June 30, 2008
Gene Gregory, President & CEO
United Egg Producers
720 Windward Concourse, Suite 230
Alpharetta, GA 30005
Re: Molting of Laying Hens
Dear Mr. Gregory:
I am writing about the current status of UEP’s molting programs, and how use of these programs by specific companies is being verified and monitored under UEP’s Certification Program.
June 4, 2007 Feedstuffs published an article about a 2004 UEP survey of 46 companies to determine what type of molting program they used. Twenty-two said they used a feed withdrawal program, and 24 said they used a non-withdrawal program. Of producers who had tried a non-withdrawal molt program, about 80 percent said they would continue using some type of non-withdrawal feeding program, according to the article, which went on to say that:
Based on the UEP scientific advisory committee guidelines, modified in February 2005, UEP amended its Animal Husbandry Guidelines for U.S. Egg Laying Flocks to specify that only non-feed withdrawal molt methods would be permitted after January 1, 2006, and molting hens would have to be fed nutritionally adequate and palatable food suitable for a non-egg producing hen.
Has UEP done any more surveys since 2004 to determine how many companies of those surveyed are using non-feed withdrawal programs? In addition:
How exactly are molting programs conducted by specific egg companies at specific locations being verified and monitored under UEP’s Certification Program? How is accountability being established and tracked – and by whom?
Please advise regarding the molting situation in 2008, and how compliance under UEP’s Certification Program is being certified, i.e., actually verified on a per-company basis. Any additional information would be greatly appreciated.
Thank you for your attention. I look forward to your response.
Sincerely,
Karen Davis, PhD
President
PO Box 150
Machipongo, VA 23405
Karen@upc-online.org
July 5, 2008
Dr. Karen Davis, President
United Poultry Concerns, Inc.
P.O. Box 150
Dr. Davis,
Your letter of June 30th requested information about the UEP Animal Husbandry Guidelines regarding molting programs. We are pleased to report that all egg farmers on the UEP Certified program must follow the molting requirements. Approximately 83% of all egg farmers in the United States now are implementing the guidelines of the UEP Certified program.
The guideline for molting is very clear. Any company that molts a flock using any feed withdrawal method is automatically cancelled from the UEP Certified program and may no longer market eggs as UEP Certified. This is verified through annual audits conducted by USDA Agricultural Marketing Service or Validus Services. UEP Certified egg farmers have taken this requirment very seriously and have discontinued feed withdrawal molts. Knowing that an egg farmer could lose their egg market, the farmers can not take the risk of continuing a feed withdrawal molt. We can therefore assure you without any further surveys that all UEP Certified companies are following the molt requirements.
UEP does have one exception. If a new company wanting to join the UEP Certified program and who had previously molted flocks that are still on their farm must agree to use only non-feed withdrawal molt programs from the date of making an application forward.
The answer we provided about are for only UEP Certified companies. We can not answer for those egg farmers that have elected to not implement the UEP Animal Husbandry Guidelines and enroll in the UEP Certified program.
United Poultry Concerns, Inc.