It is likely many will applaud the new Chapter 10 rules for California Title 3 “The Regulation on Animal Confinement”, but National Egg Farmers on June 2, 2021 submitted official comments to state officials demonstrating that implementing the new rule will have the opposite of its intended effect by jeopardizing human health, worker safety, climate change, and with less humane conditions for chickens. National Egg Farmers urged the California Department of Food and Agriculture to recognize its understanding of animal husbandry and its support of the California Health and Safety Code to correct this proposed action by urging the legislature to amend the law and allow the continued use of conventional cages for egg laying chickens. (http://www.cdfa.ca.gov/ahfss/pdfs/regulations/AnimalConfinement1stNoticePropReg_05252021.pdf

Below is a partial of National Egg Farmers’ comments [outlined (a) through (d)]:

(a)   Human Health Concerns Jeopardized by CDFA Proposal:

The attention focused on cage-free eggs in the news has spawned a spate of backyard poultry flocks with concerns being expressed for years by the Centers for Disease Control & Prevention (CDC) of contamination with the pathogen Salmonella by this hobby or enterprise producing eggs.

In 2021 the CDC reported 163 people became ill in 43 states most likely from their backyard poultry. https://www.cdc.gov/salmonella/backyardpoultry-05-21/index.html

In 2020 over 1,700 people were sickened – https://www.cdc.gov/salmonella/backyardpoultry-05-20/index.html.

In 2019 over 1,100 people were sickened – https://www.cdc.gov/salmonella/backyardpoultry-05-19/index.html.

In 2018, over 340 people were sickened – https://www.cdc.gov/salmonella/backyard-flocks-06-18/index.html.

In 2017 over 1100 people were sickened – https://www.cdc.gov/salmonella/live-poultry-06-17/index.html.

(b)   Food safety concerns resulting from CDFA proposal.

The US Animal Health Association October 17, 2017 Report stated: “Ascarids (round worms) are increasingly being found in cage-free operations with the concern being the possibility of a consumer finding an egg with a roundworm contained inside. Most all cage-free egg producers have had such an occurrence.” Chickens pick up roundworms when they come into contact with infected feces on the ground. 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 show why cages became the preferred method of producing safer eggs: “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 on free-range eggs as compared to battery caged eggs.”

(c)   Worker Safety affected by the CDFA proposal.

The proposed action by the CDFA claims benefits to human health, worker safety, or the State’s environment. When CDFA says this proposal does not directly impact human health and welfare of California residents, worker safety, or the State’s environment, it is in error. A study conducted by the Coalition for Sustainable Egg Supply reported that the cage-free system had dust levels 8-10 times higher than other systems such as conventional cages. In addition, the cage-free system resulted in high worker exposure to endotoxin dust particles and reduced lung function by the end of a shift.

(d)  CDFA Proposal Conflicts with Biden’s Efforts to Curb Climate Change

President Joe Biden recently released his full budget request for fiscal 2022, detailing his plans to ramp up spending at the US Department of Agriculture for climate research and agricultural adaptation while also increasing spending for environmental regulation at the Environmental Protection Agency and Interior Department. The budget includes both President Biden’s annual spending requests for departments and agencies as well as the sweeping, longer-term proposals under his American Jobs Plan and American Families Plan to address climate change, build roads and other infrastructure and reduce economic inequality. The $29.9 billion in budget authority that Biden is requesting for FY22 at USDA includes $914 million earmarked for climate research and resilience programs as well as clean energy.

The California Title 3 proposal reportedly does not conflict with any “Comparable Federal Regulations/Mandated by Federal Law or Regulations”. Will CDFA modify the enacted California Title 3 on animal confinement to be in alignment with the Biden Administration’s efforts on climate change with climate-smart agriculture?  Producing eggs in conventional egg systems (cages) generates less ammonia and particulate matter (PM _2.5 and PM ₁₀) than cage-free systems such as proposed by California Title 3.  Manure belt conventional cages had a mean average for all the collections taken at 0.00012 lb./hen/day compared to aviary (cage-free) at 0.00049 lb./hen/day (4 times more ammonia in cage-free compared to conventional manure belt removal).  PM_2.5 for conventional manure belt systems was 2.8 mg/hen/day compared to cage-free aviary at 12.3 (again more than 4 times more in cage-free) and PM₁₀ for conventional manure belt systems was 20.3 mg/hen/hen compared to 124.4 for cage-free (more than 6 times for cage-free). 

Below are two news updates concerning cage-free production practices.  One is a new video an egg farm being challenged on the humaneness of cage-free, and the other is a short recap of a paper presented at the Egg Industry Forum last week noting the problems with perches damaging the keel bone of layers.  Egg farmers searching for compromises with the animal rights community are again handed disappointments while those of us continuing to support conventional cages are being vindicated for opposing any compromise.

A New Video Claiming Inhumane Conditions at Egg Farm

The animal rights group Direct Action Everywhere (DxE) who has challenged the humaneness of cage-free egg production, has circulated a video that challenges the humane conditions of cage-free layers at a Morning Fresh Farms facility in Platteville, CO.  They produce eggs to be sold at Sprouts Farmers Markets (headquarters in Phoenix), known for their organic and natural products.

The video is claimed to have been filmed at the farm location in Platteville, Colorado, over the course of nine months, according to a Phoenix Business Journal report.

Sprouts issued a statement in response to the video which states in part “Animal welfare is of utmost importance to Sprouts. All of our egg suppliers are required to meet or exceed USDA Food Safety and Inspection Services Standards, and any cage-free supplier must also meet or exceed animal welfare standards such as Certified Humane certification criteria outlined by Humane Farm Animal Care, among other nationally recognized programs. The Morning Fresh Farms’ Platteville, Colo. farm supplies Certified Humane cage-free eggs under the brand names Rocky Mountain Eggs and Egg-Land’s Best only to our Colorado and New Mexico stores.”

Perches for Layers Leads to Bone Damage

A new research study shows the majority of keel bone damage originates from collisions with perches inside the layer house. Dr. Maja Makagon, assistant professor of applied animal behavior at University of California, Davis’ Department of Animal Science, discussed the results of a study conducted to analyze keel bone damage in a layer environment. Makagon, who spoke on April 19 at the Egg Industry Center Egg Industry Issues Forum in Columbus, Ohio, said the study utilized accelerometers and 3D imaging technology to study the force of the collisions and measure their effects on the keel bone.

The keel is an extension of the sternum that provides an anchor for the bird’s wing muscles and provides leverage for flight. As laying hens are being removed from a conventional cage environment, Makagon said, keel integrity is increasingly seen as an indicator of animal welfare. Damaged keels are associated with increased mortality, reduced egg production and egg quality, and keel damage is likely associated with pain for the animal.

Watt Publishing released the following story from the Midwest Poultry Federation Convention in St. Paul, MN March 16-18 on the cage-free issue where Ken Klippen, NAEF and John Brunnquell, Egg Innovations debated the forced transition to cage-free eggs.

A pair of speakers argued for and against expanding production of cage-free eggs at the Midwest Poultry Federation Convention in St. Paul, Minnesota.

A pair of polar opposites agreed about one thing on a forum about the future of cage-free egg production: the market, not the egg producers, will set the course for cage-free eggs in the U.S.

Ken Klippen, executive director of the National Association of Egg Farmers and John Brunnquell, president of Indiana-based free-range egg producer Egg Innovations argued their case for and against expanding cage-free production at a workshop at the Midwest Poultry Federation Convention. The March 17 session in St. Paul, Minnesota, drew a standing room-only crowd.

The speakers agreed that the egg industry reached a tipping point in September when McDonald’s Corp. announced its commitment to only purchase cage-free eggs in the U.S. and Canada within 10 years. Since then, more restaurants and grocers have made their own cage-free pledges. The wave of demand for cage-free eggs is pressuring egg farmers to rethink their production processes or risk losing a market for their product.

The case against cage-free eggs

Klippen argued expanding cage-free production – the forced move to cage-free, as he called it – is bad for the consumer as well as the producer and could represent an existential threat to the industry itself.

Referencing recent comments from animal welfare activists, he said the move toward cage free is just “yardage” toward the groups’ ultimate goal of dismantling the egg industry entirely. The activists have succeeded in getting the biggest food retailers to make cage-free pledges, now they are fighting to bring food production companies and eventually the farms themselves to make similar pledges, he said.

Cage-free eggs, Klippen said, will represent a health risk to the birds, the workers in the houses and potentially the consumer. He said removing layers from cages, where they have been for decades, will lead to issues with pecking and other social behaviors prevented by a cage environment which, he said, is inhumane. The eggs are more likely to be contaminated with bacteria due to prolonged exposure from litter and manure in the nest boxes. As for the workers, Klippen said the amount of dust, which can transmit pathogens, inside a cage-free house represents a health risk to farm workers, and the need for workers to collect floor eggs creates ergonomic challenges, too.

The cost of the transition to cage free is also problematic, Klippen said. More resources – feed, labor and money – are necessary to produce the same amount of eggs as conventional systems. Eggs from aviaries will cost as much as 37 percent more than conventionally raised eggs.

Klippen vowed that his group will “never surrender” in its fight against forced expansion of cage-free production. He said the consumers, the market the egg industry serves, deserve to have a choice, rather than being forced to pay higher prices for cage-free eggs.

The case for cage-free eggs

Brunnquell vehemently disagreed with Klippen’s argument that cage-free eggs are less safe for consumers and cruel to animals. Taking the animals out of the cages allows the birds to exhibit more of their natural behaviors and, in the case of free range, gives hens an environment closer to their ancestral biome.

As for the cost issue, Brunnquell couldn’t speak for transitioning from cages to cage-free, but he said starting up a free-range operation can cost as much as $800,000.

Beyond animal welfare and health issues, Brunnquell said he and Klippen are in agreement that the egg industry should let the market determine its path. However, Brunnquell thinks egg producers need to pay attention to what the market’s future, the millennial generation, wants.

He said the under-35 demographic is quickly becoming the most important consumer group, and the group’s values will reflect heavily on its future buying decisions. The group is distrustful of “big food” and wants to know more about where its food is coming from. Most importantly, they are willing to pay a premium price in order to act on their values. As many as 83 percent of millennials, he said, are specialty egg customers, and research shows they are willing to put taste, animal welfare and additive-free production ahead of pricing.

Brunnquell said free-range farming is not perfect, it’s a management challenge, and poorly managed operations can underperform, but the market is trending toward more demand for specialty eggs.

“This has nothing to do with the egg industry. This generation is going to have the same thoughts and value statements across all their shopping habits. (Millennials are) the real consumers that are driving change,” Brunnquell said. “Where we end up in the discussion of cage-free I don’t think is for us to debate. I think we have to respond to the marketplace: If the marketplace wants it, we should be there for them. If the marketplace doesn’t want it, we shouldn’t be there.”