International Standards for Animal Welfare

In the July 9th issue of Agri-Pulse was an article about Dr. Craig Morris, AMS/USDA,  leading the U.S. delegation to the International Standardization Organization (ISO) toward developing a voluntary set of standards on animal welfare.  The National Association of Egg Farmers (NAEF) saw the potential dangers from those who want to mandate colony cages for egg laying chickens.  NAEF expressed concern to the U.S. Delegation leaders that the ISO may be a renewed effort to standardize the U.S. egg industry into enhanced colony cages. 

 Dr. Craig was quoted in a recent issue of Agri-Pulse  “….the food industry isn't looking for changes in the way we treat, transport or slaughter food-producing animals in the U.S.”  The National Association of Egg Farmers wrote to Dr. Craig supporting his position statement while underscoring the fact the egg farmers are producing safe and wholesome eggs that are scientifically-supportive of the hen’s welfare.

NAEF reminded Dr. Craig that the DC-Barnyard (AFBF, National Pork Producers, National Cattlemen, National Chicken, National Turkey and the National Association of Egg Farmers) just recently were successful in defeating a similar attempt to change the U.S. egg industry into one national federal standard for egg production through a national egg bill.  For us it would actually have led to the smaller egg farmers throughout the country actually going out of business. Whereas the larger egg complexes could gradually make the transition over a 15-year period, the smaller egg farmers would not be able to because of the egg processing capabilities on those smaller farms. Those smaller egg farmers would be forced to make the conversion in one step leading to an economic disadvantage leading to insolvency for them. 

Any implied claims of increasing space for egg-producing chickens leads to better welfare is incorrect. Consider the facts.  The American Veterinary Medical Association (AVMA) in 2010 released a report on the welfare implications of various kinds of housing. (www.avma.org/issues/animal_welfare/cage_noncage_systems.asp) The report concluded consumers need to balance the hen’s freedom against exposure to potential hazards such as disease vectors and the cannibalism caused by pecking. Certainly cannibalism and pecking are welfare issues, and in conventional cages where the number of chickens is minimized, these concerns are also reduced compared to other systems. Dr. Kenneth Anderson, NC State University, presented his research findings to delegates at the 2010 Midwest Poultry Federation Convention March 16-18, 2010 where he noted that chickens reared in conventional cages had significantly greater numbers of Grade A eggs, significantly greater numbers of total eggs produced, and significantly better feed conversion rates (meaning a lower carbon footprint), and a better immune response (meaning better able to resist disease).  Certainly these are indicators of a healthier chicken and thus better welfare.

Recent research funded by the USPOULTRY and the USPOULTRY Foundation announced on June 6, 2014 the completion of a funded research project at Michigan State University in East Lansing, MI, which examined the impact of stocking density on enriched colony cages. This study shows a minimal impact on welfare in a comparison between 72 sq. in. per bird and 144 sq. in. per bird.  Project #670: Enriched Colony Cages: Stocking Density on Laying Hen Well-being - Dr. Darrin Karcher and Dr. Maja Makagon at Michigan State University studied the impact of stocking density on egg production and the well-being of laying hens in enriched colony cages. The researchers found minimal differences in measures of production and well-being at the various stocking densities, from 464 cm2 (72 sq. in)  to 929 cm2 (144 sq. in.) per bird during the period of 17 to 69 weeks of age.

The National Association of Egg Farmers urges the U.S. delegation to the ISO please consider the supporting science provided here coupled with the mistakes inherent in the European Union egg law (EU Council Directive 1999/74/ED).  The article from Farming UK (see website below) demonstrates the suffering resulting in Europe as a result of implementing one national standard for egg production on January 1, 2012.  The Germans moved even quicker than the whole of the European Union and implemented a new national law in 2010.  


The article quotes an international economist who predicts that 30% of the German egg farmers will likely become insolvent by October.

NAEF expressed confidence that Dr. Craig will vanguard the interests of egg farmers nationwide in the ISO discussions, and not succumb to the EU or any others who press for enhanced colony cages that do not manifest welfare benefits to the egg-producing chicken.  


Ag Secretary Asked to Confirm Safety of EU Egg Products by NAEF

June 30, 2014


The Honorable Tom Vilsack


U.S. Department of Agriculture

1400 Independence Ave., SW

Washington, DC  20250


Dear Mr. Secretary:


The National Association of Egg Farmers, representing egg farmers coast-to-coast, applauds your recent efforts toward expanding on trade negotiations with the European Union. During these negotiations we read with interest in CQ Roll Call your comments that it was “very important for us to convey the message that we have a common goal of expanding markets and a common language when it comes to resolving these issues, and that language is science.”  We agree and support the continued efforts to use “science” in making decisions concerning foods we produce, export or import.

We know that FSIS is currently inspecting EU egg products facilities to determine equivalency under the Egg Products Inspection Act 9 CFR Part 590NAEF wrote to Philip Derfler, Deputy Administrator of the FSIS seeking assurances that equivalency with the U.S. standards as specified in the EPIA are maintained before granting export authority by any foreign facility to the U.S..


We are asking for your assurances that, in addition to equivalency, that geographical preferences do not compromise food safety for U.S. consumers.  For example, the website shown below confirms that some EU egg products facilities adds food dyes to enhance the color of egg yolks in addition to meat as preferred by EU consumers.  There is one food dye in use in the EU that is a cause for concern from a food safety perspective. The European Food Safety Authority reports the food dye known as Red 2G and is found in sausages and beef burgers to maintain a red color may be carcinogenic.  This food color additive is banned in the U.S., Canada and Australia.



In the UK, the preference is for a darker egg yolk and this is accomplished by pigmented feed with food dyes as noted in this website



The EU practice of dying the egg yolks a deeper color is compounded by the concern for Dioxin. When poultry are subjected to soils contaminated with this cancer-causing substance in the soil is may occur in the eggs produced.  Free-range poultry and the eggs from these chickens are more prevalent in the EU than in the U.S. adding another layer of concern from Dioxin-contamination.


The NAEF is asking you to give us your assurance that no adulterated foods imported from other countries including egg products that may come from chickens fed a pigmented feed with artificial dyes or raised in free-range environments unless that environment is tested for Dioxin.


Thank you.





Kenneth Klippen



NAEF Objects to Trade Deals Beyond EPIA Requirements

On June 16, 2014 USDA Secretary Vilsack was meeting with the EU Agriculture Ministers over trade issues, word was circulating in the egg products industry that certain egg products plants in the EU were being considered for import privileges to the U.S.  NAEF addressed the issue by voicing its objections with the Deputy Administrator at the Food Safety Inspection Service and citing current regulation.  NAEF noted that since all egg products sold for human food in the U.S. operate under the Egg Products Inspection Act 9 CFR Part 590 (EPIA), NAEF asked the Administrator to please confirm that no egg products are being imported aside from these requirements. NAEF also asked for confirmation that the FSIS is not exploring the feasibility of granting egg product import approval from EU egg products facilities.  While these EU facilities are state-of-the-art in processing technology, NAEF subscribes that the eggs being processed must still be handled consistent with 9 CFR Part 590.  For example§ 590.50 Temperature and labeling requirements (a) No shell egg handler shall possess any shell eggs that are packed into containers destined for the ultimate consumer unless they are stored and transported under refrigeration at an ambient temperature of no greater than 45 °F (7.2 °C).  Eggs processed in the EU are not temperature regulated consistent with this requirement.  Furthermore, many EU egg products plants are not operating consistent with § 590.24 Egg products plants requiring continuous inspection. No plant in which egg products processing operations are conducted shall process egg products without continuous inspection under these regulations, except as expressly exempted in § 590.100. While § 590.100 provides for specific exemptions, they are exempt to the extent prescribed as to the provision for continuous inspection of processing operations in section 5(a) of the Act: Provided, That the conditions for exemption and provisions of these regulations are met: (b) Subject to the approval of the Administrator. 

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