Deadline for submitting comments is August 31, 1999. To submit comments, contact the Organic Trade Association at 413- 774-7511. OTA website: www.ota.com. OTA has a submission form that must accompany Comments.

Karen Davis' Letter to OTA follows:

American Organic Standards August 23, 1999
c/o Organic Trade Association
PO Box 1078
Greenfield, MA 01301

Comments Submitted by Karen Davis, PhD

As president of United Poultry Concerns, I appreciate this opportunity to submit comments on the Organic Trade Association's American Organic Standards. United Poultry Concerns is a 501(c)(3) national nonprofit organization incorporated in the state of Maryland. We address the treatment of domestic fowl in food production, science, education, entertainment, and human companionship situations. We promote the compassionate and respectful treatment of domestic fowl.

Comments on the American Organic Standards, Draft 2 Re: Section 6.7.6.1 and Section 6.7.6.2, pp. 64-65. Section 6.7.6.1, page 64: Physical alterations must be conducted for the animal's ultimate benefit, and these practices shall be administered in ways that minimize pain and stress. Response: It has sometimes been claimed by livestock and poultry producers that mutilations such as toe clipping and debeaking of poultry are conducted "for their own good." This claim does not represent good welfare practice. Such mutilations are a response to problems that can occur in pathogenic systems in which foraging birds are unnaturally housed in crowded confinement buildings or are kept in crowded, sterile, pathogen- and feces- filled yards in which chronic stresses including boredom manifest themselves in distorted avian behavior patterns. The birds are mistreated first by being placed in systems that frustrate their natural interests and activities, and secondly by having various parts of their bodies cut off in order to accommodate these systems. The mutilations may be rationalized as "for the animal's own good." However, if birds and other animals must be mutilated in order to live in human-created systems, the systems themselves are wrong and must be reformed or eliminated.

Section 6.7.6.2.A (1-4), pp. 64-65. "Beak trimming of poultry." Beak trimming should be prohibited in the American Organic Standards. Before proceeding, I wish to state that I have maintained a sanctuary for chickens of all kinds including "broiler" chickens, leghorns, bantams, barred rocks, Rhode Island Reds, "Golden Comets," and others since 1987. Feather pecking has never been a problem in our 100+ flock whose members range by day in a large, grassy fenced 150 sq ft yard with shady bushes during the day and are locked in predator-proof buildings at night. In my experience, feather pecking has been a problem only when there were too many roosters per number of hens, particularly "broiler"-type hens. The problem is a function of mating in which the roosters hold down hens partly by using their beaks. However, people who keep poultry for production are not likely to maintain "too many roosters."

Many of our chickens derive from production agriculture and were debeaked as chicks at the hatchery. Chickens we have obtained range from having semi-intact beaks to having only nubs were the beak originally was. The point is that the debeaking operation is haphazard and uncontrollable. Guillotining the beaks off tiny chicks is a hit and miss operation that may slice the beak almost completely off, slice off part of the chick's tongue, etc. For this reason alone, mutilation of the sensitive organ whereby birds constitute themselves by eating and drinking should be prohibited. It should be prohibited as well because it disfigures the bird's face as well as causing pain and suffering. By "pain" I refer to the sensation of bodily injury. By "injury" I refer to the sustaining of a wound that may or may not be technically experienced as pain. Such injuries (insults, traumas, harms) may manifest themselves subjectively as discomfort, distress, depression, and incapacity as well as pain. All of these have been identified with the inhumane practice of "beak trimming," i.e. debeaking.

Debeaking causes acute and chronic pain and suffering

"There is now good morphological, neurophysiological and behavioral evidence that beak trimming leads to both acute and behavioral evidence that beak trimming leads to both acute and chronic pain. The morphological evidence is that the tip of the beak is richly innervated and has nociceptors or pain receptors. This means that cutting and heating the beak will lead to acute pain. In addition, it has been shown that as the nerve fibers in the amputated stump of the beak start to regenerate into the damaged tissue, neuromas [tumors] form. Neuromas are tiny tangled nerve masses that have been implicated in phantom limb pain (a type of chronic pain) in human beings.

"The neurophysiological evidence is that there are abnormal afferent nerve discharges in fibers running from the amputated stump for many weeks after beak trimming--long after the healing process has occurred. This is similar to what happens in human amputees who suffer from phantom limb pain.

The behavioral evidence is that the behavior of beak-trimmed birds is radically altered for many weeks compared to that which occurs immediately before the operation and compared to that shown by sham-operated control birds. In particular, classes of behavior involving the beak, namely feeding, drinking, preening and pecking at the environment, occur much less frequently, and two behavior patterns, standing idle and dozing, occur much more frequently. The only reasonable explanation of these changes is that the birds are suffering from chronic pain." Ian Duncan, The Science of Animal Well-Being, rpt from Animal Welfare Information Center Newsletter, 1993. National Agricultural Library 4.1 (Jan-March):5.

"Close examination of filmed feeding activity . . . showed that beak trimmed birds were not able to grasp feed pellets as efficiently as intact birds. The results of these studies of ingestive behavior and the associated observations of decreased feed usage and depressed weight gains leave little doubt that a reduction in the bird's ability to consume feed, and possibly water, occurs as a result of trimming" (131). Dan L. Cunningham, Beak-Trimming Effects on Performance, Behavior and Welfare of Chickens: A Review, Journal of Applied Poultry Research 1 (1992):129-134.

"The main injury caused by humans, knowingly rather than accidently, is beak trimming. It is now known to cause pain, in the short term and probably also in the long term, in a way similar to other amputations" (20).

Michael C. Appleby, Do Hens Suffer in Battery Cages? A Review of the Scientific Evidence Commissioned by the Athene Trust. Institute of Ecology and Resource Management, 1991. University of Edinburgh.

"There is no physiological basis for the assertion that the operation is similar to the clipping of human finger nails. Between the horn and bone [of the beak] is a thin layer of highly sensitive soft tissue, resembling the quick of the human nail. The hot knife blade used in debeaking cuts through this complex horn, bone and sensitive tissue causing severe pain." R.W.R. Brambell, Report of the Technical Committee to Enquire into the Welfare of Animals Kept Under Intensive Livestock Husbandry Systems, 1965. Command paper 2836 London: Her Majesty's Stationery Office, 1965, par. 97, p. 26.

Why would chickens or other domestic fowl be driven to peck at each other? What is the link to the welfare insult of debeaking?

Chickens, turkeys and other gallinaceous (chickenlike groundnesting birds) are foragers with a strong urge to explore. Pecking, scratching, and exploring the ground is how they get their food. Their beak serves as both hand and mouth for them. They exhibit a genetic need to peck even when food is provided for them. Chickens, turkeys, ducks and other birds use their beaks also to preen and dustbathe. Preening and dustbathing are how these birds practice bodily hygiene including the removal of dander and old skin oils and the maintaining of good feather structure and plumage, just as humans shower and bathe with water and brush their hair in order to maintain the health of skin and hair, remove dirt, old oils and dandruff, and prevent lice and other external parasites from attacking. Debeaking impairs or prevents the performance of bodily hygiene in birds.

The onset of destructive feather pecking and other beak- related behavioral distortions in chickens is described on pages 222 and 233 in American Poultry History 1823-1973. It is noted that pathological behaviors such as feather pecking began when chickens were taken off the ground, crowded, and confined. Based on the evidence, the government advisory Farm Animal Welfare Council in Britain declared in its 1991 Report on the Welfare of Laying Hens in Colony Systems that debeaking is "a serious welfare insult [injury, trauma] to the hens" that "should not be necessary in a well-managed system where the hens' requirements are fully met" (London: MAFF Publications, Dec 1991:23-24).

Poultry researchers attribute abnormal beak-related behaviors to a variety of causes. For example, chickens will peck the feathers of cage mates in order to obtain protein and other nutrients they would normally find on range but cannot obtain to meet their individual needs in fixed rations. Mash increases the problem because the birds can't select specific nutritional components from it. Debeaking makes this problem even worse.

Chickens can be driven to peck at each other as a result of their inability to dustbathe. Studies conducted by Klaus Vestergaard have shown that hens deprived of dustbathing materials suffer from "an abnormal development of the perceptual mechanism responsible for the detection of dust for dustbathing." Deprived of loose, earthlike materials, chickens "are more likely to come to accept feathers as dust" (Animal Behaviour 45 [1993]: 1127-1140).

Vestergaard has shown also that fear is not only a result of pecking at cage mates, but a cause of it: "[T]he peckers are the fearful birds, and the more they peck the more fearful they are. This finding emphasizes abnormal behaviour in the evaluation of wellbeing in animals which have no obvious physical signs of suffering."

Conclusion

However, as a husbandry practice, debeaking cannot be justified. Dr Lesley Rogers explains in The Development of Brain and Behaviour in the Chicken that in the beak-trimmed bird, "The re-shaped beak appears to be inappropriate for food and mandibulation and food intake is reduced. Also, the re-shaped beak may be less able to provide tactile, proprioceptive and even taste rewards. These considerations raise both ethical and practical concerns about the practice of beak trimming. Feed efficiency is reduced by beak trimming because the birds either fail to grasp the food pellets or do not transfer them to the pharynx for subsequent swallowing, but the stereotyped pattern of pecking is not altered by beak trimming. It is as if the operation causes something akin to the phantom limb effect which occurs in humans following the loss of a limb" (p. 98). Lesley J. Rogers, The Development of Brain and Behaviour in the Chicken, Wallingford, Oxon, UK: Cab International, 1995. Supplemental Materials

I am enclosing reports by United Poultry Concerns on the forced molting of poultry and on the use of contact lenses lest these extremely inhumane practices should be misrepresented as "humane." I am enclosing my book Prisoned Chickens, Poisoned Eggs: An Inside Look at the Modern Poultry Industry which has information about the behavior of chickens beginning with embryonic development; and Laying Hens: 12 years of experience with new husbandry systems in Switzerland, a Report of the poultry working group of the Swiss Society for the Protection of Animals.

Karen Davis, PhD
President
United Poultry Concerns