., Ag Stop 0275
PO Box 96456
Washington, DC 20090-6456
Dear Mr. Jones:
On behalf of our 10,000 members, United Poultry Concerns
appreciates this opportunity to respond to the US Department of
Agriculture's proposed Organic Standards. United Poultry Concerns
is a 501(c)(3) national nonprofit organization which promotes the
well-being of chickens and other domestic fowl (poultry). We will
briefly address four husbandry/management practices that harm the
well-being of poultry: 1) debeaking; 2) forced molting; 3)
confinement living conditions; 4) forced rapid growth.
We urge that
1) USDA Organic Standards prohibit debeaking ("beak trimming").
2) USDA Organic Standards prohibit forced ("induced") molting.
3) USDA Organic Standards prohibit indoor confinement systems for
poultry, including cages and total confinement sheds. USDA
Organic Standards should require that poultry be kept in free-
range systems, and strictly define free-range systems to mean
that the birds can run and walk freely on range: i.e. an outdoor
environment in which they can completely or partially sustain
themselves, and exercise their natural behaviors: i.e. foraging,
dustbathing, sunbathing, walking, intermittent flying, perching,
laying their eggs in stress-free nesting areas.
4) USDA Organic Standards prohibit artificial growth promoting
practices including genetics, diet, and use of growth-promoting
antibiotics. Should an application for the use of growth-
promoting hormones be approved by the FDA for use in poultry
(currently there is no FDA-approved commercial use of hormones in
poultry), the use of hormones should be prohibited under USDA
I. DEBEAKING should be prohibited. As summarized in Michael C.
Appleby (1991) Do Hens Suffer in Battery Cages "The main injury
caused by humans, knowingly rather than accidently, is beak
trimming. It is now known to cause pain, in the short term and
probably also in the long term, in a way very similar to other
amputations" (pp. 9-10). Debeaking is a welfare abuse designed to
accommodate inhumane housing conditions that result in "severe
abnormal behaviors" in birds (Mench & Tienhoven, "Farm Animal
Welfare," American Scientist 74 [Nov-Dec 1986]:600). It prevents
birds from eating properly, preening (practicing hygiene)
successfully, and exploring the environment effectively.
According to Lesley J. Rogers, The Development of Brain and
Behaviour in the Chicken (1995), "The chicken uses its beak as if
it were a hand." A mutilated mouth and "hand" are not consistent
with good welfare. Dr. Ian J.H. Duncan, Professor of Poultry
Science, University of Guelph, has summarized the morphological,
neurophysiological, and behavioral evidence that "beak trimming
leads to both acute and chronic pain." (Duncan, "The Science of
Animal Well-Being," Animal Welfare Information Center Newsletter,
National Agricultural Library 4.1 [Jan-March 1993]:5.
Bottom Line: Debeaking should be prohibited.
II. FORCED MOLTING should be prohibited. Forced molting as
commonly practiced by the US poultry and egg industry consists in
removing all food from hens for 5 - 14 days to manipulate the
economics of egg production. Forced molting is a welfare abuse
that has been shown to increase susceptibility to Salmonella
enteritidis (SE) in hens, their eggs, and consumers of eggs and
egg products. Forced molting depresses hens' cellular immune
function as well as causing other pathologic changes including
"substantial damage" to the hen's large intestine (Peter Holt,
"The Effect of Induced Molting . . ." July 2,1998:
USDA's "Salmonella Enteritidis Risk Assessment-Shell Eggs and Egg
Products Final Report" June 12, Aug. 10, 1998, states: "There is
epidemiologic evidence which associates [forced] molting with
higher prevalence of SE in flocks. . . . [I]n a field study
during the Pennsylvania Pilot Project, molted flocks produced SE-
positive eggs twice as frequently as non-molted flocks for a
period up to 140 days following [forced] molt." This USDA study
by Schlosser et al (1995) comprised 31 hen flocks from May 1,
1992 to May 1, 1994.
USDA's Food Safety & Inspection Service states: "FSIS recognizes
that public health concerns are raised by highly stressful forced
molting practices. For example, extended starvation and water
deprivation practices lead to increased shedding of Salmonella
enteritidis (Se) by laying hens subjected to these practices"
(August 21, 1998).
USDA's Animal & Plant Health Inspection Service stated (Aug. 21,
1998) that the USDA Farm Animal Well-Being Task Group expressed
"serious concerns regarding the practice of forced molting of
poultry" with respect to "the humaneness of this practice as well
as the food safety issue."
The Animal Welfare Committee of the United Egg Producers (UEP),
which represents 80% of all US egg producers, stated in a letter
to California Assembly Member Ted Lempert. April 31, 2000:
"Behavioral and immune system measures indicate that the welfare
of the hen is compromised when feed withdrawal or restriction is
used to induce a molt. . . . We do not believe that feed
restriction or withdrawal to induce a molt should be continued."
Bottom Line: Forced molting should be prohibited.
III. LIVING CONDITIONS should be free-range, and free range
should be strictly defined as consisting of a clean, sustainable,
predator-proof outdoor environment--preferably a rotational
system to avoid build-up of manure and pathogens--in which the
birds have ample opportunities to perform natural behaviors
including nesting, perching, foraging, dustbathing, and
sunbathing as well as taking refuge in shade. Ducks should be
required to have swimming ponds that allow them to rinse their
eyes frequently in order to avoid "sticky eye" and related
infections to which ducks deprived of rinsing water are
susceptible. Terms such as "free roaming," free walking," and
"free running" should refer only to a predator-proof outdoor
sustainable (or semi-sustainable) environments for poultry.
Most especially, battery cages for hens used for egg production
should be strictly prohibited under USDA Organic Standards. In
June 1999, European Agriculture Ministers, acting under advice
from European scientists, agreed to ban battery cages from 2012.
Similarly, in Australia, all eight State and Territory
Agriculture Ministers agreed on March 3, 2000 that a phase out of
battery cages is necessary on welfare grounds.
At the United Egg Producers annual meeting in October 1999, Dr.
Jeffrey Armstrong, head of the animal sciences department at
Purdue University and chair of the UEP's advisory committee on
animal welfare stated that battery cages cause "suppressed social
behavior" in hens.
In The Development of Brain and Behaviour in the Chicken (1995),
Dr. Lesley J. Rogers summarizes the welfare abuse of battery
cages as follows:
Chickens in battery cages are cramped in overcrowded
conditions. Apart from restricted movement, they have few or
no opportunities for decision making and control over their
own lives. They have no opportunity to search for food and
if they are fed on powdered food, they have no opportunity
to decide at which grains to peck. These are just some
examples of the impoverishment of their environment. Others
include abnormal levels of sensory or social stimulation
caused by excessive tactile contact with cage mates and
continuous auditory stimulation produced by the vocalizing
of huge flocks housed in the same shed. Also, they have no
access to dustbathing or nesting material. . . . The
behavioural repertoire becomes directed towards self or cage
mates and takes on abnormal patterns, such as feather
pecking or other stereotyped behaviours. These behaviours
are used as indicators of stress in caged animals. (p. 219)
Bottom Line: Battery cages should be strictly prohibited and
poultry should be kept in genuinely free-range, preferably
rotational, outdoor environments and confined in predator-proof
enclosures at night. Dr. Lesley J. Rogers states in The
Development of Brain and Behaviour in the Chicken (1995),
"[G]enetic selection has favoured chickens that can live in
farmyard free-ranging conditions in contact with humans and other
species, but not in battery cages."
IV. FORCED RAPID GROWTH OF CHICKENS, TURKEYS, AND DUCKS
Antibiotics, genetic selection, and feed ingredients intended to
manipulate the growth of poultry artificially should be
prohibited under USDA Organic Standards. Birds subjected to
forced rapid growth are highly susceptible to metabolic and
skeletal disorders including ascites, heart attacks, and tibia
dyschondroplasia, in which the bones develop fractures and
fissures. Degenerative hip disorders in adult male turkeys have
been shown to result in a state of chronic pain that inhibits
their normal activity (Research in Veterinary Science 1991,
50:200-203). The pain in chickens caused by the lameness they
develop from forced rapid growth is so severe that given a choice
they choose food containing pain relieving drugs (The Veterinary
Record 146 [March 11, 2000]:307-311).
The administration of antibiotics to poultry to promote
artificial growth rates has been shown to impair their immune
systems and invite infections including fungal infections, as
well as to create disease-resistant bacteria rendering antibiotic
treatment of humans less effective or ineffective.
Bottom Line: Artificial growth promoters in poultry should be
prohibited under USDA Organic Standards.
United Poultry Concerns supports and welcomes organic farming and
USDA Organic Standards. We support the organic farming of plants
for human consumption. We do not support the use of animals for
food. We submit these comments with a view to reducing the
welfare abuses to which birds used for meat and egg production
are subjected in being so used. We have identified four serious
welfare abuses of the commercial poultry industry--the tip of the
iceberg. At the very least, USDA Organic Standards should
prohibit debeaking, forced molting, intensive confinement, and
forced rapid growth of chickens, turkeys, ducks, and any other
birds used for agricultural purposes. USDA Organic Standards
should incorporate specific husbandry requirements to ensure that
these birds can express their natural behaviors and not be
subjected to the chronic pain, frustrations, mutilations, and
other welfare insults imposed on them by the nonorganic
commercial poultry and egg industries.
Karen Davis, President
United Poultry Concerns, Inc.
Tel: 757-678-7875; fax: 757-678-5070
United Poultry Concerns. June 7, 2000