Opposing S. 820 and H.R. 1731 Egg Bill Before Congress

Economic Concerns with Colony Cages

In March 2013 at the Midwest Poultry Federation Convention in St. Paul, MN, Dr. Atoussa Mazaheri, Company Veterinarian with Lohmann Tierzucht GmbH, Veterinary Laboratory in Cuxhaven, Germany reported that egg farmers in her country regretted the investment in the enriched colony cages because the animal activists, after successfully pressuring the move toward enriched colony cages, were now pressuring for no cages at all. She also reported with the changes in production systems of the re-emergence of poultry diseases that had been eradicated from Germany since 1998 with the resulting mortality in chickens upwards of 30% (an obvious welfare problem with the new production systems in Germany) 

In January 2013 at The Future of the U.S. Egg Industry educational program in Atlanta during the International Poultry Expo, German Professor Hans-Wilhelm Windhorst, International Egg Commission economist, described the effects of the conventional layer cage system ban in Germany in 2010. This preceded the January 1, 2012 EU Council Directive 1999/74/ED that mandated converting from conventional cages to colony cage systems for the whole of the European Union. According to Windhorst, the ban resulted in: 1) A countrywide loss of egg production requiring that eggs be imported. 2) Forced many farms into foreclosure.

Dr. Daniel Sumner, an agricultural economics professor at the University of California and director of the University’s California Agricultural Issues Center, said “real cost differences” are being found in the colony cage systems. On a cost-per-dozen basis, overall costs are highest for aviaries, followed by colonies and then by conventional cages.

The United Soybean Board released an economic impact study (March 2, 2012) showing the cost of eggs increasing 25% from $1.68 to $2.10 as a result of this legislation. A total cost increase to consumers in the U.S. by $2.66 billion.

Hen Welfare Concerns with Colony Cages

USDA’s research from the Egg Laying Hen Welfare released in the Summer of 2011 states: “Hens can experience stress in all housing types, and no single housing system gets high scores on all welfare parameters. Like-wise, no single breed of laying hen is perfectly adapted to all types of housing systems. Additionally, management of each system has a profound impact on the welfare of the birds in that system, thus even a housing system that is considered to be superior relative to hen welfare, can have a negative impact on welfare if poorly managed.” – -Laying Hen Welfare Fact Sheet, USDA-ARS-MWA, Livestock Behavior Research Unit, Summer 2011

The Coalition for Sustainable Egg Supply (CSES) noted preliminary welfare concerns from the enhanced colony cage systems. The scientists participating noted that in the enhanced colony cage the chickens sustained more leg and wing injuries. Dr. Joy Mench, co-scientific director and director of the University of California Center for Animal Welfare, said each housing system indicated its own advantages and disadvantages in providing for the health and wellbeing of the hens housed. Hens in enriched colonies experienced increased leg and wing fractures.  

Human Health Concerns with Colony Cages

As reported in the 2011 Journal of Poultry Science 90:1391-1396) under the title

Horizontal Transmission of Salmonella Enteritidis in groups of experimentally-infected laying hens housed in different housing systems By J. De Vylder*, J. Dewulf #, S. Van Hoorebeke#, F. Pasmans*, F. Haesebrouck*, R. Ducatelle*, and F. Van Immerseel* Department of Pathology, Bacteriology and Avian Diseases *, and the Department of Reproduction, Obstetrics and Herd Health, Research Group of Veterinary Public Health and Zoonoses #, Faculty of Veterinary Medicine, Ghent University, Salisburylaan 133, B-9820 Merelbeke, Belgium.

Abstract (abbreviated): Concerns regarding the welfare of laying hens have led to the ban of conventional cages in Europe from 2012 onward and to the development of alternative housing systems. A transmission experiment was performed to quantify the effect of the housing system on the spread of Salmonella Enteritidis (SE) within a group of layers. At 16 weeks of age, 126 birds were inoculated with SE and housed in 4 different systems; conventional cages, furnished cage, an aviary, and a floor system.

Discussion (abbreviated): Transmission between birds is expected to be higher in floor-raised birds. For the conventional cage, no transmission was observed. For the furnished cage, it was found that 1 seeder bird infected on average 0.201 contact animals. It needs to be emphasized the rate of transmission were obtained for a 4-week observation period. Therefore, for a full production cycle, which might take 40-50 weeks, a much higher number of secondary cases originating from the 1 infectious animal might be expected.

If the spread of a known pathogen is likely to increase under this cage system, then increased surveillance for this pathogen must be taken. This added cost will be borne by those 58 egg farmers making the conversion to the enhanced cage system.

For more information contact: Ken Klippen (Spokesman for Egg Farmers of America) tel: 610-415-1055 email:
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NAEF is urging egg farmers to explain how an animal welfare policy of transitioning to cage-free eggs is a step backwards. NAEF is not opposed to producing cage-free eggs, just opposed to the false premise in the recent food company announcements that cage-free eggs are more humane and better quality of eggs.  This implies that eggs produced in conventional cages are not. 

Animal activists are reaching out to food companies that use eggs urging a transition to cage-free eggs.  Conventional cage egg farmers are being urged by NAEF to expose the false narrative that cage-free is more humane or produces a better quality egg. 

Some egg farmers have done that using the results from the Coalition for Sustainable Egg Supply.  From a humane standpoint, egg quality standpoint, a farm worker standpoint, and cost standpoint, conventionally-produced eggs score the highest.  Egg farmers know that animal activists are intent on forcing production changes in the egg industry that will increase the cost of eggs without the supposed benefits they claim.  Furthermore, egg farmers have learnded that the animal activists will not be content with simply cage-free, but now they are recommending access to the out-of-doors.  While this seems innocent to the uninformed, out-of-doors access is setting up the industry for another devastating avian influenza outbreak.

Below are some points egg farmers are using in customer communications:

1. Humanely producing eggs

Cage-free increases the stress on chickens due to the establishment of a “pecking order” among the chickens.  The behavior inherent in chickens is to determine the social standing of the individual hens through “pecking” each other.  The individual chicken lower in the social order is pecked the most.  When chickens are housed in conventional cages with 6 chickens, the establishment of this pecking order is minimized compared to thousands of chickens in a cage-free environment. 

2. Egg quality

 The Journal Poultry Science in 2011 [90, pp. 1586-1593] published “Comparison of shell bacteria from unwashed and washed table eggs harvested from caged laying hens and cage-free floor-housed laying hens.”  This study found that the numbers of bacteria on eggs was lower in housing systems that separated hens from manure and shavings. Conventional cages allow the feces to drop through the screen floor whereas in cage-free systems, the eggs are laid in the same general area for manure.  The potential for contamination is increased.

These results were confirmed in the Journal Food Control published a study June 17, 2014 entitled “Microbiological Contamination of Shell Eggs Produced in Conventional and Free-Range Housing Systems”  The conclusions state “Battery caged hens (conventional cages) are standing on wire slats that allow feces to fall to a manure collection system beneath the hens.  Conversely, free-range hens (cage-free) laid their eggs in nest boxes on shavings and the eggs remained in contact with hens, shavings and fecal material until they are collected.  The longer contact time with free-range hens, shavings and feces would explain the higher enterobacteriaceae counts (pathogenic bacteria) on free-range eggs as compared to battery caged eggs.”

3. Worker safety

The results of the study by the Coalition for Sustainable Egg Supply, farm workers in cage-free egg systems were exposed to more particulate matter and more endotoxins resulting in an environment that could impair lung health.  Worker ergonomics were more compromised in a cage-free egg system.

4. Egg cost

The Coalition for Sustainable Egg Supply has shown that eggs produced in conventional cages cost less in a) feed cost, b) pullet cost, c) labor cost, d) capital cost, e) operating cost.

Letters to the Editor Des Moines Register:  In the October 14^th issue of the Des Moines Register is an excoriating attack on Iowa lawmakers and Governor Terry Branstad in “Our Misplaced Priorities” by Rekhu Basu.  

http://www.desmoinesregister.com/story/opinion/columnists/rekha-basu/2014/10/15/misplaced-priorities/17283547/

She used the 2010 Salmonella outbreak attributed to Wright County Eggs as her platform, but no Iowa lawmakers or any state or federal agency condoned the mismanagement by Jack and Peter DeCoster at that Congressional hearing in 2010.  I was there at that hearing.  Was Ms. Basu there?  Her criticism was also leveled at the Governor for participating with 5 other state Attorneys General in challenging the California egg law restricting the interstate commerce of eggs.  Governor Branstad is to be commended for his leadership.  Too often political leaders lead from behind after reading the polls.  Governor Branstad, a true leader, showed he leads in the front by knowing the issue and the science behind Iowa’s egg production standards.

Ms. Basu wants Iowa to be “championing its commitment to a clean environment and the health of its residents.”  The Iowa egg industry is already doing that in following the FDA’s food safety standards [21 CFR Part 118].  Interestingly, those federal standards say states may not require “standards of quality condition that are different from or in addition to federal requirements.”  Certainly in Ms. Basu’s defense of the California standards [Title 3 Section 1350] are “in addition to.” Governor Branstad was championing the federal standards in support of the Iowa egg industry.

So, what are the facts behind the eggs produced in Iowa for which Governor Branstad supports.  Chickens in Iowa’s conventional cages produce more eggs, larger eggs, better grade eggs, and waste less feed than chickens running loose on the farm ¹.  Moving from an Iowa conventional cage to a non-cage system increases the likelihood of microbiological contamination of internal contents with Salmonella enterica serovar Enteritidis or other pathogens, or chemical contamination with dioxins in the soil, pesticides, or heavy metals ².  Eggs from caged facilities have a 25 per cent smaller carbon footprint (2.2 kg of carbon equivalent per kilo of eggs compared to 2.75 kg of CO₂e per kilo of eggs for free-range ³. The Coalition for Sustainable Egg Supply, a group of animal welfare specialists in the United States who know and understand poultry production,  recently reviewed 5 areas related to housing hens in addition to the welfare of the chicken and made observations for conventional cages, enriched cages, or aviary (cage-free) systems ⁴.  Those areas are; 1) health and welfare, 2) environmental impact, 3) economics, 4) food safety, 5) worker health and safety.

1.                   Health, well-being
Hens in the aviary and enriched systems had a higher incidence of keel bone deviations and/or fractures than hens in the conventional system.

2.                   Environmental impact
Regarding indoor air quality, the daily mean ammonia concentrations were less than 15 parts per million in both conventional and enriched cage houses throughout the monitoring period, but higher ammonia concentrations in the aviary house exceeded 25 ppm. Further, particulate matter (PM) concentrations in the aviary house were roughly 8-10 times those in the conventional system.

3.                   Economics

Farm costs for eggs were highest for eggs produced in the aviary system, followed by those from enriched housing and then conventional housing. In total it was 36% more expensive to produce eggs in the aviary system than the conventional system, while the enriched system was 13% more expensive than conventional cages. 

4.       Food safety

The forage area of the aviary system and scratch pads of the enriched colonies had the highest levels of total aerobes and coliforms, while eggs from the aviary floor had the highest total aerobes and coliform levels. 

5.       Worker health, safety

Sampling from personal exposure monitors worn by workers while in the hen houses found that inhalable particle and PM 2.5 concentrations, as well as endotoxins, were significantly higher in the aviary system compared to those in the conventional and enriched systems, which were not statistically different from each other. Worker ergonomics were also considered, with a number of tasks standing out as possible risks. Gathering the eggs birds had laid on the floor in the aviary system was found to be another issue for worker ergonomics as it warranted extreme body positions, including squatting for an extended period of time. Crawling and lying on the floor to collect floor eggs also exposed employees to potential respiratory hazards.

References

¹ Anderson, Kenneth, NC State University, 2010

² Holt, Peter, USDA/ARS Egg Safety and Quality Research Unit, Athens, GA

³ de Boer, Impke, Wageningen University, Netherlands, 2010

⁴ www2.sustainableeggcoalition.org.