United Poultry Concerns
June 7, 2000
UPC Response to Proposed Organic Standards

Keith Jones
Docket No. TMD-00-02-PR
Program Manager 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 Organic Standards.


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: www.nal.usda.gov/ttic/tektran/data/000007/07/0000070701.html).

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."


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
Email: karend@upc-online.org
Website: www.upc-online.org

United Poultry Concerns. June 7, 2000

United Poultry Concerns, Inc.
PO Box 150
Machipongo, VA 23405-0150
FAX: 757-678-5070

( UPC Response to Proposed Organic Standards )