This letter is in response to the USDA news Release No. 0212.98 entitled: USDA, FDA EXPAND EFFORTS TO ENSURE EGG SAFETY.

Please send the USDA your comments!

Comments will be accepted until August 18, 1998

June 16, 1998

Docket Clerk
Docket No. 96-035A
Room 3806 South Agricultural Building
1400 Independence Avenue, SW
Washington, DC 20250-3700

The Comments of United Poultry Concerns on Preventing the Introduction of Salmonella enteritidis in Laying Chickens

United Poultry Concerns, Inc. is a 501(c)(3) non-profit organization that addresses the treatment of domestic fowl in food production, science, education, entertainment, and human companionship situations. United Poultry Concerns promotes the compassionate and respectful treatment of chickens and other domestic fowl.


United Poultry Concerns welcomes the joint effort by the U.S. Food & Drug Administration and the U.S. Department of Agriculture to establish a farm-to-table strategy affecting the treatment of hens used for egg production, based on the fact that, as stated in the Federal Register Proposed Rules, May 19, 1998, Salmonella enteritidis infected flocks have become prevalent throughout the country.

While the handling of eggs no doubt contributes to the incidence of foodborne illness, handling per se does not generate Salmonella enteritidis. Poor handling--"product abuse"--can only multiply the salmonellae that are already in the egg, reflecting the pathogenicities--the disease-causing complex of animal abuses--to which the birds who lay them are subjected. Cleaning of contaminated layer houses is virtually impossible (Beard & Gast 36). Conditions at the farm level have been shown to debilitate the hens' immune response, causing disease organisms to enter into the formation of their eggs (Beard & Gast 32).

Chronic stress

Chronic stress weakens the birds' immune response, inviting primary and secondary pathogens to colonize their systems. Chronic stressors to which hens used for egg production are subjected include concentrated excretory ammonia gases (Carlile 101) and the frustration of basic hygienic behaviors, in particular, dustbathing (Vestergaard 10; Rogers 221). Caging, crowding, debeaking (Riddell 827-828), and antibiotics (Fowler 9; Evans n.p.) debilitate the birds' immune systems. Artificial light-dark manipulations (Smith 5) and forced molting--the deliberate starvation of hens for days and weeks at a time-- (Holt; Mason) promote Salmonella enteritidis in laying hens. Overall, the "stresses of high production and high stocking density" (Hooge 14) are so severe and overwhelming as to compromise the health and well-being of the birds. Fundamental improvements in husbandry practice and attitudes are needed.

Concentrated caged confinement

Microbiologist John Avens says that "Salmonella infection of animals will occur more frequently and affect more individual animals, as concentration of confinement increases" (122). The concentrated confinement of laying hens is such that 97.8 percent of hens laying eggs for human consumption in the United States are in cages so densely packed that the individual 3-to-4-pound bird has only 48 square inches of total living space (Bell 37; Hooge 29). The hen cannot assume a single normal body posture (Baxter 617). Locked in a state of unrelieved suffering and stress which includes the polluted air from the proximity of so many equally stressed hens, the hen is a prey to disease. Avian physiologist Lesley J. Rogers states that:
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. Chickens experiencing such environmental conditions attempt to find ways to cope with them. Their behavioural repertoire becomes directed towards self or cage mates and takes on abnormal patterns, such as feather pecking and other stereotyped behaviours. These behaviours are used as indicators of stress in caged animals. (Rogers 219)
Rogers states categorically concerning the battery cage system of housing hens, "In no way can these living conditions meet the demands of a complex nervous system designed to form a multitude of memories and to make complex decisions" (218).

Forced Molting

Forced molting is a stressor that has been found to depress the cellular immune response and increase the severity of a concurrent intestinal Salmonella enteritidis infection, creating a disease state in the alimentary tract of force-molted hens (Holt & Porter 1842). Dr. John Mason told a joint FSIS/FDA conference on November 20, 1996, that forced molted hens lay many more eggs that contain Salmonella enteritidis. Furthermore, force-molted hens are driven by their hunger to pluck and eat each others' salmonella-contaminated feathers in order to obtain nutrients (Riddell 828; Holt 1995:248). The spread of Salmonella enteritidis to and among the hens is amplified as a result of their consumption of contaminated feathers (Holt 1995:248).


Rodents also transmit Salmonella enteritidis. Forced molting facilitates the multiplication of salmonellae through the contaminated feces of the rodents that live in the caged layer houses. At night, mice eat the hens' food in the trough where they deposit an average of 100 fecal pellets per mouse in a 24 hour period. These contaminated fecal pellets are the first thing consumed by the hens when the lights are turned on in the morning (Beard & Gast 35; Holt 1993:416-417).

Conclusion: The Suffering and Sickness are Linked

While the issue at hand is Salmonella enteritidis, this pathogen does not occur in isolation; rather it is one part of a whole complex of diseases of caged laying hens, including immunosuppression, heat prostration, chronic respiratory disease (CRD), osteoporosis, cellulitis, viral tumors, fungal mouth ulcers, fatty liver syndrome, airsacculitis, and much more--a range of human groundwork production pathologies (Davis 56-61, 72-73). Disease organisms emerge and will continue to flourish and evolve in the inherently filthy, crowded, stressful, inhumane environment that the majority of chickens in the United States are condemned to live and lay their eggs in.


  1. The U.S. Department of Agriculture should establish and rigorously enforce regulatory authority over husbandry practices at the farm level of both hatching and commercial egg production.

  2. The USDA and the FDA should prohibit the forced molting of laying hens, based on the evidence that this cruel practice leads to Salmonella enteritidis in the birds, eggs, and consumers.

  3. The United States needs to join the European Union, Great Britain, Australia, Switzerland, and Sweden in acknowledging that the current methods of housing and treating chickens used for egg production are inhumane. The cruelty and contamination are linked via the hen's immune system. The prevalence of Salmonella enteritidis in U.S. laying flocks is a good example. It is time for the United States government to employ its skills and resources in the service of a husbandry system that incorporates the needs and well-being of the birds--their need to perch, dustbathe, exercise their bodies, breathe fresh air, and to eat and preen with an intact beak. The Department of Agriculture should establish a regulatory leadership role that combines genuine standards of humaneness and health for the birds, starting with the prohibition of debeaking and forced molting, and the implementation of a cage-free housing system. The Food and Drug Administration should prohibit the practice of forced molting, a vicious practice which causes suffering, contamination, and disease (United Poultry Concerns).

Works Cited

  • Avens, J.S. 1987. Overview: Salmonella--what's the problem? Third Poultry Symposium Proceedings (Fort Collins, CO: Colorado State University), 119-123.
  • Baxter, M.R. 1994. The welfare problems of laying hens in battery cages. The Veterinary Record 134:614-619.
  • Beard, C. and R. Gast. Jul/Aug 1992. Where are we with S.e.? Egg Industry:32-37.
  • Davis, K. 1996. Prisoned Chickens, Poisoned Eggs: An Inside Look at the Modern Poultry Industry (Summertown TN: Book Publishing Company).
  • Evans, T. Oct 1995. IEC gathers in Stockholm. Egg Industry: n.p.
  • Fowler, N. 1990. Competitive exclusion--the way forward? International Hatchery Practice 5.1:5,9.
  • Holt, P.S. 1992. Effects of induced moulting on immune responses of hens. British Poultry Science 33:165-175..
  • Holt, P.S. 1993. Effect of induced molting on the susceptibility of white leghorn hens to a Salmonella enteritidis infection. Avian Diseases 37:412-417.
  • Holt, P.S., and R.E. Porter. 1994. Effect of induced molting on the recurrence of a previous Salmonella enteritidis infection. Poultry Science 73:1267-1275.
  • Holt, P.S. 1995. Horizontal transmission of Salmonella enteritidis in molted and unmolted laying chickens. Avian Diseases 39:239-249.
  • Hooge, D.M. Aug 1994. Laying hen nutrition at high production, stocking densities. Poultry Digest:14, 16, 20.
  • Mason, J. Nov 20, 1996. FSIS/FDA Conference on Time and Temperature.
  • Riddell, C. 1991. Developmental, Metabolic, and Miscellaneous Disorders. Diseases of Poultry, 9th ed (Ames, IA: Iowa State University Press).
  • Rogers, L.J. 1995. The Development of Brain and Behaviour in the Chicken. (Wallingford, Oxon, U.K.: CAB INTERNATIONAL).
  • Smith, J.L. May 27, 1994 seminar. Reported in Food Chemical News, June 6, 1994.
  • United Poultry Concerns and the Association of Veterinarians for Animal Rights. 1998. Petition to the FDA to eliminate the forced molting of laying hens. Docket number 98P-0203/CP. Reported in Food Chemical News April 27, 1998:15.
  • Vestergaard, K.S. 1987. Alternative farm animal housing: ethological considerations. Scientists Center Newsletter 9.3:10-11.

    Karen Davis, PhD
    June 16, 1998

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