Deadline for Reporting Ammonia and Hydrogen Sulfide-Report to EPA

On Friday, January 19, 2018 EPA posted on their website (after the conference call with farm leaders saying they expected the emissions requirement to go forward) the following statement:On Friday, January 19, 2018, EPA filed a motion with the D.C. Circuit Court of Appeals to further delay issuance of the mandate. No reporting is required until the Court issues its order, or mandate, enforcing its decision to eliminate the reporting exemptions for farms. 



Deadlines on reporting air emissions to EPA kept changing through 2017 and into 2018.  The latest deadline is now January 22, 2018. EPA has simplified the reporting (see How To Report to EPA Ammonia Emissions from Farms).

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. 


 How to Report to EPA Ammonia Emissions from Farms


  • Notify the National Response Center. This may be done by email ( This email address is being protected from spambots. You need JavaScript enabled to view it. ). Please identify your reportable release as an “initial continuous release notification.” 
  • Submit an initial written notification to the EPA Regional Office; and
  • One year later submit an additional follow-up written notification to the EPA Regional Office.



 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


Egg Farmers Rebuttal to NPR on Organic Poultry having access Outdoors

Egg Farmers Rebuttal to NPR on Organic Poultry having access Outdoors

This is in response to the January 11th article in NPR MarketPlace "An Animal Welfare Rule Aimed at Organic Egg Production is on the Chopping Block." We trust that NPR MarketPlace intends to provide both sides of the debate from people knowledgeable in poultry welfare and will therefore print our rebuttal to the claims that outdoor access for poultry improves animal welfare. It does not when considering the possibility of spreading poultry diseases.

When the National Association of Egg Farmers who represent approximately 200 egg farmers nationwide filed their comments, they expressed appreciation that the purpose of the Organic Foods Production Act of 1990 (OFPA) (7 U.S.C. 6501-6522) is to assure consumers that organically produced products meet a consistent and uniform standard (7 U.S.C. 6501), but we questioned the subjective nature of some of the proposed amendments pertaining to egg laying chickens without the benefit of practical science.

Outdoor access was one proposal that would not contribute to better poultry welfare because it can subject chickens to poultry diseases such as highly pathogenic avian influenza. This is recognized by the US Department of Agriculture Animal & Plant Health Inspection Service noting that chickens outdoors should not have contact with migratory waterfowl. ( Migratory birds, through fecal contamination, can fly over a flock of outdoor chickens and contaminate them. One teaspoon of avian influenza infected manure dropped among outdoor chickens has the potential to contaminate one million chickens. In 2015 the loss of chickens and turkeys from avian influenza cost the US economy more than $3 billion in dealing with the disease and increased egg costs to the consumer.

While we appreciate organic egg farmers reaching for greater consistency in organic livestock practices through specificity and clarity of certain organic feeds fed to organic poultry, outdoor access for poultry is not improved welfare with its potential to devastate once again the other egg farmers producing conventionally in cage systems for their customers.

(Article in NPR MarketPlace)


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.


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