New organic standards proposed
The Accredited Certi;ers Association has drafted a guidance document for organic poultry production. The intent
is to codify space requirements which will
conform to EU standards. The National
Organic Standards Livestock Committee
is scheduled to revisit these certi;cation
standards which are based on “natural behavior of animals.”
The proposals include the following requirements:
✔Access to dust baths or litter,
✔Areas of retreat in both houses and outdoor areas,
✔Perches for layers,
✔A minimum of 30% of the area of ;oor
houses must comprise litter,
✔Suf;cient exit area along the walls of
houses to allow outside access.
The guidance document speci;es “an
area equal to ten linear feet per thousand
square foot of house space.” Since the terms
“area” and “linear feet” are inconsistent it is
assumed that the vertical and horizontal dimensions of the openings provided, should
amount to 10 linear feet per 1,000 square
feet of ;oor area.
density of 1. 8 square feet/hen. The outside
area would extend 75 feet from the long
wall of the house to provide 30,000 square
feet for the ;ock. This would restrict the
number of houses per farm and prevent existing and proposed in-line and multi-house
;oor and aviary units from complying with
organic requirements.
The proposed standards also state that
birds must not be con;ned to houses due to
a threat of an outbreak of disease. Con;ne-ment is permitted if there is a documented
occurrence of a disease in the region or migratory pathway or in the event of a state or
federal advisory. Producers must also “
identify how they plan to protect birds from disease and predators.”
timately destructive to the U.S. organic egg
production sector and the certifying agencies
without producing any tangible bene;ts in
terms of welfare, food safety or consumer
satisfaction.
It is inevitable that if the suggested standards are adopted, existing commercial producers of organic eggs may develop a new category of product based on organic feed, drug-free
systems, high standards of hygiene and safety
which are not currently addressed in the NOP
requirements. Although these eggs will not
be eligible for the “USDA Organic” logo, the
product will be available in suf;cient quantity
and at a price which satis;es demand. An educational campaign for consumers and the support of the supermarket and institutional sectors for a wholesome egg product conforming
to existing organic production standards will
be required. USDA-Certi;ed organic product
For more information on the
Accerdited Certifiers Association,
their practices and potential mem-
bership, visit them on the Web at:
www.accreditedcertifiers.org
12 • Industry Egg • August 2009 • www.WATTpoultry.com
Floor requirements
The most important restrictions in the
proposed standards relate to ;oor area:
✔Indoor ;oor space: 1 square foot/pullet
and 1. 8 square feet /laying hen,
✔Outdoor runs: 2 square feet/pullet and
2. 7 square feet/per laying hen.
Using a typical converted broiler breeder
house or a purpose-constructed slat-and-lit-ter ;oor house 400 feet by 50 feet in extent,
the ;ock would comprise 11,111 hens at a
Organic impact
The proposed standards, based on EU
requirements will clearly impact
commercial-scale production of organic eggs. The National Organics
Standards Board was unable to state
or justify a speci;c area requirement
when the regulations were originally
established, allowing domination of
organic egg production by commercial farms responding to free-market
supply-and-demand considerations.
Should organic egg production be seriously
curtailed over the ;ve-year period of implementation of the suggested standards, major
food distributors and retailers will be unable
to obtain adequate and regular supplies of
product. The cost of production would escalate further curtailing demand. Organic egg
production will contract to a group of small-scale producers supplying local outlets.
Current family-owned and corporate producers of organic eggs will revert to cage-free
status based on their existing investment in
housing and facilities which may range from
$15-20 per hen for converted housing and
as much as $35 per hen for advanced aviary
installations. The proposal to extend space
requirements and especially outside access
without any scienti;c justi;cation will be ul-
will revert to the mom-and-pop producers with
limited resources, and possibly questionable
food safety. To justify the proposed regulations
on the basis of “harmonization with the EU or
Canada” is fallacious since there is no trade
in organic eggs within NAFTA or to the EU.
Given the proposed regulations future exports
would appear even more remote.
There is an obvious need for common
sense in the selection of standards and
evaluation of organic requirements and the
design of future production systems. Standards should take into account science-based
practices and economic realities. Certifying
agencies and the NOP should assess the
impact of “moving the goalposts” after an
industry has been created and investment
committed to a market segment. EI
