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Animal welfare standards for organic poultry

September 20, 2011

Dear members of the National Organic Standards Board’s Livestock Committee,

Strong and meaningful animal welfare benchmarks are desperately needed in the federal organic regulations. We appreciate your efforts to make this happen, and your desire to make the organic seal the “gold standard” in terms of animal welfare in meat, egg and dairy production.

However, we are gravely concerned that your draft recommendations for poultry are woefully inadequate.

While we commend your position outlawing porches as “outdoor access” for organic poultry, we urge you not to settle for outdoor space requirements that are far too low to bestow any real and meaningful welfare benefits to the animals.

In the outdoor space that you are considering – 2 square feet per laying hen and 1 square feet per broiler – a bird would not even be able to stretch his or her wings, let alone move around freely to engage in natural behaviors such as dust bathing, foraging and wing flapping.

We believe that 5 square feet for laying hens and broilers, and 5 square feet per 7.5 lbs. for turkeys, is the absolute minimum acceptable compromise to meet the welfare needs of the birds and the expectations of organic consumers.

A body of scientific literature by animal welfare specialists confirms the numerous welfare benefits gained when birds are able to engage in natural behavior outdoors—including markedly reducing injuries stemming from aggression towards each other. With the proposed standard, the outdoor run would simply be too small to allow the birds to engage in any of these beneficial natural behaviors and will result in environmental degradation.

In the European Union, organic standards have a strong animal welfare component, and require at least 43 square feet per bird for laying hens and broilers. In countries where land is in much shorter supply than in the United States, every organic henhouse or broiler house has ample outdoor space available to each flock.

A minimum space requirement of 5 square feet is a compromise between your current proposal of 2 square feet and 1 square feet, and the ideal standard of 43 square feet. But most importantly, 5 square feet can be done – it is a realistic standard that can be met by commercial-scale organic producers in this country.

All but one of 80 farmer-members of the CROPP cooperative, selling organic eggs under the Organic Valley® brand name, currently meet the outdoor requirement for 5 square feet, as do farmers associated with a number of other organic brands. More than 40 organic farms and marketers who are ranked in the highest category (5-egg rating) of The Cornucopia Institute’s Organic Egg Scorecard currently meet or exceed the requirement of 5 square feet (the majority grant much more than 5 square feet).

We also urge you to accept a standard of 1.75 square feet per laying hen indoors, which is the current standard for major name-brand egg producers, including Organic Valley.® For broilers, which often spend a small percentage of their short lives outdoors, a strong requirement for indoor environmental enrichment is vital.

A phase-in period of one year, from the date that the rule goes into effect, would be acceptable. Given that the final rule is not likely to be approved by the USDA, published in the Federal Register, and brought into effect for some time after a NOSB vote, this would effectively give producers several years to come into compliance after a NOSB vote.

There is no precedent for a longer phase-in period, as has been discussed on the livestock committee. The one-year transition for the organic dairy industry, troubled by industrial-scale confinement operations, proved to be adequate.

Bending over backwards to accommodate multimillion dollar, vertically-integrated industrial producers of "organic" eggs, will continue to economically injure existing farmers and their marketing partners who are adhering to the spirit and letter of the current law. It would also deprive the opportunity for new farm families to enter this lucrative market segment.

Because of the disproportionate resources being spent by industrial-scale egg producers, we are concerned that you, the members of the Livestock Committee, have not adequately heard the balancing voices of those in the organic community who believe that outdoor space requirements for poultry should be meaningful – and by “meaningful,” we mean the space should be large enough to permit the birds to engage in natural instinctive behaviors without destroying the environment.

The recently convened NOSB working group on animal welfare issues was disproportionally composed of industry participants that have economic interests in opposing meaningful outdoor access. Larger industrial-scale producers have boycotted the process entirely, instead using their financial clout in an attempt to convince the USDA and FDA to ban outdoor access altogether.

We, the undersigned organizations, urge you to propose 5 square feet of outdoor space per laying hen and per broiler, and 5 square feet per 7.5 lbs for turkeys.

This is the bare minimum necessary to treat organic livestock respectfully and to meet the expectations of consumers who are willing to pay a premium in support of a more humane animal husbandry model.

Sincerely,

Animal Welfare Institute
Attune Foods
Basics Cooperative
Berkshire Co-op Market
Bloomingfoods/Bloomington Cooperative Services
Caughlan, Goldie (former NOSB member)
Center for Media and Democracy’s Food Rights Network
Common Ground Food Co-op
Community Alliance for Global Justice
Compassion in World Farming
Concord Cooperative Market
Cornucopia Institute
Cuatro Cienegas Farms & Ranches, LLC
Dawn Land Farm
Family Farm Defenders
Farmaggedon/Kristin Marie Productions
Farmer Direct Co-operative Ltd.
Ferry County Co-op
Food and Water Watch
Food Animal Concerns Trust
Giving Nature Organic Foods
Grand Forks Food Co-op
GreenTree Organic Grocery
Hall, Jennifer (former NOSB member)
Harmony Valley Farm
Harvest Market
Hippocrates Health Institute
Kalona Organics
Kettle Crust Bakery
James, Bea (former NOSB member)
Lehman Egg Service
LifeSource Natural Foods
McGrath Family Farms
Michigan Land Trustees
Michigan Organic Food and Farm Alliance
Midwest Organic Farmers Cooperative
Misty Meadows Farm
Mount Adams Buddhist Temple
National Family Farm Coalition
Nature’s One, Inc.
Nature’s Pantry
Neighborhood Co-op Grocery
New Morning Market
Northwind Natural Foods Co-op
Nourising the Planet
NYfoods, LLC
OPINS Co-op (Organic Producers Iowa, Nebraska, South Dakota)
Organic Consumers Association
Park Slope Food Coop
PCC Natural Markets
People’s Food Coop
Real Food Co-op
Real Food Store, Inc.
Respecting Animal Welfare and Rights/Clark University
Rising Tide Community Market
Safe Food and Fertilizer
Scheffler Farm
Selene Whole Foods Cooperative
Slow Food USA
Sustainable Living Systems
Tasting Awareness
Texas Organic Farmers and Gardeners Association
Trillium Natural Foods Community Co-op
Trout Lake Abbey
Turtle Ledge Farm
Tuscarora Organic Growers Cooperative
United Poultry Concerns
Vital Farms
Village Farm
Weston A. Price Foundation
Williamson Street Co-operative Grocery
Willimantic Food Coop
Windy Ridge Natural Farms
World Society for the Protection of Animals

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