The American Pastured Poultry Producers Association (APPPA) recognizes the United States Department of Agriculture’s (USDA) Agricultural Marketing Service’s (AMS) effort to make the organic label address consumers’ expectations with regard to animal welfare and husbandry practices. While the proposed “National Organic Program: Organic Livestock and Poultry Practices” rule makes some beneficial strides toward improving the animal welfare of organically certified poultry, it stops short in several critical ways.

APPPA is a non-profit membership-based organization that provides educational resources to pastured poultry farmers and represents approximately 1,000 active member farms. APPPA was formed in 1997 as a clearing house of ideas to support a renewed interest in pastured poultry.

Pastured poultry embodies a few key tenets of production: the birds live a significant portion of their lives outside on vegetated pasture; the birds are rotated to fresh vegetation often in a managed way; flocks are housed in lower stocking densities to ensure the birds can express their natural behaviors without stress and injury to themselves or other birds; in addition to the forage offered via pasture, the birds eat a nutritionally balanced feed that is appropriate for the species and age of the flock; slaughter is typically done in small-scale or exempt facilities by hand in a way that respects the life of the animal.

In practice, pastured poultry farmers employ different production models typically identified as daily move, day-range, and free range systems. In a daily move system, poultry are confined inside a movable shelter that typically accommodate groups of 50 to 600 birds per shelter; however, the birds have direct access to the soil and pasture while inside these well ventilated shelters.

In day range systems, the birds are allowed to access an outdoor area independent of the housing area. Birds typically range inside temporary paddocks created by portable electric fencing and the housing, if left stationary, will have bedding and may have flooring and roosts. At regular intervals, the house and the paddock are rotated to areas of fresh vegetated pasture.

A free-range model places birds on range without fences and relies on longer distance pasture rotations to keep the birds on fresh pasture; though this free-range concept offers the most idyllic view of outdoor poultry production, it offers the least amount of predator protection and is difficult to make work on small acreages.

A majority of pastured poultry producers will use either daily move or day range systems. Producers typically favor day range for laying flocks, waterfowl, and finishing turkeys. The daily move system is often used for broilers, young turkeys, and maximum predator protection for laying hens.

Ranging out of a fixed building is not commonly done on a pastured poultry farm because it’s difficult to manage the outdoor area in a way that does not result in degradation of the quality of soil, pasture, and forages. If the producer is stocking the fixed house paddock in a way that does not degrade the pasture, then the birds are not efficiently utilizing the range. This is the conundrum AMS has with trying to fit the intent of organic poultry production into the confined animal feeding operation model. The current proposal fails to solve the conundrum.

APPPA clearly differentiates between certified organic production and pastured poultry production. They are not equivalent, even though some pastured poultry producers are certified organic. In publishing standards, in marketing, in education, and in discussions AMS should take care to ensure that they clearly communicate that the organic certification does not necessarily mean the birds have been pasture-raised. In the final rule, we would like AMS to acknowledge that while some locally available organic chicken may be pasture-raised, organic certification does not mean the birds have been raised on pasture.

The proposed rule falls short of the typical animal welfare measures provided in the management of commercial pastured poultry flocks in terms of low stocking densities, living outdoors for significant portions of life, and managed and planned pasture rotation.

Based on a 2014 APPPA survey of pastured poultry producers, the number of certified organic layer flocks (as self-reported) was 8% certified organic and 7% Animal Welfare Approved (AWA). The number of certified organic broilers was 9% and 7% AWA.

The relatively low incidence of pastured poultry producers seeking organic certification has two primary causes.

First, most pastured poultry producers serve direct markets where trust is earned through direct contact with the consumer–the epitome of “know your farmer.”

Second, the organic poultry and egg standards, as currently enforced, place confinement organic poultry and organic pastured poultry operations as equals in the marketplace; in reality, however, they are different. Producers know it and more consumers are realizing it. Pastured poultry answers the consumer calls that the commercial (as defined by USDA) organic poultry industry ignores: local production, less densely stocked flocks, husbandry practices that leverage the birds’ natural behaviors, and beneficial impacts to soil health and fertility.

With regard to distinguishing pastured poultry from organic poultry production, APPPA recommends:

1. AMS clearly state that certified organic poultry does not imply pasture-raised and organic certification does not connote the principles of pasture-raised poultry as outlined by the American Pastured Poultry Producers Association in this response.
   
2. AMS acknowledge that pasture housing (daily move, day range and free range) are acceptable production models with regard to the organic regulations, as long as those housing models meet the minimum standards as published in the final rule.
   

Outdoor Access and Stocking Density

The recognition that porches do not constitute outdoor access is obvious, and AMS should follow through on its proposal to disallow porches. The allowance of porches skirts the existing outdoor access requirement in organic poultry production by providing a thinly veiled appearance of compliance.

The natural bird response to being confined in large numbers on the floor prevents all birds from moving around as freely as expected and therefore prevents many of them from accessing the door. The birds’ response in these houses is to gather in groups that stay in one area; the birds do not circulate and move freely around the entire floor. That means the birds don’t use the porch and other outdoor access areas in any meaningful way. Commercial poultry producers see this hierarchy at play each day when a negligible number of birds take advantage of their outdoor access.

When the government has to define the meanings of “soil” and “the outdoors,” it’s clear that the intent of organic poultry production has become adulterated. APPPA feels strongly that outdoor access requires provision of areas with 90 to 100% vegetative cover. Such vegetative cover requires soil, sun, and planned rest from grazing to grow. This access to vegetative cover in the outdoor area is a principled point of differentiation between pastured poultry production and the AMS’s organic standards. Consumer feedback to pastured poultry producers repeatedly indicates that they expect organically raised poultry to live a significant portion of their lives outside on pasture; compliance with the proposed rule will not meet that expectation.

Specifying outdoor stocking densities without consideration of pasture rotation, including planning for forage regeneration, creates an incomplete understanding for producers. This represents another major differentiation between pastured poultry and the proposed organic standard. A key to successfully producing poultry on vegetative pasture is the managed rotation of the birds to fresh vegetation at frequent intervals, sometimes multiple times a day. Disconnecting the flock rotation from outdoor stocking density runs the risk of denuded outdoor paddocks, which leads to health risks to the flock and decreased soil health. The size of the outdoor area is predicated on the pasture management plan, which includes consideration of the quantity and quality of the vegetation in the pasture, as well as the amount of time the birds will be on the ground. The size of the outdoor area cannot be accurately predetermined without consideration of those and other unique factors, such as geography and seasonal variations.

The movement of the birds away from their own waste, via regular movement and rotation of housing areas, creates the healthy environment needed to rear flocks without the reliance on antibiotics. The proposed standards do not clearly articulate the relationship between stocking densities and pasture rotation.

With regard to outdoor access and stocking density, APPPA requests that the final rule:

1. Disallow covered porches as the only outdoor access area.
   
2. Provision for outdoor areas to have 90 to 100% vegetative cover.
   
3. Ensure producers plan for the appropriate pasture space, stocking density, and rotation to ensure the health and natural behavior of the birds while not resulting in the degradation of the soil, pasture, and forages. Outdoor area must minimize the spread of parasites and diseases and the build-up of excess nutrients.
   

Indoor Stocking Density

The proposed indoor stocking densities as set forth in the proposed rule set a low standard. The indoor housing recommendation of 4.5 pounds per square foot (1 square foot per laying hen) for a pasture housing type will only work if the birds are also ranging on pasture. In a winter, or indoor, housing environment, that stocking density will create a stressful environment.

There is a simple test to ensure that stocking densities are correct. If debeaking or beak trimming is required to keep the flock from pecking each other, then the stocking density is too high and, consequently, the animal welfare is too low. One common cause of pecking is caused by environmental stressors, such as crowding.

The proposed indoor stocking densities continue to enable producers to violate consumer expectations by permitting multi-story aviary production models for laying hens. Multi-story laying houses should not be permitted in organic production. The rule is going to create a clear double standard in organic production based on housing type and more production will move to the multi-story houses, creating economies of scale that further water down the organic egg market and further violate consumer expectations and reduce animal welfare. Houses that encourage birds defecating on each other are not a vision most consumers have of organic egg production. It’s also not a healthy way to raise laying hens.

Indoor stocking densities also need to make considerations for the season, the weather and the access to the outdoors. In a pastured housing model, a laying hen may be content with 1.5 to 2.0 square feet of indoor space if allowed access to a rotated pasture. However, when a laying hen is confined in the winter, lower stocking densities provide less stress and less ammonia build up.

With regard to indoor stocking density, APPPA recommends:

1. The use of multi-story houses is discontinued in organic production.
   
2. Indoor stocking densities are lowered. When birds are withheld from outdoor areas or when birds are housed in a daily move pasture shelter, APPPA recommends the following stocking densities across all housing types: 3 sq. ft. per laying hen (1.5 lbs. per sq. ft.); 1.5 sq. ft. per broiler (4 lbs. per sq. ft.); 7 sq. ft. per turkey (4 lbs. per sq. ft.).
   
3. Organic production disallows beak trimming and debeaking as defined in the proposed rule. The burden of managing the physical behaviors should revert to the producer employing husbandry practices that complement the natural bird behaviors.
   

Indoor Confinement

APPPA feels strongly that organic poultry producers are permitted, by the current and proposed rules, to overreact and confine flocks too easily. The organic confinement model poultry industry continues to use the fallacious threat of disease for denying outdoor access.

When organic producers are allowed to repeatedly and continually confine the flock based on the threat of a disease, it further erodes the confidence of the organic label. We point to the recent Highly Pathogenic Avian Influenza (HPAI) outbreaks in the United States as evidence. At the time of comments (June 2016), many organic flocks are still permitted to be confined and have been confined since the beginning of 2015 based on the perceived threat of HPAI and a risk assessment that does not match the observed data from prior outbreaks.

To illustrate, we’ll cite the USDA’s own assessment of the risk of HPAI as published in Docket ID: APHIS-2015-0061. Conditions for Payment of Highly Pathogenic Avian Influenza Indemnity Claims. This excerpt is taken from the proposed biosecurity exemption for smaller facilities (less than 100,000 broilers annually, 30,000 turkeys annually, and commercial table egg facilities with less than 75,000 birds): "[T]he smaller facilities that we are exempting from the requirement are less likely to have HPAI outbreaks than are the non-exempt ones. On smaller facilities, birds density tends to be less which minimizes overall viral load. Additionally, if a smaller facility was identified with HPAI the disease is less likely to spread outward to other premises because there are fewer birds, vehicles, pieces of equipment, and employees moving onto and off of the smaller, exempted facilities when compared to the larger, non-exempted ones."

In light of APHIS’ stated correlation between stocking density and viral load to HPAI, APPPA believes strongly that both indoor and outdoor stocking densities play an important role in the health and management of the flock. AMS should decrease the stocking densities for both indoor and outdoor access and recognize that appropriate stocking density is a key factor in healthy poultry husbandry.

With regard to HPAI, the evidence is also clear that the virus is susceptible to heat and sunlight. Yet, current organic production regulations – and hence practices - support continued disregard of that data.

More and more consumers see through the shortcomings of the organic label, which propels them to pasture-raised poultry, a craft production system that focuses on managing symbiotic relationships, working with the natural tendencies of the poultry, and ensuring animal welfare.

In the information we’ve gathered, neither a well-managed pastured flock nor a certified organic flock has been infected with HPAI. That’s different than saying there is no risk; we can never eliminate the risk of HPAI in a poultry flock, but we can manage it. 49.7 million birds were affected by HPAI in the 2014/15 outbreak in the U.S.

The HPAI 2014/15 Confirmed Detection report by APHIS shows that less than 4,000 of the birds affected were spread across 20 backyard flocks; APHIS reports an additional game bird flock of 5,830 pheasants that it counts as a backyard flock. That means that more than 49.6 million intensely confined birds were killed either by the virus or destroyed by regulators as a part of the outbreak response.

Of the effected backyard flocks, we do not know the husbandry practices of those flocks (at least not publicly). Backyard poultry is also not synonymous with pastured poultry, even though the current categorization by the USDA equates these practices, not differentiating between backyard flocks, hobby flocks, poultry ranging and pastured poultry.

The indoor stocking densities tie into the proposed change in measuring ammonia levels in the house. APPPA and its board routinely cite 10ppm and 25ppm as the warning levels of ammonia exposure. At ammonia levels of less than 10ppm the birds’ ciliary function and immune system are negatively affected and at 25ppm, the level at which the human nose can detect ammonia, there is already damage being done to humans and animals - creating welfare problems for the poultry and the people. Ammonia exposure is non-existent in a well-managed pasture rotation.

Stocking density will affect the ability to keep the bedding dry and keep ammonia levels down. For example, market age Cornish cross broilers stocked at approximately one square feet per bird (5 pounds per square foot) will require constant bedding management in order to keep the ammonia levels under dangerous levels. Decreasing the stocking densities for all the poultry species will not only provide a low stress living environment that doesn’t require beak trimming, it will provide a way for all producers to manage ammonia levels.

With regard to indoor confinement, APPPA recommends:

1. Organic production requires natural sunlight to enter the indoor living space.
   
2. The final rule promotes lower stocking densities as a means to lower the viral load in the house and thereby reduce the risk of disease as stated by the USDA.
   
3. AMS should maintain the proposed ammonia standards and further clarify the standards by requiring ongoing measurement of the ammonia levels (e.g., ammonia test strips). The human nose is not sufficient to reliably detect dangerous ammonia levels.
   

Slaughter

In terms of slaughter, APPPA believes strongly that the PPIA poultry processing exemptions need to be maintained for all poultry producers, including pastured and organic flocks. USDA should remove obstacles to make exempt processing more accessible to more producers. Many beginning farmers turn to pastured poultry production as their inaugural farming venture, but access to adequate processing is an obstacle that needs to be addressed. There is a lack of accessible inspected processing facilities throughout the United States; the poultry processing exemptions allow farmers to test poultry markets and businesses and to serve direct markets in a way that wouldn’t be possible without the exemptions.

Limited access to legal processing options that enable farmers to move their products in open commerce is a competitive disadvantage. Ambiguity and misinterpretation of the poultry processing exemptions at the federal, state, and local levels of government suppresses the growth of small businesses that want to raise pastured poultry, which also affects independent producers who want to be organically certified.

Some of the proposed slaughter requirements make sense and should be obvious. Specifically, not scalding live birds or shackling lame birds is sound welfare guidance. However, APPPA would like to state emphatically that humane poultry slaughter is not synonymous with stunning or controlled environmental suffocation. Stunning, especially when automated at high speeds, has the potential to be one of the most inhumane actions possible. Otherwise, AMS would not need to codify common sense welfare positions, such as only scald dead birds and don’t hang lame birds by their legs on high speed shackle lines.

The proposed standard mentions that small producers are permitted to use killing cones and non-stunning exsanguination. The use of killing cones and exsanguination should be allowed in all poultry slaughter operations, including organic and at all size operations. APPPA would like to see the organic standards unequivocally reflect an acceptance of the use of killing cones and exsanguination without stunning regardless of facility size.

With regard to poultry slaughter, APPPA recommends:

1. The federally regulated poultry processing regulations remain as a legal and acceptable option to put birds into commerce for all types of poultry producers, including pastured and organic.
   
2. Slaughter not be limited to stunning and include other methods, such as the hand slaughter of birds in killing cones by way of exsanguination.
   

Summary

In closing, APPPA applauds this effort and strongly emphasizes the need to clarify the distinctions of pastured poultry. As the welfare realities of pastured poultry production and the minimum standards of organic poultry production draws closer, we are confident that more pastured poultry producers will find value in organic certification, especially in lieu of lesser known, competing third-party welfare programs. We are available to help provide a pastured perspective, as needed (grit@apppa.org or 888-662-7772).