Kraft Foods Urged to Re-Consider Cage-Free Policy

To the Board of Directors at Kraft Foods

On December 12, 2017 The National Association of Egg Farmers, representing egg farmers nationwide, respectfully urged Kraft Foods to reconsider its policy on sourcing eggs only from cage-free egg production flocks.  There are four reasons why farmers have evolved to producing eggs with chickens in cages.



1.Food Safety and Security


Food safety is paramount and refutes claims that cage-free improves egg safety. Penn State researchers have found that eggs from small flocks of chickens are more likely to be contaminated with Salmonella enteritidis as eggs sold in grocery stores, which typically come from larger flocks. The analysis of the Salmonella enteritidis present in the eggs from small flocks shows they are the same types commonly reported to the Centers for Disease Control and Prevention from human foodborne outbreaks.


  1. 2.Human Health and Welfare

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. 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.

  1. 3.Sustainable Egg Production Systems

The rush by retailers and food manufacturers to source their egg needs from cage-free facilities must consider these facts on sustainability.The cost to implement new barns for cage-free chickens needed is calculated at $45 per chicken.  For 200 million chickens producing for retailers demanding cage-free systems, that’s a capital investment of $9 billion. Cage-free egg production costs are determined to be 36% higher than conventional.

  1. 4.Animal Welfare and Husbandry

The Coalition for Sustainable Egg Supply reported at International Poultry Production and Processing Exposition in Atlanta, GA on January 26, 2016:

Total accumulated mortality was highest in the cage-free system (11.5 percent), due to aggressive pecking and cannibalism. It was 4.7 percent in conventional cages. This results from the hens establishing a pecking order among the chickens in a flock. Conventional cages reduces the size of this population and thus reduces the stress caused from pecking.

Keel bone breakage was highest in the cage-free system. Increased keel bone breakage was confirmed with New Research at the University of California-Davis. This new research study shows the majority of breast bone damage originates from collisions with perches in cage-free environments. Dr. Maja Makagon, assistant professor of applied animal behavior at University of California, Davis’ Department of Animal Science, noted the increased bone breakage in cage-free systems.



Deadline for Reporting Ammonia and Hydrogen Sulfide-Report to EPA is November 15, 2017

In the NAEF Egg Farmers Newsletter sent out Memorial Day (May 29) we reminded all members that the U.S. Court of Appeals for the D.C. Circuit has thrown out a 2008 final rule issued by the Environmental Protection Agency (EPA) exempting farms from reporting ammonia and hydrogen sulfide when above 100 pounds.


All members have been provided a spreadsheet from the Egg Industry Center at Iowa State University that will help you determine your emissions based on your housing style.  In the Memorial Day release of the newsletter, we provided you the phone number of the National Response Center (NRC). Today is the final day to report to the NRC what the spreadsheet has calculated as to your emissions.


Why is this happening now?  During rulemaking, the EPA proposed exempting farms from CERCLA and EPCRA reporting air releases from animal waste.  “CERCLA” stands for Comprehensive Environmental Response, Compensation, and Liability Act and “EPCRA” for the Emergency Planning and Community Right-to-Know Act.


The EPA reasoned that requiring reports for animal waste air releases was “unnecessary” because a federal response would usually be “impractical and unlikely.”  They noted that, as of 2007, they had never taken a response action based on animal waste.  During public comment, the EPA expressly requested comments on whether there could be a situation where a response would be triggered due to air release from animal waste on a farm.

In 2008, the EPA finalized the rule.  Soon after the rule was published, the lawsuits started rolling in.  Environmental groups, led by Waterkeeper Alliance, argued that CERCLA and EPCRA do not allow the EPA to exempt anyone from reporting requirements if there are releases over the statutory reportable quantity.  Further, the environmental groups claim that the rule is arbitrary in treating waste on farms differently than similar waste in other places, such as at a zoo or a slaughterhouse, which would not be exempted from reporting.  


So now, under CERCLA and EPCRA farmers must notify the National Response Center (NRC) when amounts of certain hazardous materials over a set quantity of 100 pounds are released into the environment. Below is the telephone number.  NAEF called the NRC on May 25th and spoke to the Watch Commander (this is part of the U.S. Coast Guard). The NRC will provide a report number that is then submitted to the EPA in which you have 30 days to submit.


Telephone NRC: 1-800-424-8802 (or email at  This email address is being protected from spambots. You need JavaScript enabled to view it.  and indicate "initial continual release notification"

1) Identify your report as "Continuous Release"

2) Provide the name and location of the facility

3) Identify the hazardous substance (ammonia and hydrogen sulfide)

4) Give your name and telephone number

5) Within 30 days a written report is required to be filed



(b) State Emergency Response Commission (;source=gmail&ust=1496333767129000&usg=AFQjCNHJ2iPQt8_46CBQf5xOM7GScOojMw">

(c) Local Emergency Planning Committee (;source=gmail&ust=1496333767129000&usg=AFQjCNGXBbyda7WtGdRhRO9KnZQpSsTXhw">


For help in reporting see the following websites (the first one is an updated link for egg farmers to calculate the emissions based on your particular housing for hens and pullets. The other two are from EPA):;source=gmail&ust=1496333767129000&usg=AFQjCNHduPPNu4LRrJMlOSXvuHfppO3CTw">;source=gmail&ust=1496333767129000&usg=AFQjCNGSqsAJWHKSceECamJkXCKxMHWHpA">;source=gmail&ust=1496333767129000&usg=AFQjCNHlHGoNdvQVtacdEYhprYczrLVwPA"> release reporting


Support for HR 2887 "No Regulation without Representation"

The National Association of Egg Farmers sent an invitation on September 27th to the state poultry & egg associations listed below to join them in resisting the Humane Society of the United States in their second California ballot initiative effort by supporting Rep. Jim Sensenbrenner's bill HR 2887 "No Regulation without Represenation". Attached is the letter sent to the associations.

Alabama Poultry & Egg
Arkansas Poultry Federation
California Egg Farmers Association
California Poultry Federation
Connecticut Poultry Association
Delmarva Poultry Industry, Inc.
Florida Poultry Association
Georgia Poultry Federation
Illinois Poultry Industry Council
Indiana State Poultry Association
Iowa Poultry Association
Iowa Turkey Federation
Kansas Poultry Association
Kentucky Poultry Federation
Louisiana Egg Commission
Michigan Allied Poultry Industries, Inc.
Midwest Poultry Federation (Chicken and Egg Association of Minnesota)
Mississippi Poultry Association
Missouri Poultry Federation
Nebraska Poultry Industries
North Carolina Egg Association
North Carolina Poultry Federation, Inc.
Ohio Poultry Association
The Poultry Federation Oklahoma
Oregon (Pacific Northwest Poultry Council)
PennAg Industries Association Poultry Council
South Carolina Poultry Federation
Tennessee Egg and Poultry Association
Texas Poultry Federation
Virginia Egg Council
Virginia Poultry Federation
Wisconsin Poultry & Egg Industries Association

Letter sent:

We are reaching out to all state poultry & egg associations. Please help us in being proactive in stopping the Humane Society of the U.S.

We are writing you to urge support for Rep. Jim Sensenbrenner's bill HR 2887 "No Regulation without Representation" in hopes of ending the efforts of the Humane Society of the U.S. in establishing production standards for eggs layers and gestation sows, and eventually for all of animal agriculture. (Bill copied below). HSUS has already stated publicly this legislation is their number one target to defeat in Congress. The National Association of Egg Farmers has come out in support of the bill as we have seen how one ballot initiative in California is not enough for the activists.

Recently I debated with Wayne Pacelle, President of HSUS, on California Public Radio. Here's the audio tape showing our egg farmers are willing to fight this second ballot initiative in California.:

But we need more than simply defense against the activists. We need to go on the offense and that is what Rep. Sensenbrenner's bill will do. We urge you to contact your Representatives, especially those on the House Judiciary Committee, to get this bill through committee and on the Floor of the House of Representatives. After doing so, please let us know. Please help us do this for the sake of animal agriculture in the U.S.

Ken Klippen, President

H. R. 2887 To regulate certain State impositions on interstate commerce.
JUNE 12, 2017
Mr. SENSENBRENNER (for himself, Mr. GOODLATTE, Mr. DESJARLAIS, Mr. MCCLINTOCK, Mr. GROTHMAN, Mr. MEADOWS, Mr. CONAWAY, and Mr. TROTT) introduced the following bill; which was referred to the Committee on the Judiciary
To regulate certain State impositions on interstate commerce.

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