LocalHarvest Newsletter, September 20, 2013
Welcome back to the LocalHarvest newsletter.
This month and next we are devoting this space to two important sets of regulations that, if implemented as written, would seriously undermine the integrity of organic food and the viability of small scale vegetable and fruit production. It is one of those times when people who care about good food need to make our voices heard — because what's at stake is important, and because some of what is being proposed just plain defies reason.
Today's concern is the new FDA's proposed guidelines for organic egg producers. One cornerstone of the existing organic law regarding egg production is that chickens must have access to the outdoors — you know, grass and sun, dirt and bugs. Stuff chickens like. Under the new FDA guidelines, organic egg producers could forego actual chicken yards in favor of enclosed porches attached to the henhouse. But the porches don't need to be big enough for all, or even most, of the chickens to use at once. Allowing some hens to crane their necks and see the great outdoors from their confinement does not uphold the spirit of the existing laws governing organic.
Our concern here is that the guidelines give large-scale egg facilities the green light to tack on a little porch to the outside of the poultry house, close down the chicken yard, and continue to call their eggs "organic". In fact, this already happens. According to The Cornucopia Institute, giant organic egg operations are currently housing 100,000 birds in a building equipped with a porch so small that only 1-3% of the birds can elbow their way out there. The USDA, the agency charged with enforcing organic law, is already being threatened with lawsuits for failing to enforce the outdoor access rule. With these new Salmonella guidelines, the FDA is essentially building a backdoor for the USDA to get out of enforcing this rule, thereby undermining both the spirit of the organic law and the efforts of those egg producers who take on the extra work of letting their birds roam outside.
The goal of the FDA's proposed guidelines is to reduce exposure to Salmonella. This is a worthy goal, without question, but scientific studies have demonstrated that eggs raised in systems providing true outdoor access for the birds have lower incidences of Salmonella than do those of confined birds. For more on this point, I recommend reading The Cornucopia Institute's evaluation of the scientific literature.
I mentioned above that aspects of the proposed guidelines fly in the face of reason. Here comes that part. One way that the FDA is attempting to limit exposure to Salmonella is by directing farmers to limit the hens' exposure to wild birds and other wildlife. Never mind that the science doesn't demonstrate a significantly lessened risk ofSalmonella among hens kept away from other birds — though that does seem relevant. But let's picture it for a minute. We're egg farmers. We're organically certified, so we have a nice yard where the birds spend a good deal of the day sunning themselves, scratching around, pestering one another — being chickens! Wild birds fly overhead. Sometimes they land on the fence and once in a while they light in the yard. If we follow the proposed guidelines, we'll have to keep the birds away. How will we do it? The FDA suggests several methods, including putting bird netting or a roof over the entire chicken yard. This would be costly and a maintenance nightmare. The FDA's second suggestion is to use noise cannons. These emit an "almost sonic level" sound every minute or so, according to one cannon manufacturer. The cannons would no doubt frighten away the wild birds. Trouble is, they are also going to scare the chickens, and scared chickens don't lay eggs.
If organic farmers are required to keep wild birds away from their hens, having the birds outside is going to be extremely difficult, if not impossible. Kind of makes the enclosed porch seem like a good idea, doesn't it? …except that common sense and the science both say that hens are actually healthier and their eggs have fewer incidents of Salmonella when they are allowed to roam around outside.
At LocalHarvest we feel that there is a significant difference between eggs laid by chickens who spend time in the sun and those from chickens who don't. If these federal agencies either fail to enforce the National Organic Standards or throw up roadblocks to their implementation, the "organic" label will not allow consumers to tell the difference.
We have to wonder if that isn't the point.
Just today a journalist writing about the local food movement asked me if I think there will be a point when small scale agriculture threatens large scale ag enough to result in some push back. I said, "That day is here!" and told him this story as an example. It isn't the small scale organic egg producers asking for work-arounds to the outdoor access rule.
The FDA's official comment period for this issue closes this Monday, September 23. We are hoping you will take a few minutes to weigh in with them before then, though it would still be worth doing even after the 23rd. You can do so directly here or through The Cornucopia Institute. They have done a lot of good work on this issue and have a proxy letter you can sign that they will hand deliver to the FDA.
Thank you for your attention to this issue. We'd love to hear what you think about it.
Until next time, take good care and eat well.
Erin
Erin Barnett
Director
LocalHarvest
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