scrambled eggs: separating factory farm egg production from authentic organic agriculture

8/6/2019 Scrambled Eggs: Separating Factory Farm Egg Production from Authentic Organic Agriculture

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Scrambled EggsSeparating Factory Farm EggProduction from AuthenticOrganic Agriculture

A Report and Scorecard by The Cornucopia Institute


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2 Scrambled eggS: Separating actory arm egg production rom authentic organic agriculture

The ollowing sta members helped research, write, edit, and support this report and scorecard:

Charlotte Vallaeys, Farm and Food Policy Analyst, principal researcher and authorMark Kastel, Senior Farm and Food Policy Analyst, associate researcher/author and editorWill Fantle, Research DirectorLynn Christianson, Research AssistantJohn Peck, Farm and Food Policy Analyst

The ollowing provided proessional assistance:

Michana Buchman, copyeditingTim Hill, report layout/design, timhilldesign.comJeremy Vossman, Papertree Design, web design, papertreedesign.comAlex Turner, scorecard layout

The Cornucopia Institute is dedicated to the ght or economic justice or the amily-scale arming community. Throughresearch, advocacy, and economic development, our goal is to empower armers both politically and through marketplaceinitiatives.

The Organic Integrity Project acts as a corporate and governmental watchdog assuring that no compromises to the credibil-ity o organic arming methods and the ood it produces are made in the pursuit o prot. We will actively resist regulatoryrollbacks and the weakening o organic standards, to protect and maintain consumer condence in the organic ood label.

The Cornucopia InstituteP.O. Box 126Cornucopia, WI 54827608-625-2042 voice866-861-2214 [email protected]

Cover design by Tim Hill.Cover photos courtesy o The Cornucopia Institute, Alexandre Family Ecodairy Farms and Old Friends Farm.

Copyright 2010, The Cornucopia Institute


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the cornucopia inStitute 3

Table o Contents

Acknowledgments 4

executive summAry 5

introduction: the orgAnic egg industry 8

orgAnic egg Producers: three APProAches to orgAnic egg Production 10Pasture-BasedMobile Housing or Rotated Paddocks 10

Permanent HousingAdequate Outdoor Access 14

Industrial Organics 18

outdoor AccessA shell gAme 23

cornucoPiAs orgAnic egg scorecArd 25

mArket conditionsrotten eggs 26

deining reAl/legAl orgAnic egg Production 27Organic as dened by the United States Department o Agriculture 27

Organic dened by various USDA-accredited certiying agencies 28Organic Dened by the National Organic Standards Board 28

Organic dened by the International Federation o Organic Agriculture Movements (IFOAM) 29

Organic dened by USDAs National Institute o Food and Agriculture 30

industriAl-style egg Production And the growth o industriAl orgAnics 31No Yoke: Industrial Egg Production 31

The Conventional Egg Industry Today 34

The American Egg Board 35

Growth o Industrial Organics 36

Benets o Buying OrganicThe Gold Standard o Saety and Nutrition 39

the ight or AnimAl welAre stAndArds in orgAnics 40Outdoor Runs and Natural Behavior 41

industriAl orgAnics Arguments AgAinst outdoor sPAce 43Land issues/zoning 43

Loss to Predators 43

Avian Infuenza 44

Other Disease 45

Chickens dont like to go outside 46

Soil, Air and Water Quality 48

Food Saety (FDA Egg Rule) 48

Beak Trimming 50

Science to prevent pecking 51

AnimAl welAre lAbels 52

conclusion 54

APPendix A: legAl comPlAint 55

APPendix b: rAtings or the orgAnic egg scorecArd 59Organic Egg Scorecard Ratings 59

endnotes 65


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Acknowledgments

The Cornucopia Institute wishes to thank:

Blooming Prairie FoundationJessie Smith Noyes FoundationForrest and Frances Lattner FoundationWedge Community Co-op

And the thousands o amily armers, and their urban allies, who und our work with their generous donations.


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Ecologically minded armers have responded to this growingdemand or ethically produced ood, and organic armers arebringing laying hens back to the arm.

But while consumers expect the organic label to provide analternative to the industrialized ood system, paths are di-

verging in the organic-egg-producing community: One pathaords more outdoor access (oten on well-managed pas-ture), more diversity on the arm and allows the hens to ex-hibit their natural behavior outdoors; and another path hasled to large-scale industrialization motivated by prot.

All organic egg producers claim to be ollowing the ederalorganic standards, but with dierent working denitions andviewpoints o what the standards mean. For most consum-ers and many producers, organic arming means respectingunderlying principles o the organic arming movement,such as building soil ertility, maintaining ecological balance,promoting biodiversity, reducing dependence on o-arm in-

puts, recycling nutrients, and allowing livestock to displaytheir natural instinctive behaviors. For others, especiallyindustrial-scale producers, organic appears to be nothingmore than a protable marketing term that they apply to theagro-industrial production systemsimply substituting or-

ganic eed in their production model and eliminating harm-ul synthetic inputs, such as pesticides and antibiotics.

Since 2002, the use o the term organic on ood packaginghas been regulated by the United States Department o Agri-culture (USDA). Federal regulations determine which armsand processors qualiy as organic, and may use the ocialUSDA Organic seal on their ood packaging.

These standards include a requirement or outdoor accessor livestock, including laying hens; unortunately, our re-

search ound that most industrial-scale producers are cur-rently conning tens o thousands o hens inside henhouses,commonly only oering tiny concrete or wooden porches asoutdoor accessand getting away with it. In some casestheyve used statements rom veterinarians concerning hy-pothetical disease transmission as an excuse to oer no out-door access whatsoever.

Outdoor access or laying hens is important or many reasons.When the National Organic Standards Boards LivestockCommittee rst recommended meaningul outdoor accessor laying hens, they specied that the intent o outdoor runswas to satisy [the chickens] natural behavior patterns, pro-

vide adequate exercise area, provide preventive health carebenets and answer consumer expectations o organic live-stock management.1

This questionwhether legal organic egg production re-quires meaningul outdoor access or hens, on vegetatedoutdoor runs or rotated pastureis currently a topic o de-bate beore the National Organic Standards Board (NOSB),the expert citizen panel that meets biannually to advise theSecretary o Agriculture on organic policy, rulemaking andenorcement.

Although the NOSB already issued a recommendation in

2002 (never adopted as regulation by the USDA), statingthat organic egg producers must provide vegetated outdoorruns and that porches do not meet the intent o the organicrule, the issue resuraced in 2009 when the NOSBs Live-stock Committee included similar language in a set o recom-

Executive Summary

ConsumersareinCreasinglyinterested in knowing the story behind their oodespecially when ood pro-

duction involves animals that are oten treated by our industrialized ood system as units o production

rather than as living beings. Organic consumers are also looking or an alternative to the industrial ood

systemthey desire a ood system that treats the environment, amily armers and animals with respect.

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mendations aimed at strengthening animal welare in organicood production. The proposed recommendations would alsorequire a minimum amount o square ootage o indoor andoutdoor space per laying hen. The exact number has yet tobe decided, and is a topic o contentious debate.

In response to the proposed language that would enorceproper outdoor access or laying hens, industrial-scale pro-ducers traveled to the spring 2010 NOSB meetings, alongwith their trade group lobbyist rom the United Egg Produc-ers, to publicly oppose requirements or meaningul outdooraccess. Bart Slaugh, director o quality assurance at EgglandsBest, commented: The push or continually expanding out-door access needs to stop, and I believe that the proposedstandards have gone too ar.2

These industrial-scale egg producers apparently do not cur-rently provide enough outdoor access or all their birds to en-joy vegetated outdoor space; rather, their birds are essentiallyconned in henhouses with as many as 85,000 hens (suchas Herbrucks Poultry Ranchs Organic acility in Michigan,with a total o 340,000 birds). And unlike most amily-scaleorganic egg producers, they appear completely unwilling tomake any changes to their production system to accommo-date stricter animal welare standards.

A handul o industrial-scale producers argue that the organ-ic egg industry would collapse i they were required to grantoutdoor access. However, there are hundreds o amily arm-

ers producing organic eggs who do grant meaningul outdooraccess to their hens. Three production models are commonin the organic egg industry: pasture-based production; xedhousing aording minimal but adequate outdoor space; andthe industrial model. Because o their size, industrial-scaleproducers are undoubtedly marketing the majority o organiceggs, but they are by no means representative o the majorityo organic egg producers.

On pasture-based organic arms, focks o laying hens arehoused in either xed houses surrounded by pasture or mo-bile chicken coops rotated in the pasture itsel. The birds areallowed to roam reelyso the chickens are never on the

same section o pasture or very longor the outdoor spaceis large enough so it is not quickly reduced to dirt and mudby the chickens. Chickens can exhibit their natural behavioron pasture, such as oraging and scratching, and can exerciseby running around and fapping their wings and receive some

percentage o their rations rom resh grass, earthworms,seeds and insects.

Many amily-scale organic egg producers do not oer man-aged pasture, but do oer enough outdoor space or all theirhens to be outside at the same time. These outdoor runs tendto consist o dirt and mud close to the henhouse, and grasses

and weeds urther rom the house. Henhouses in this catego-ry will generally hold between 1,000 and 20,000 birds, wherehens live on the foorno cageswith nest boxes, perchesand litter. These producers generally sell their eggs througharmer-owned cooperatives or companies that market theireggs under national or regional brand names.

According to industrial-scale egg producers, their model oorganic egg production produces 80% o the organic eggs onthe market. There are, however, only a handul o companiesthat ollow the industrial model. These producers sometimeshouse as many as hundreds o thousands o birds on organicarms, using aviary systems that are described by one or-

ganic producer as gloried cages. Concrete porches thatare accessible to only a small percentage o the birds pass asoutdoor access, and sometimes the certiying agent evengrants a permanent exemption rom going outside.

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The Cornucopia Institute believes that these producers arein violation o the organic standards, and our organizationhas led several ormal legal complaints.

I industrial-scale producers manage to convince the NOSBto scratch strong animal welare requirements or layinghens, it would give them the green light or construction oadditional huge, double-story henhouses without outdooraccess, which would economically disadvantage producersthat do currently ollow the spirit and letter o the organicrule. This will likely orce many o the amily-scale organicarmers out o business.

Meanwhile, consumers and wholesale buyers can use TheCornucopia Institutes newly developed Organic Egg Score-card to guide their purchasing decisions in the marketplace.The Organic Egg Scorecard rates organic egg brands basedon criteria that are important to organic consumers, suchas legal and legitimate outdoor access, and adherence to or-ganic principles such as arm diversity and nutrient cycling.Consumers are encouraged to purchase ethically produced

and highly rated brands in avor o those with a low rating.The Organic Egg Scorecard is available on the Cornucopiawebsite, along with this report and other related materials(www.cornucopia.org).

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But while the organic label is commonly viewed as providingan alternative to the industrialized ood system, paths are di-verging in the organic-egg-producing community: one pathtoward more outdoor access, more diversity on the arm andallowing hens to exhibit their natural behavior; the otherpath is simultaneously shiting to industrialization and eco-nomic eciency at the expense o animal welare and thevalues that have driven the success o the organic industry.

All organic egg producers, with approval rom their indepen-dent certiers, claim to be organic, but with undamentallydierent working denitions and viewpoints o what thismeans. Karma Glos, owner and armer o Kingbird Farmsin New York, describes organic agriculture as a holistic sys-

tem o production designed to optimize the productivity andtness o diverse communities within the agroecosystem.Along with her husband and daughter, she manages a di-verse arm that includes 300 laying hens on pasture. Theireggs are or sale in a local cooperative grocery store. For Ms.Glos, the term outdoor access, a requirement in the ed-

eral organic regulations, means hens roam reely on rotatedpasture, protected by electric encing. Farmers like Ms. Glossee organic arming as a philosophy and way o lienot justa set o marketing regulations enorced by the United StatesDepartment o Agriculture.

Most owners and managers o industrial-scale organic eggoperations dene organic production and outdoor access

very dierentlyi they can hire a USDA-accredited certiy-ing agency to approve an egg operation as organic, basedon current ederal standards, it is organic. They conne tenso thousands o laying hens in henhouses, with meaninglessoutdoor access, at best, which oten consists o concrete orwooden porches barely large enough or one-twentieth othe chickens to be outside at one time. As long as they givethe chickens organic eed and abstain rom using prohibitedsubstances such as antibiotics, they consider their operationsto be organic.

There are also many amily armers who supply organic eggsor nationwide brands, and are neither pasture-based nor

industrial-scale. Their focks are larger than most pasture-based producersusually thousands o birds rather thanhundreds o birdsbut not as large as industrial-scale or-ganic producers with hundreds o thousands o birds. Thesemedium-size amily armers do generally grant outdoor ac-cess to their hensusually at least as much outdoor spaceas indoor space.

This questionwhether organic egg production entailsmeaningul outdoor access or hens, on vegetated outdoorruns or rotated pastureis currently a topic o debate at themeetings o the National Organic Standards Board (NOSB),the expert citizen panel that meets biannually to advise the

Secretary o Agriculture on organic policy and rulemaking.

Although the NOSB already issued a recommendation in2002, stating that organic egg producers must provide veg-etated outdoor runs and that concrete porches do not meetthe intent o the organic rule, the issue resuraced when the

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Introduction: The Organic Egg Industry

inCreasingly, Consumersareinterested in knowing the story behind their ood. Especially with oods that

involve animals, many consumers want to know how arm animals are treated. The organic industry has

experienced tremendous growth in past years, ueled in large part by consumer interest in nding an alter-

native to actory arms and the industrialized ood production system that oten treats animals as units oproduction rather than as living beings, and avors economic eciency over respect or the environment,

amily armers, and the larger community.

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NOSBs Livestock Committee included similar language in aset o recommendations in 2009 that aimed at strengthening

animal welare practices in organic ood production.

In response to the proposed language that would enorceproper outdoor access or laying hens, including quantita-tive standards or indoor/outdoor square ootage per bird,industrial-scale producers traveled en masse to NOSB meet-ings in 2009 and 2010, along with their United Egg Produc-ers lobbyist (the industry trade group), to publicly opposethese various components o the proposed recommenda-tions. They came with arguments such as: Our best deenseagainst such contagious diseases [as avian infuenza] is keep-ing birds indoors.3

Public comment, especially rom organic producers andconsumers, is an important element o NOSB meetings anddeliberations. Meetings are open to the public, and anyone

who requests a time slot is given ve minutes to share theiropinions with the members o the NOSB. Those who can-not attend in person are encouraged to submit written com-ments. For the past yearat two meetingsindustrial-scaleproducers have been organized, energized and well repre-sented as they oppose indoor/outdoor space requirements ororganic laying hens. In contrast, almost no amily-scale or-ganic egg producers were aware o this controversy and havenot been present to publicly comment or support the meritso meaningul outdoor access or poultry.

I industrial-scale producers manage to convince the NOSBto drop the proposals that would give teeth to the require-ment or outdoor access, the economic disadvantage experi-enced by producers that currently ollow the spirit and letter

o the organic rule, giving legitimate outdoor access to theirhens, will continue. Given the rising prole o this debate,the voices o organic egg producers, as well as their consumerallies, who believe that hens should be allowed to go outside,will likely be heard at the upcoming NOSB meeting, sched-uled or October 25-28, 2010, and beyond.

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PAsture-bAsedmobile housingor rotAted PAddocks

On pasture-based arms, focks o laying hens are housed ineither xed houses or mobile chicken coops, and are allowedto roam reely on pasture that is either regularly rotatedso

the chickens are never on the same section o pasture orvery longor the outdoor space is well-managed and largeenough so it is not quickly reduced to dirt and mud by thechickens. Chickens can exhibit their natural behavior onpasture, such as oraging and scratching, and can exercise

by running around and fapping their wings. Or, as promi-nent armer and writer Joel Salatin would say, displaying thechickenness o the chicken.

The pasture-based organic egg producer oers a perect ex-ample o a arm that embodies a common denition o or-ganic arming, as a system that promotes and enhances bio-diversity, biological cycles and soil biological activity. It alsoembodies the belie that organic arms must be based onminimal use o o-arm inputs and on management practicesthat restore, maintain and enhance ecological harmony.5

By incorporating chicken production into a diversied arm,the animals are more than egg-laying machines. They pro-vide valuable services to the arm, such as ertilization, till-age, weed control and insect control on pasture.6 The chick-ens rich manure ertilizes the pasture soil; thereore, a directecological relationship exists between the arms animals, theproduction o their eed, and soil health.

Organic dairy and bee cattle producers also like to keepchickens on pasture because the animals scratch apart lar-va-harboring dung patties, which helps reduce fy and para-site problems on cattle while better distributing nutrients.7

Meanwhile, the dairy cows or cattle are large enough to helpdeter certain wild animals that prey on the chickensthusproviding natural and harmless predator protection or thehens.

By maintaining the hens on pasture, nutrients are cycled be-tween plants and animals on the arm,8 especially i at least aportion o the hens non-pasture eed (grain) is also producedon the arm. Biological cycles and biological soil activity areenhanced, and the use o o-arm inputs is consciously re-duced.

In an attempt to lobby against outdoor access, industrial-scale

producers like to make the case that chickens pick up dis-eases and parasites outside, that they peck the outdoor areato shreds and leave behind a moonscape detrimental toenvironmental stewardship. Bob Beauregard o The CountryHen, or example, commented that Our own experimental

Organic Egg Producers:Three approaches to organic egg production

organiCeggproduCers are a diverse group. Every arm is dierent, but there are generally enough similar-

ities in the various production systems to group armers into one o three organic egg production models:

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trials with 50 hens in a 150-square-oot pen, on the ground, reduced the ground (grass) to mud in about one week.9By rotating chickens on pasture, organic producers can pre-vent these problems. As Anne Fanatico, Ph.D., an organicpoultry expert at Appalachian State University, writes:

It is critical to rest or rotate pastures to prevent these prob-lems. I the house is xed, a rotation should be used to restthe pasture.10

Laying hens on pasture-based arms tend to live longerlivesrequently closer to three years instead o the one year

that is common on industrial-scale arms. Depending on thestate o the birds, spent hens are sold to local communitymembers as backyard chickens; consumed by the arm amilyas stewing hens or sold as stewing hens; or they are, as a lastresort, composted and used to ertilize the arms soil. Evenater they are no longer used to lay eggs, these animals con-tinue to play an important role on the arm or in the com-munity.

heAlthier eggs

Research at Pennsylvania State University reveals discern-

ible nutritional benets to the consumer rom raising layinghens on pasture. When compared with caged hens ed onlya commercial diet, pastured hens produce eggs with twiceas much vitamin E and 2.5-old more healthy omega-3 attyacids.11

Mother Earth News conducted a similar studycomparingthe nutritional qualities o conventional eggs with thoseproduced by pastured hens. Their tests ound that pasture-raised eggs contain one-third less cholesterol, one-quarter

less saturated at, two-thirds more vitamin A, two timesmore omega-3 atty acids and three times more vitamin E.12

Since the nutritional benets stem rom the hens consump-tion o greens outside, hens that have access to mockoutside areas (concrete, gravel, wood or a dirt moonscape)would be unlikely to produce eggs with the same nutritionalattributes.

some select PAsture-bAsed industryPlAyers

Almost by denition, pasture-based organic egg producersare rarely engaged solely in egg production. They tend to rundiversied arms that produce crops and other animal prod-ucts, such as organic dairy and meat. Their laying hens are an

important part o their arm and business, providing incomethrough the sale o eggs while also providing ree servicessuch as ertilization o the soil and insect and weed control.As Missy Bahret, o Old Friends Farm in Massachusetts, ex-plains: Our eathered employees pay rent as they go.

These arms tend to be small or medium scale, since manag-ing a diversied, ecologically balanced arm is labor-inten-sive and becomes more dicult as the size o the arm grows.Their eggs are commonly available through armers markets,Community Supported Agriculture (CSA), or directly romthe arm. But many also sell through local grocery coopera-tives or independent retail stores, and some can be ound

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in supermarket chains such as Whole Foods. Pasture-basedproducers generally sell their eggs locally and independentlyunder their arms name or their independently owned brandname.

Joel Salatin, a sustainable/local diversied armer in Virginia,is a rare media-star armer proled in Michael Pollans TheOmnivores Dilemma and the Academy award-winning docu-mentary Food Inc. He rotates 1,800 chickens in pasture us-ing an eggmobile two 12-by-20-oot trailers hooked to-

gether, each holding 400 layers. The trailers ollow the cows,unctioning, says Salatin, as a biological pasture sanitizer,mimicking birds ollowing herbivores in a wild, like theegret on the rhinos nose.

He also uses what he calls a eathernet, a 20-by-32-ootootprint on skids: Kind o an A-rame with a catwalk upthe middle and nest boxes on the sides. Inside, it holds 1,000layers with a quarter-acre electried poultry net, moved ev-ery 3 days to a new quarter-acre.

Another successul entrepreneur is Nigel Walker o Dixon,Caliornia. Walker raises 2,000 to 3,000 birds, which lay an

average o two to three eggs per week during what he callstheir two-year career. His birds are divided in trailers hous-ing 500 to 600 birds, which are rotated in the pasture.

Examples, based on our research, interviews and site visits osome highly rated, rotational pasture-based egg brands:

Aa k (caa)

The Alexandre Kids brand o organic eggs is available inNorthern Caliornia stores, including North Coast Co-op

and Whole Foods. Hens are housed in mobile egg-mobiles,designed and constructed by the armers children as a Fu-ture Farmers o America project. One egg-mobile houses300 birds, another houses 500 birds, and a third houses 1,000birds. The egg-mobiles are moved to a new section o pas-ture once or twice per week. Predators are controlled withthe help o a Great Pyrenees dog that stays with the fock,and by the dairy cows that share their pasture. Enough pas-ture is available to give each hen 350 square eet o outdoorspaceyes, that is 350 times more outdoor space than in-

dustrial-scale producers like Chino Valley Ranchers, whoseeggs, with the same USDA Organic label, are ound on storeshelves next to Alexandre Kids eggs.

Alexandre Kids hens also live much longer than the averagelaying hen in a crowded henhousehens are sold to peoplein the community when they are three years old. Instead obuying 17-week old pullets (adolescent birds) raised by acontractor or supplier, the Alexandres raise their own chicks.Pasture-based producers also typically do not trim the hensbeaks, a practice that is not prohibited in the organic stan-dards and thereore common in connement systems, where,due to stressul conditions, hens are prone to be aggressive

and cause injuries to fock mates.

Like most armers who rotate their laying hens on pasture,the Alexandre amily raises much more than just chickens.Their arm is diverse, with dairy cows and crop production.

c c (w)

Cook Creek Family Farm produces eggs on a diverse organicarm that also grows vegetables and produces meat and goatmilk. Mobile henhouses hold 85 birds each. The arm has

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1,000 square eet per bird o pasture available, and pasture iscareully rotated weekly. The laying hens share pasture withgoats, and dogs protect them rom predators.

Like most pastured hens, their beaks are not trimmed, andthey are allowed to live on the arm or three years, whenthey are sold as pets or stewing hens. Their manure providesvaluable ertilizer or the arms soil.

PAsture-bAsed And growing!

Industrial-scale organic producers like to argue that theirmodel o large-scale industrial production is necessary toprovide enough organic eggs or the U.S. organic market-place. They believe that their connement model is the onlyway or armers to produce enough organic eggs to meet cur-rent demand. In response to the NOSBs Livestock Commit-tees proposal to require at least as much space outdoors asindoors or organic laying hens, the lobbyist representing in-dustrial-scale producers wrote: While it might be the intent

o the Livestock Committee to limit the production o organ-ic ood products to just small armers or egg production to socalled backyard focks, it should be understood that thesearms cannot produce a sucient volume to meet the cur-rent organic market, and certainly not a growing market.13But their thesis, that meeting market demand is possible onlywith connement systems, is increasingly being challengedby other commercial-scale producers in the industry.

First, European consumers enjoy organic eggs rom hensthat have a minimum o 40 square eet o outdoor space,and organic eggs are readily available in supermarkets acrossthe continent. Second, in the United States, entrepreneur-

ial egg producers are experimenting with scaling up pastureoperations in an eort to make commercial organic egg pro-

duction more sustainable, and more in line with expecta-tions o organic consumers who believe organic oods shouldbe produced on arms adhering to basic organic principles,which include allowing animals to go outside on spaciousoutdoor runs.

And, in the United States, many entrepreneurial arm ami-lies are proving you can do truly pasture-based poultry pro-duction on a commercial scale.

PAths (ba Paa, aaa na)

Another example o this kind o program is called PATHSProgressing Agriculture Toward Healthier Sustainabilitywhich encourages existing organic egg producers to transi-tion toward a pasture program or their animals. John Baker,the president o Giving Nature, an egg marketing company,ounded the program in 2009. Like so many others in theorganic community, Baker believes that the organic egg in-dustry can grow without sacricing its original principles and

ideals. Unlike industrial-scale producers, who argue againstoutdoor access or laying hens, Baker does not believe thatthe growth o the organic industry needs to depend on anindustrial, connement ramework. I the principles o or-ganic arming necessitate pasturing hens on arms that allowor interdependent communities o soil, crops and animalsto interact, then he explains that the organic industry mustgrow while respecting these principles.

Another goal o PATHS Pastured Program or Laying Hensis providing a uture or sustainable, diversied amily arm-ers. Baker explains that PATHS participants can move theirarms toward greater sustainability, generally on arms rang-

ing rom 40 to 200 acresthe typical amily arm in thestate o Pennsylvania, where Bakers business is headquar-tered. While common, modest arms are quickly disappear-ing as large monoculture corporate arming pushes them outand deprives the next generation o a true livelihood in poly-culture sustainable arming, says Baker. The sizes we aretrying to make provide a good income when supported bythe other income derived rom a sustainable and diversiedarming model. It creates a sustainable income uture or thearm.

To participate in the program, egg producers must be certi-ed organic and must provide pasture that is at least three-

ourths vegetated at all times. This means the outdoor spacemust not be overpopulated and must be rotated to allow thepasture to rest and recover rom the pecking and scratchingo the hens. Much o the area will thereore be unused by thebirds at any given time while the pasture restores itsel. Theprogram also requires the use o cover trees or shade clothto provide shade and cover rom overhead predators such ashawks, which will encourage the hens to use all o the out-door space, as opposed to staying close to the henhouse.hs s sws j

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In an eort to promote sustainability on the arm, reduce theneed or o-arm inputs, and recycle nutrients on the arm,the PATHS program encourages egg producers to work to-ward growing at least 50% o the crops needed or the layinghens eed, and to produce and recycle only as much manureas is needed or the crop nutrient needs o the arm.

Three organic egg armers are currently participating in thePATHS program, which is in its early stages. Numerous addi-tional armers have expressed interest. I the program grows,as many as 150,000 laying hens could be out on pastureproducing organic eggs in the state o Pennsylvania alone.I it is successul and other producers in other states adoptthis model o organic production, it would prove that largercommercial-scale organic egg production is possible on truepasture.

O course, 150,000 laying hens in the state o Pennsylvaniais still less than hal the total o laying hens on a single or-ganic industrial-scale arm such as Green Meadow Organics,a mammoth operation owned by Herbrucks Poultry Ranch

in Michigan. The dierence is that Herbrucks hens are con-centrated in one locationand housed in a total o onlythree buildings.

There is, in Bakers opinion, a limit to how large an egg-layingoperation can be beore it is no longer sustainableand thatlimit is roughly 20,000 chickens. To promote sustainability,the goal o the program is to enlist countless independent,medium-scale armers to move their arms toward this typeo sustainability. This is a very dierent model rom buildingone huge complex with 340,000 chickens in one location,as in the Herbrucks example, and then claiming that givingeach chicken outdoor space is simply not easible.

Eggs produced on PATHS arms are currently available inall New York region and Mid-Atlantic Whole Foods stores,marketed under the Giving Nature label.

va a (ba ta, aaa a)Vital Farms is based in Austin, Texas, and produces pasture-raised organic eggs that can be ound in Whole Foods storesacross the country. Currently, 15,000 laying hens are pas-tured on our dierent arms in Texas and Arkansas. Birdson the main arm in Texas are housed in converted cottontrailers that are moved to new pasture every week. Birds onthe Arkansas arm are in xed houses with eight sections opasture radiating rom the house, which are rotated regularlyto maintain the health o the pasture. Each bird has accessto approximately 25 square eet o native grasses, careullymanaged through rotation to maintain healthy and produc-tive pasture.

To meet growing demand, Vital Farms plans to enlist moreamily-scale, pasture-based armers to supply their eggs, rath-er than growing their existing arms in scale.

PermAnent housingAdequAte

outdoor Access

Many organic egg producers in this category have henhousesthat will generally hold between 1,000 and 20,000 birds, withadjacent outdoor space that is at least large enough or allchickens to be outside at the same time. Inside the henhouse,the hens generally live on the foorno cageswith nestboxes, perches and litter, although some houses have aviariesthat have multiple levels within the house or the hens to ac-cess. They are generally granted between 1.2 square eet and1.8 square eet o indoor space per bird.

In this model, outdoor access consists o an outdoor run. Atthe very least, the outdoor space is as large as the indoorspace. However, the outdoor space is xed and generally notmanaged to prevent the hens rom destroying the vegeta-tion. As a result, the entire space or a large portion o thespace can quickly turn into a moonscape.

The chickens ability to run around outside, dustbathe andsunbathe, and engage in other natural behaviors, meets animportant expectation o organic egg consumers. Some othe armers in this category produce other organic commodi-ties as welland some grow eed crops or their birds. Thechickens manure, thereore, is used to ertilize the arms soil,

ullling an important role or the organic arms ecologicalbalance, and reducing the need or o-arm inputs.

However, many producers in this category operate conven-tional arms where the chicken house is their only organicenterprise. In these cases all the eed or the birds is pur-chased rom o the arm, usually rom a local certied organ-ic eed mill. Chicken manure is then spread on other elds inthe area or sold as a commercial ertilizer.

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outdoor Accesstheory versus reAlity

Unortunately, even on many o the amily-scale operationsthat do aord outdoor access, only a minute percentageo the birds actually leave the chicken house to access theoutdoors.

In some cases there is only one large door on the end o abuilding housing 5,000-20,000 birds. A ew hundred hensrom that end o the building might very well take advantageo the outdoor space, but the majority o the birds will nothave eective access to the outdoors (they are not going toclimb over thousands o birds to get outside).

Other operators seem to be intentionally oering outdoor ac-cess with their ngers crossed behind their backs. AlthoughOrganic Valley previously limited their chicken houses to10,000 birds, they have allowed some operations to growbeyond that scale. One arm, in northeast Iowa, houses ap-proximately 35,000 birds in three buildings containing 4,500to 16,000 animals each. The photo above is o one o their

larger buildings. It has just one very small door, on one sideo the building, aording inadequate working access to anarea that appears to comply with Organic Valleys minimumo ve square eet per bird. Not surprisingly, almost no birdswere outside at the time o our visit.

Modern chicken houses, regardless o scale, are generallysplit in hal, with the nesting boxes and conveyor systemsrunning down the middle. In essence, whether the buildinghouses 1,500 birds or 20,000, there are essentially two fockso birds in each building. Many times, there are literally onlygaps o approximately 2 eet allowing birds to cross rom sideto side (which ew do). So, the many examples o housing

where outdoor runs exist only on one side o the building inpractice deprive hal o the birds rom any realistic access tothe outdoors.

Problems with Pullets

Pullets (adolescent birds that have not started laying eggs)are commonly raised rom chicks by subcontractors/suppli-ers rather than the armers themselves. A high percentageo these operations, based on our interviews and site visits,provide no outdoor access whatsoever to the young birds. Bythe time the chickens are old enough to enter the laying op-

erations (commonly 17 weeks o age) they have never beenoutdoors. Even i the henhouse has an adequate numbero doors, and a large, well-maintained outdoor space, mostchickens will never venture outside.

However, we did interview a number o armers who raisepullets or themselves and to sell to others, in the 5,000-15,000-bird range, who do in act comply with the ederalregulations by letting their chickens out at an early age.

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Some smaller operators said they open the doors ater a cou-ple o weeks. The larger pullet producers said they let theirbirds out when their eathers are mature enough to provideprotection, varying between six and ten weeks o age, de-pending on the judgment o the producer (this clearly jus-ties the suitable age or outdoor access established by theNOSB o six weeks).

Widespread abuses are going on in pullet production, lead-ing to mature birds not leaving their housing, as all too manyoperations attempt to alsely reinorce the illusion o outdooraccess with their marketing materials. We urge the USDA toclosely inspect these operations.

some select industry PlAyers ProvidingAdequAte outdoor Access

Based on our research, interviews and site visits, these pro-ducers tend to be independent amily armers who do notmarket their own eggs, but sell to, or contract with, a region-

al organic egg marketing company, or belong to a coopera-tive that markets their eggs. Examples o brands that sell eggsrom medium-scale producers with outdoor access includeOrganic Valley, Farmers Hen House, Pete and Gerrys, andGiving Nature.

a h h

Farmers Hen House organic eggs are produced on medium-size, independent amily arms that provide enough outdooraccess or all hens to be outside at the same time. Most pro-ducers are Amish and Mennonite amily armers, and 90% oFarmers Hen House eggs are produced in the Kalona, Iowa

area, within 10 miles o the egg-processing acility. Many othe arms grow the grain that is ed to their chickens, and usemanure rom the chickens to ertilize the eldscreating theinterdependent relationship between the land, crop produc-tion and the animals on the arm that is such an importantphilosophical aspect or those committed to the principles oorganic arming.

Farmers Hen House has provided an opportunity or Amishand Mennonite amily armers to stay in business by mar-keting their eggsthese armers are interested mainly inarming, and do not want to be engaged in marketing un-der their own brand name. In doing so, Farmers Hen House

also provides an alternative to consumers rom buying romindustrial-scale egg producers. Farmers Hen House eggs areavailable in retail stores, such as Whole Foods, Hy-Vee, Vita-min Cottage Natural Grocers and cooperatives, in the Mid-west and Southwest.

oa va (ba w, aaaa)

The Organic Valley brand is owned by CROPP, the largest

organic armer-owned cooperative in the country, with over$500 million in annual sales. According to its website, a to-tal o 1,652 organic amily armers across the United Statesproduce Organic Valley products, including dairy products,eggs, soy beverages, meat, and orange juice. Organic ValleyFamily o Farms central mission is to support rural commu-nities by protecting the health o the amily armworkingtoward both economic and environmental sustainability.The cooperative has 86 armers nationwide producing theirorganic eggs.

The vast majority o their armer-members are truly amily-scale and operate with high integrity. The co-op has beena leader in the organic industry, with production primarilyrom amily armers, and has developed a viable business thathas supported many amilies in transitioning their arms toorganic management.

Organic Valley has high standards, higher than the minimumsset out in the USDA organic regulations, or its egg produc-ers, including at least ve square eet per bird o outdoorspace. Most o its producers meet this standard. Its membersare generally small, and the cooperative historically had alimit o 10,000 birds per house. This has since been modi-ed, and some o their arms house as many as 17,000 birdsper building. It has also purchased eggs rom non-members,based on market demand, with chicken houses holding asmany as 34,000 birds.

In Caliornia, Organic Valley eggs are supplied by Judy andSteves Egg Farm, described as a amily arm member on thecooperatives website.14 The producer is actually PetalumaFarms.

Petaluma Farms is an industrial-scale, vertically integratedegg producer based in Petaluma, Caliornia. It markets eggsboth organic and conventional cage-reeunder multipleother brand names, including Judys Family Farms, UncleEddies Wild Hen Farm and Rock Island Fertile eggs.

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Although Organic Valley has one o the highest standards orits armer members, it has aorded an exemption to this singleproducer in Caliornia. According to Organic Valleys state-ments, none o the laying hens raised by Petaluma Farms haveoutdoor runs, since its certiying agent, Oregon Tilth, appar-ently allows Petaluma to conne its hens indoors, perpetually.

Describing Petaluma Farms in the bestseller The OmnivoresDilemma, author Michael Pollan says that the industrial eggproducer Truly mastered the conventions o SupermarketPastoral, the term Pollan uses to describe agribusinessesmisrepresenting their products through beautiul packaging,advertising or websites depicting amily arms. The Cornuco-pia Institutes senior arm policy analyst, Mark Kastel, callsthe same phenomenon arming by press release its a loteasier than actual organic livestock management.

Pollan went on to write, Who could begrudge a armernamed Judy $3.59 or a dozen organic eggs she presumablyhas to get up at dawn each morning to gather?15

In addition to the production in Caliornia, which appearsto be an aberration, Cornucopias visits to dozens o OrganicValley member-arms ound a ew isolated examples o in-adequate oversight and noncompliance with both the coop-eratives standards and the ederal organic law. In one case,a 12,000-hen acility near Genoa, Wisconsin, less than vemiles rom the cooperatives CEOs home, had absolutely noaccess to the outdoors or any o their birds, nor do they pro-vide any natural light within the acility.

Thereore, ater Cornucopia sta visits at dozens o OrganicValley member-arms, it appears that the vast majority omember-armers are operating ethically and in ull compli-

ance with USDA regulations and the cooperatives highersel-imposed and publicized standards. But unortunately,not all members appear to be held to the strict standard ove square eet o outdoor space because o selective enorce-ment. We hope that the ndings in this report will motivatethe armer leadership at this cooperative to institute tightercontrols on their management to correct these inconsisten-cies with their public commitments to their customers.

P a g

Pete and Gerrys, based in New Hampshire, produces organiceggs or the Northeast market under its own brand name, as

well as eggs or private label brands.

Producers like Pete and Gerrys challenge the assertionoten repeated by industrial-scale producers who opposeoutdoor accessthat large-scale egg production is not pos-sible while also striving toward meaningul outdoor accessor chickens. Pete and Gerrys has, over the past couple oyears, put winter gardens in all its barns while also increasingoutdoor access. Winter gardens, which are extensions o thebarn, with berglass on top to let in natural light and chicken

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wire on the side to let in resh air, allow the hens to orage indeep litter, enjoy more space, sunlight and resh outdoor air.(Winter gardens are an excellent amenity but no substitute

or legitimate access to outdoors when weather permits.)Rather than meeting demand or organic eggs by buildinglarger henhouses, Pete and Gerrys is instead working withmore amily-scale armers in the region to supply their eggs.

Unlike industrial-scale producers who vehemently opposeany changes to the organic standards that would requireand enorce outdoor access, Pete and Gerrys president JesseLaFlamme is already expanding outdoor space and says, wewill absolutely strive to meet any standard that is passed.

industriAl orgAnicsThe industrial model o egg production is applied to organ-ics most commonly by large-scale, national egg-productioncompanies. Virtually all are primarily engaged in conven-tional egg production, and expanded their product line toinclude organic eggs once they realized the popularity o or-ganics among consumersand the price premium it carries.

Unlike pasture-based producers, and those with meaning-ul outdoor access, industrial-scale organic producers rarelyhave much knowledge or experience in organic arming.Rather than seeing organic arming as an alternative system

to industrial ood production, they seem to believe that theindustrial ood production model (actory arms) can beused to produce organic oodas long as no pesticides, syn-thetic ertilizer, antibiotics, or other prohibited substancesare used.

Industrial-scale producers sometimes buy old conventionalhenhouses and convert them by taking out the cages. In or-der to meet the organic requirement or outdoor access,they commonly build a small, insignicant concrete porchthat is accessible through one or two small popholes.

When they build new henhouses specically or organic pro-duction, they do not move away rom this model, but ratherbuild very large barns housing many tens o thousands ochickens, with nothing more than a small concrete coveredporch as token outdoor access. In some cases, they bringthe outdoors indoors by building winter gardens, whichare enclosed indoor spaces that simulate an outdoor envi-ronment by providing deep litter and allowing access to reshair and sunlight.

Aviary systems, allowing many more birds in individual build-ings as compared to ree-foor systems, are also popular withindustrial-scale producers. Using this approach, houses canhold 85,000 birds or moreexamples are Herbrucks PoultryRanchs Green Meadows Farm in Michigan and Cal-Mainesnew organic buildings in Kansas. According to one organicproducer who specializes in pastured production, some typeso aviary systems are, essentially, gloried cages.

Because cages are opened during the day, allowing the hensto roam reely on the foor, industrial-scale producers con-

sider this a cage-ree operation, and eligible or organiccertication.

In these aviaries, when the hens rst move into the house,they are conned in multi-tiered cages. Ater some time, thedoors to the cages are opened to allow the hens to accessscratching areas on the foor o the house. Because the cagesopen during the day, producers consider this system to becage-ree. Those in cages on top levels have stairways toaccess the foor. Partitions divide the hens into fock sizes o130 to 150 birds.

The manuacturer o one popular aviary system states: The

design concept is based on the idea to reduce the manage-ment eort and at the same time increase reliable and e-cient production.16 Since the cages are closed at night, thesystem is in a gray area between caged and cage-ree produc-tion. This question has never been legally tested.

In their comments to the National Organic Standards Board(NOSB), in response to proposals or stronger rules enorcingoutdoor access, most industrial-scale producers have made itclear that they currently do not provide substantive outdooraccess or their animals and object to prescriptive languagethat would compel them to do so. Their specic argumentsagainst granting outdoor access are listed and addressed in

the section below titled Industrial Organics Argumentsagainst Outdoor Space, page 43.

how common is industriAl orgAnic eggProduction?

According to the United Egg Producers, a trade group orindustrial-scale egg producers, and estimates by some pro-ducers, 80% o eggs come rom the largest producers in theindustry, with layer houses that mirror the conventional/

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industrial model o production and do not provide enoughoutdoor space or every hen to be outside at the same time.

some select industriAl-scAleconinement PlAyers

Examples, based on our research, interviews and site visitso some o the largest corporate players in the organic eggindustry:

ea b (na)

Egglands Best is a major nationwide marketer o conven-tional and organic eggs, available in most grocery stores.Twelve dierent production companies supply organic eggsor the Egglands Best brand.

Bart Slaugh, Director o Quality Assurance at EgglandsBest, opposes increased space requirements or organic lay-ing hens: The push or continually expanding outdoor ac-

cess and decreasing protection needs to stop, and I believethat the proposed standards have gone too ar.17

On its website, Egglands Best misleadingly tells customersthat the company adopted very stringent welare regula-tions. But, the only third party certication it adheres toor its caged hens is the sel-serving United Egg ProducersAnimal Welare program, which guarantees only that henshave access to eed and water; the standards do not evenrequire that hens have enough space to stretch their wings.In act, the standards are so lax and industry-beholden thatthey even allow cageswhich are, o course, prohibited inorganic production.

One o the 12 suppliers or Egglands Best organic eggs is Cal-Maine, the largest agribusiness producing eggs in the UnitedStates. Cal-Maine (signiying Caliornia to Maine) is a pub-licly traded corporation that is mainly involved in conven-tional, caged egg production, but has, in recent years, grown

its presence in organics. Cal-Maine boasts that it is one othe largest producers and marketers o value-added specialtyshell eggs in the United States, with specialty sales repre-senting 13.8% o its shell egg sales in scal year 2009. 18 Itsspecialty egg sales are not limited to organic eggs but includecage-ree, all-natural, vegetarian and omega-3 eggs.

Other companies that supply organic eggs or the Egg-LandsBest brand and or private labels include Braswell, the sec-ond-largest Egg-Lands Best ranchisee, which also suppliesHorizon Organic eggs (a division o Dean Foods),19 Moark,Morning Fresh,20 Herbrucks in the Midwest, and Dixie EggCompany in the Southeast.21

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4gaIn addition to selling organic eggs under the Egglands Bestbrand name, Cal-Maine markets its own organic eggs underits 4Grain brand name.22 The company also produces organicshell eggs or private-label customers.

Cal-Maine, as a corporation, is not a supporter o animalwelare measuresit was a major donor to the campaign inCaliornia opposing the Prevention o Farm Animal CrueltyAct. Cal-Maine reportedly spent more than hal a milliondollars to oppose this measure, which outlawed keepinglaying hens in cages, and which voters overwhelmingly ap-proved in 2008.23

Cal-Maine has ocused on industry consolidation. From1989 to 2009, the company acquired 16 companies, rangingin size rom 600,000 layers to 7.5 million layers. One o theseacquisitions was Hillandale, which produces organically cer-tied eggs in its Pennsylvania acility. The Cal-Maine/Hil-landale organic henhouse has two stories, and hens on thesecond story have access to small porches via a single door

(or tens o thousands o chickens) and a ramp leading downto this space. Given that there are an estimated 30,000 henson each foor, it is not surprising that very ew o the hensseemed to use the small outdoor porchresearch shows thatthe larger the fock size, the less the hens go outside.24

Cal-Maine is also a pro rata guarantor o debt undertaken byDelta Egg Farm, LLC, to construct an organic egg produc-tion and distribution acility near Chase, Kansas.25

c va ra

Chino Valley Ranchers produces both conventional and or-

ganic eggs on its own ranches, located in Caliornia andTexas, as well as eggs rom small- and medium-scale armersin the Midwest. Its eggs can be ound in 30 states under theChino Valley Ranchers label, and it also provides eggs orprivate-label customers.

Chino Valley Ranchers presents misleading marketing in-ormation to its customers. The company markets eggs pro-duced on numerous arms, including a giant industrial acil-ity in Texas. On the homepage o its website, the companywrites, Our ranch is nestled in the picturesque rolling hillso Southern Caliornia.26 On another webpage, it writes thatour commitment is to the wellbeing o our birds, the land

we arm, the hard-working olks who run the arms, and theconsumer, who deserves to know the truth about where theirood comes rom.27 When asked about the location o itsTexas egg-producing acility, Chino Valley reused to shareany inormation with The Cornucopia Institute. It appearsthat its customers right to know how their ood is producedhas its limits. (Ater the publication o this report, ChinoValley Ranches management said they are considering al-lowing Cornucopia researchers to visit their Texas acility.)

At the November 2009 meeting o the National OrganicStandards Board, Chino Valley Ranchers General Man-ager, David Will, lobbied against stronger animal welarestandards, and opposed increased outdoor space and indoorspace requirements or laying hens. Mr. Will pointed out thatChino Valley bought existing egg production operations, o-ten caged henhouses, and converted them to organic, keep-ing the existing building ootprint, spacing and boundaries.I they have to grant every laying hen two square eet inside,and three square eet outside, David Will predicted that itwould, orce a major constriction i not total abandonmento our organic egg production.28

Paa a

Producing both conventional and organic eggs, Petalumamarkets them under a number o dierent labels: Rock Is-land, Uncle Eddies, Gold Circle and Judys Family Farm.

Petaluma is owned by Steve Mahrt (his wie is the Judy otheir organic label), a third-generation egg producer. Edible

East Bay reported in 2009 that Petaluma joined other indus-trial egg producers in Caliornia ghting Proposition 2. Thesuccessul ballot initiative requires minimum humane stan-dards or livestock production, bans battery cages or layinghens and requires the birds to be able to turn around reely,lie down, stand up and ully extend their limbs.

Asked about smaller producers by Edible East Bay, Mahrtresponded, Whats ree range? I dont know o anyone re-ally producing ree range. The article also eatured a proleo Eatwell Farm in Dixon, Caliornia, which produces eggsrom 2,000 to 3,000 chickens in individual 500- to 600-birdmobile chicken coops on pasture.

In the same article, Nigel Walker, owner o Eatwell, criticizedPetalumas marketing approach, saying, What [Mahrts] do-ing is hal way, but hes making it look like the whole way my problem is the misrepresentation.29

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The Mahrt amily also owns and controls Rock Island Rerig-erated Distributors, Inc., a $17 million distributor o eggs and

other perishable ood.

See the Organic Valley prole above or more background onPetaluma Farms, Organic Valleys West Coast egg supplier.

industriAl-scAle Producers

Pa la

The term private label reers to store brands, such as Sae-ways O Organics, Stop n Shops Natures Promise andTrader Joes. Many, i not all, industrial-scale organic eggproducers supply organic eggs or private-label customers. In

addition to Cal-Maine and Chino Valley, described above,Herbrucks Poultry Ranch in Michigan is an example o alarge company supplying private-label organic eggs.

Herbrucks produces both conventional and organic eggswith organic eggs accounting or approximately 10% o itsbusiness. The company supplies organic eggs or stores suchas Meijer, Kroger, Saeway and others, as well as brand namessuch as Egg-Lands Best.

Herbrucks keeps 80% o its laying hens in cages, and itsconventional egg business supplies Cargill, which in turnsupplies eggs or McDonalds (it should be noted that many

corporate purchasers o eggs are now demanding cage-reeproduction). The president o Herbrucks Poultry Ranch ap-parently believes that keeping hens in cages is a good idea:We went away rom [letting hens roam ree] or a wholebunch o really good reasons, said Stephen Herbruck.30

Yet, demand or organic eggs is growing, so Herbrucks re-cently expanded its organic business. In 2008, the companyinvested $13 million to build our new organically certiedhenhouses, each housing 85,000 laying hens. The acility,

called Green Meadow Organics, has room or our more

houses, which would push Herbrucks number o certied

organic laying hens past 1 million.

Greg Herbruck, who represents the amily business at NOSB

meetings, opposes strengthened animal welare standards

since Green Meadow Organics could not comply with the

proposed space requirements. He said: Our henhouses were

not designed to meet the outside or inside space standards

as proposed.

It is noteworthy to remember that the current (2010) organic

standards clearly require year-round access or all animals to

the outdoors.31 The current deliberations by the NOSB are

about setting dened benchmarks so that certiers can moreeasily enorce the requirement.

Mr. Herbruck wrote to the National Organic Standards

Board: I implemented, existing producers must be grand-

athered in, as they have met all organic standards until

this current drat. I not grandathered in, they must be

adequately compensated or their signicant losses or their

present organic conversion capital investments. 32 However,

producers like Herbrucks, should they be unwilling to meet

the animal management standards demanded by the organic

industry, have other options, such as cage-ree, or the sale

o their shell eggs.

Other organic egg producers, who do provide adequate out-

door space or their hens, point out that producers such as

Herbruck should have considered the possibility o enorce-

ment and a urther rening o the standards to comply with

organic principles and consumer expectations, and that these

producers must accept the consequences o a leveling o the

playing eld or all organic egg producers.

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Producer Location o industrial-scaleorganic acility

Conventionaleggs?

Certiedorganiceggs?

Organic certier Signatory to UEPletter opposingoutdoor access

Chino Valley Ranchers i, tX;a, ca

ys ys c co s

n

Cal-Maine cs, KS;S gv, pa

ys ys o t ys

Petaluma Farms p, ca ys ys o t n

Herbrucks Poultry Ranch S, mi ys ys Q assi

ys

Delta Egg Farms d, ut ys ys o t ys

Dixie Egg Company bks, ga ys ys Q cSvs

ys

Fassio Egg Farms u ys ys u d. a ys

Fort Recovery Equity rv, oh ys ys g o a ysKrehers Farm Fresh Eggs c, ny ys ys ukw ys

Nature Pure o g oc

ys

Oakdell lws, ut ys ys u d. a ys

Ritewood lws, ut ys ys u d. a ys

Egg Innovations i ys ys QcS n

The Country Hen hs, ma n ys n s cs n

Moark J, oK ys ys goc n

Cal-MaineChase, KS

Petaluma FarmsPetaluma, CA

Herbrucks Poultry RanchSaranac, MI

Fassio Egg FarmsWest Valley, UTDelta Egg Farms

Delta, UT

OakdellLewiston, UT

RitewoodLewiston, UT

Dixie Egg CompanyBlackshear, GA

Fort Recovery EquityFort Recovery, OH

The Country HenHubbardston, MA

Nature PureOhio

Krehers FarmFresh Eggs

Clarence, NY

Egg InnovationsIndiana

Cal-MaineSpring Grove, PA

Chino Valley RanchersIdalou, TX

MoarkJay, OKChino Valley Ranchers

Arcadia, CA

ps ss 2010

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Well-versed in modern production, such new entrants to theorganic egg industry are amiliar with raising tens o thou-sands, sometimes hundreds o thousands, o chickens inconnement, and have no experience with or knowledge omanaging pasture or outdoor runs.

In act, they seem to nd the thought o allowing chick-ens to roam reely on pasture to be utterly mind-boggling.Foodonics, a company that recently converted two sites with55,000 laying hens to organic production, writes that the

subjection o a chicken to potentially deadly bacteria anddiseases would be endless by allowing them to roam reely ina pasture.33 These industrial-scale producers admit to hav-ing entered the organic market or protability reasons, andcomplain that allowing chickens to go outside would vastlyoutweigh organic protability.34

These producers sometimes acknowledge that the only di-erence between their conventional and organic laying hensis their dietno dierences exist in the birds ability to go

outside and exhibit their natural behavior outdoors. For ex-ample, Petaluma Farms in Caliornia, which markets JudysFamily Farm organic eggs and supplies other brands such asOrganic Valley, writes on its website that the only real di-erence in how the focks are raised is what they eat.35

The thought o letting chickens roam outside is incompre-hensible to industrial-scale producers because it would benearly impossible to manage so-called actory arms o theircurrent scale i chickens were allowed outside. HerbrucksPoultry Ranchs new Green Meadow Organics acility, which

houses 340,000 organic laying hens, would require, at a mini-mum, 22 acres i every animal were granted three square eeto outdoor space (note that some voluntary standards, suchas Organic Valleys, require ve square eet.). To protect thepasture and the animals, 340,000 hens would need to be ro-tated on pasturelikely requiring more than 22 acres. Her-brucks has repeatedly complained to the National OrganicStandards Board that granting 22 acres o outdoor spacewould be impossibleunwilling, apparently, to recognizethat plenty o true organic armers with much ewer birds

grant much more than 22 acres o outdoor space to theirchickens. In real organic arming, 22 acres o pasture is, ocourse, no big deal at all.

These industrial-scale producers rely extensively on their or-ganic certiersi the certier approves their operation asmeeting the organic standards, they are satised and benetrom the price premium that the organic label commands.Especially with livestock producers there are persistent ru-mors o shopping or a certier where operators will search

or an accredited certier that will bless their operation a-ter inquiries with other reputable certiers have resulted inguidance that their production model, without modication,would not meet the ederal standards.

Certiers play an important role in the organic communityand industry. While organic rules are determined and en-orced by the United States Department o Agriculture, it isthe role o USDA-accredited certiying agencies to inspectindividual arms and processing acilities to ensure they are

Outdoor AccessA Shell Game

sinCeeggproduCers have been able to easily convert cage-ree henhouses to organic by simply eeding

organic eed and building a small concrete porch attached to the henhouse, the organic egg industry has

attracted highly-capitalized newcomers who are amiliar with modern poultry production, but have no

understanding o organic principles and arming.

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in compliance with the ederal standards. The certiying

agencys interpretation o the organic standards is thereorevery important. Unortunately, some certiying agents havegiven a green light to huge, industrial-scale henhouses withsmall, bare concrete porches, and some have even grantedpermanent exemptions rom outdoor access.

As an example, some industrial-scale egg producers have pro-cured letters rom their veterinarians stating that it would beunhealthy or the birds to be allowed outdoors. In the caseo Petaluma Farms, operating in Caliornia, one o their buy-ers, Organic Valley, reerences that state veterinarians andthe Caliornia Department o Agriculture strongly advocatethat birds not have ree-range outdoor access because o therisk o avian infuenza transmission36 to justiy their total-connement operation. However, less than 10 miles downthe road is another large competing industrial operation thatgives its birds at least some outdoor access, and the state oCaliornia has plenty o organic producers whose birds enjoyree access to the outdoors. It must also be noted that theletter rom state regulators was just a recommendation, nota legal mandate, and it was thus ignored by many organicproducers who have the legal obligation to aord outdooraccess to their birds.

Moreover, when the NOSB discussed outdoor access orpoultry in 2001 and 2002, the industrial egg lobbyist triedto make the case that outdoor access was dangerous to the

health o the birds. Board members repeatedly asked or prooo outbreaks among organic and pastured hens. None wasever supplied. On the contrary, cases o avian infuenza aremost commonly detected on connement operations, whichhas led to the orced destruction o entire focks.37

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Cornucopias Organic Egg Scorecard

tohelporganiCConsumers determine which brand o organic eggs complies with their ethical expec-

tations and ts into which o the three aorementioned organic production models, The Cornucopia

Institute developed a scorecard o organic egg brands. Ratings are based on the producers answers to a

questionnaire about production practices, site inspections, satellite imagery and extensive interviews.It is designed so consumers and wholesale buyers can makediscerning purchasing decisions rewarding the individualarms, cooperatives and corporations that have made theinvestment in both knowledge and acilities to comply with

both the letter o the ederal laws governing organics and thevalues-based expectations o organic egg customers.

Brands all in one o ve categories:

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Dening Real/Legal Organic Egg Production

thequestion, What does being organic mean in egg production? is a contentious one in the organic

community. Large-scale producers insist that their industrial model o ood productionregardless o

its inherent monoculture (lack o biodiversity), dependence on inputs imported rom o the arm, and

dependence on connement systems or livestock, etc.can be applied to organics. For them, organic isnothing more than a set o standards developed in 2002 by the United States Department o Agriculture,

which opens the door to higher prots rom consumers who are willing to pay more. Some industry lobby-

ists play the same games trying to develop or exploit loopholes in the organic standards in the same way

that their ellow tax attorneys attempt to manipulate and exploit the tax code or corporate benet.

For most organic armers and consum-ers, organic is much more than a seto ederal regulationsit is a armmanagement system, an agricul-tural philosophy, and a way o lie.

Unortunately, amily armers whobelieve in the ecological principleso organic agriculture, such as di-versity and the interdependence osoil, crops, animals and people, can-not compete with the prices oered byindustrial organics and are being placed ata distinct competitive disadvantage.

So what should organic mean? Denitions rom varioussources, including the United States Department o Agri-culture, challenge the assertion that the industrial model oagriculture can be applied to organics.

orgAnic As deined by theunited stAtes dePArtment oAgriculture

Congress passed the Organic Foods Production Act in 1990,giving birth to the United States Department o AgriculturesNational Organic Program (NOP). Unlike most eco-labelson ood packages, the term organic is dened and highlyregulated by the ederal government. A ood package cannot

claim to be organic unless it was produced and processed ac-cording to a strict set o rules governing the use o pesticides,synthetic ertilizers, livestock living conditions, drugs suchas antibiotics, genetically engineered organisms, potentiallydangerous processing agents, and the list goes on.

Under the Terms Dened section o the National OrganicPrograms ederal standards, organic production is denedas ollows:

A production system that is managed in accordance withthe Act and regulations in this part to respond to site-

specic conditions by integrating cultural, biological, andmechanical practices that oster cycling o resources,promote ecological balance, and conserve biodiversity[emphasis added].

For eggs specically, the USDAs standards speciythat the term organic can only be used i the ol-

lowing standards are met:

205.239 (a) The producer o an organic livestock opera-tion must establish and maintain livestock living condi-tions which accommodate the health and natural behavioro animals, including:

Year-round access or all animals to the outdoors, shade,shelter, exercise areas, resh air, clean water and direct sun-light suitable to the species, its stage o production, theclimate, and the environment [emphasis added].

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In February 2010, the national organic standards were modi-ed as a result o the long-awaited pasture rule, which wasaimed at strengthening the organic standards or dairy cowsand bee cattle but aects poultry operations as well. Theollowing sentence was added to the standards in 205.239(a)(1):

Continuous total connement o any animal indoors isprohibited.

While they are developed and ultimately enorced by theederal government (with years o input rom all industrystakeholders), the actual inspections o arms and processingplants are perormed by certiying agents that are accreditedby the USDA. The USDA doesnt actually certiy any ood.They, in essence, certiy the certiers.

Certiers, reerred to by the USDA as Accredited Certiy-ing Agencies (ACAs), have the responsibility o ensuringthat anyone claiming to be organic is indeed adhering to theorganic standards. Unortunately, there have been consid-

erable dierences, amplied by economic considerations, inhow certiying agencies interpret the standards.

orgAnic deined by vArious

usdA-Accredited certiyingAgencies

Certiying agencies conduct the third-party annual inspec-tions o all organic arms and processors, to ensure that theyare complying with the ederally regulated organic standards.Fity-nine USDA accredited agencies currently operate inthe United States.39

There are substantial dierences in the way in which USDA-accredited certiying agencies interpret the ederal standardspertaining to poultry production. For example, the North-east Organic Farming Association New York (NOFA-NY)species that chickens must be granted meaningul outdooraccess, which means pecking on the ground, resh air, anddirect sunlight. The certier also recommends rotation opasture to make outdoor access meaningul, and speciesthat an organic egg operation must grant at least 1.5 squareeet per bird o outdoor space40 (all requirements seeminglyrelate to the language in the above-noted section 205.239 othe ederal standards).

Unlike NOFA-NY, some other certiying agencies do notlook or meaningul outdoor access. They approve any out-door area, regardless o its size, the birds ability to reach thisarea or the birds ability to engage in natural behaviors. Asmall porch, under a roo, with concrete fooring and net-ting, chicken wire or screening all around, passes as outdooraccess or these certiers. Oregon Tilth, or example, certi-es Petaluma Farms, which grants no outdoor access what-

soever, and Natural Foods Certiers certies The CountryHen, which has small covered, enclosed wooden porches asoutdoor access. For certiers such as Pennsylvania Certi-ed Organic, an outdoor porch that is 10% the size o theindoor space passes as outdoor access.

orgAnic deined by the nAtionAlorgAnic stAndArds boArd

When the 1990 Organic Food Production Act established

the National Organic Program, it also created an expertcitizen panel, called the National Organic Standards Board(NOSB), charged with the task o advising the Secretary oAgriculture in setting the standards upon which the Nation-al Organic Program is based. In 1995, members o the NOSBdened organic as ollows:

Organic agriculture is an ecological production managementsystem that promotes and enhances biodiversity, biologicalcycles and soil biological activity. It is based on minimal useo o-arm inputs and on management practices that restore,maintain and enhance ecological harmony.

Organic is a labeling term that denotes products producedunder the authority o the Organic Foods Production Act.The principal guidelines or organic production are to usematerials and practices that enhance the ecological balanceo natural systems and that integrate the parts o the armingsystem into an ecological whole.

Organic agriculture practices cannot ensure that productsare completely ree o residues; however, methods are usedto minimize pollution rom air, soil and water.

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Organic ood handlers, processors and retailers adhere tostandards that maintain the integrity o organic agriculturalproducts. The primary goal o organic agriculture is to opti-mize the health and productivity o interdependent commu-nities o soil lie, plants, animals and people.

Unlike the industrial egg production model, which seekseconomic eciency by separating various aspects o pro-ductioneed is grown in one place (possibly as ar away asChina), chickens are raised on another operation, and theirmanure is shipped to entirely dierent arms (requently noteven organic)true organic production aims to imitate nat-ural processes in which a diversity o animals and crops areintegrated into an ecological whole, reducing the need oro-arm inputs and minimizing avoidable use o nonrenew-able resources in production, processing and transport. TheNOSBs denition o organic calls or such integration. Theindustrial model o egg productionwhere an egg operationwith tens or hundreds o thousands o chickens is completelyseparated rom any land base or crop productionhardly tsthe NOSBs original denition o organic agriculture.

Moreover, in 2002, members o the NOSB recognized thatsome producers might use meaningless porches as outdooraccess, and issued a recommendation to clariy the intento the organic standards. Their recommendation languished,and has not been adopted by the National Organic Programas an ocial standard, but certiying agents and organicarmers oten use NOSB recommendations to better under-stand the intent o ambiguous or unclear organic standards.The poultry recommendation41 states:

Organically managed poultry must have access to the out-doors. Organic livestock acilities shall give poultry the abil-

ity to choose to be in the housing or outside in the openair and direct sunshine. The producers organic system planshall illustrate how the producer will maximize and encour-age access to the outdoors.

Bare suraces other than soil (e.g. metal, concrete, wood) donot meet the intent o the National Organic Standards.

The producer o organically managed poultry may, whenjustied in the organic system plan (and reviewed by the or-ganic certication agent), provide temporary connementbecause o:

Inclement weather;

The stage o production (i.e. insucient eathering to pre-vent health problems caused by outside exposure);

Conditions under which the health, saety, or well being othe poultry could be jeopardized; or

Risk to soil or water quality.

First, the NOSB specied that laying hens must be encour-aged to go outside. The recommendation also states that

poultry shall have the ability to choose to be in the housingor outside in the open air and direct sunshine. Providingone or two small doors in a house with tens o thousandso chickens hardly qualies as encouraging the birds to gooutside. For the vast majority o hens in a crowded henhouse,the door to the outdoors is too ar to give them t

scrambled eggs: separating factory farm egg production from authentic organic agriculture

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