This letter is in response to the USDA news Release No. 0212.98 entitled:
USDA, FDA EXPAND EFFORTS TO ENSURE EGG SAFETY.
Please send the USDA your comments! Comments
will be accepted until August 18, 1998
June 16, 1998
Docket Clerk
Docket No. 96-035A
Room 3806 South Agricultural Building
1400 Independence Avenue, SW
Washington, DC 20250-3700
The Comments of United Poultry Concerns on
Preventing the Introduction of Salmonella enteritidis
in Laying Chickens
United Poultry Concerns, Inc. is a 501(c)(3) non-profit
organization that addresses the treatment of domestic fowl in
food production, science, education, entertainment, and human
companionship situations. United Poultry Concerns promotes the
compassionate and respectful treatment of chickens and other
domestic fowl.
Introduction
United Poultry Concerns welcomes the joint effort by the
U.S. Food & Drug Administration and the U.S. Department of
Agriculture to establish a farm-to-table strategy affecting the
treatment of hens used for egg production, based on the fact
that, as stated in the Federal Register Proposed Rules, May 19,
1998, Salmonella enteritidis infected flocks have become
prevalent throughout the country.
While the handling of eggs no doubt contributes to the
incidence of foodborne illness, handling per se does not generate
Salmonella enteritidis. Poor handling--"product abuse"--can only
multiply the salmonellae that are already in the egg, reflecting
the pathogenicities--the disease-causing complex of animal
abuses--to which the birds who lay them are subjected. Cleaning
of contaminated layer houses is virtually impossible (Beard &
Gast 36). Conditions at the farm level have been shown to
debilitate the hens' immune response, causing disease organisms
to enter into the formation of their eggs (Beard & Gast 32).
Chronic stress
Chronic stress weakens the birds' immune response, inviting
primary and secondary pathogens to colonize their systems.
Chronic stressors to which hens used for egg production are
subjected include concentrated excretory ammonia gases (Carlile
101) and the frustration of basic hygienic behaviors, in
particular, dustbathing (Vestergaard 10; Rogers 221). Caging,
crowding, debeaking (Riddell 827-828), and antibiotics (Fowler 9;
Evans n.p.) debilitate the birds' immune systems. Artificial
light-dark manipulations (Smith 5) and forced molting--the
deliberate starvation of hens for days and weeks at a time--
(Holt; Mason) promote Salmonella enteritidis in laying hens.
Overall, the "stresses of high production and high stocking
density" (Hooge 14) are so severe and overwhelming as to
compromise the health and well-being of the birds. Fundamental
improvements in husbandry practice and attitudes are needed.
Concentrated caged confinement
Microbiologist John Avens says that "Salmonella infection of
animals will occur more frequently and affect more individual
animals, as concentration of confinement increases" (122). The
concentrated confinement of laying hens is such that 97.8 percent
of hens laying eggs for human consumption in the United States
are in cages so densely packed that the individual 3-to-4-pound
bird has only 48 square inches of total living space (Bell 37;
Hooge 29). The hen cannot assume a single normal body posture
(Baxter 617). Locked in a state of unrelieved suffering and
stress which includes the polluted air from the proximity of so
many equally stressed hens, the hen is a prey to disease. Avian
physiologist Lesley J. Rogers states that:
Chickens in battery cages are cramped in overcrowded
conditions. Apart from restricted movement, they have few or
no opportunities for decision-making and control over their
own lives. They have no opportunity to search for food and,
if they are fed on powdered food, they have no opportunity
to decide at which grains to peck. These are just some
examples of the impoverishment of their environment. Others
include abnormal levels of sensory or social stimulation
caused by excessive tactile contact with cage mates and
continuous auditory stimulation produced by the vocalizing
of huge flocks housed in the same shed. Also, they have no
access to dustbathing or nesting material. Chickens
experiencing such environmental conditions attempt to find
ways to cope with them. Their behavioural repertoire becomes
directed towards self or cage mates and takes on abnormal
patterns, such as feather pecking and other stereotyped
behaviours. These behaviours are used as indicators of
stress in caged animals. (Rogers 219)
Rogers states categorically concerning the battery cage
system of housing hens, "In no way can these living conditions
meet the demands of a complex nervous system designed to form a
multitude of memories and to make complex decisions" (218).
Forced Molting
Forced molting is a stressor that has been found to depress
the cellular immune response and increase the severity of a
concurrent intestinal Salmonella enteritidis infection, creating
a disease state in the alimentary tract of force-molted hens
(Holt & Porter 1842). Dr. John Mason told a joint FSIS/FDA
conference on November 20, 1996, that forced molted hens lay many
more eggs that contain Salmonella enteritidis. Furthermore,
force-molted hens are driven by their hunger to pluck and eat
each others' salmonella-contaminated feathers in order to obtain
nutrients (Riddell 828; Holt 1995:248). The spread of Salmonella
enteritidis to and among the hens is amplified as a result of
their consumption of contaminated feathers (Holt 1995:248).
Rodents
Rodents also transmit Salmonella enteritidis. Forced molting
facilitates the multiplication of salmonellae through the
contaminated feces of the rodents that live in the caged layer
houses. At night, mice eat the hens' food in the trough where
they deposit an average of 100 fecal pellets per mouse in a 24
hour period. These contaminated fecal pellets are the first thing
consumed by the hens when the lights are turned on in the morning
(Beard & Gast 35; Holt 1993:416-417).
Conclusion: The Suffering and Sickness are Linked
While the issue at hand is Salmonella enteritidis, this
pathogen does not occur in isolation; rather it is one part of a
whole complex of diseases of caged laying hens, including
immunosuppression, heat prostration, chronic respiratory disease
(CRD), osteoporosis, cellulitis, viral tumors, fungal mouth
ulcers, fatty liver syndrome, airsacculitis, and much more--a
range of human groundwork production pathologies (Davis 56-61,
72-73). Disease organisms emerge and will continue to flourish
and evolve in the inherently filthy, crowded, stressful, inhumane
environment that the majority of chickens in the United States
are condemned to live and lay their eggs in.
Recommendations
- The U.S. Department of Agriculture should establish and
rigorously enforce regulatory authority over husbandry practices
at the farm level of both hatching and commercial egg production.
- The USDA and the FDA should prohibit the forced molting of
laying hens, based on the evidence that this cruel practice leads
to Salmonella enteritidis in the birds, eggs, and consumers.
- The United States needs to join the European Union, Great
Britain, Australia, Switzerland, and Sweden in acknowledging that
the current methods of housing and treating chickens used for egg
production are inhumane. The cruelty and contamination are linked
via the hen's immune system. The prevalence of Salmonella
enteritidis in U.S. laying flocks is a good example. It is time
for the United States government to employ its skills and
resources in the service of a husbandry system that incorporates
the needs and well-being of the birds--their need to perch,
dustbathe, exercise their bodies, breathe fresh air, and to eat
and preen with an intact beak. The Department of Agriculture
should establish a regulatory leadership role that combines
genuine standards of humaneness and health for the birds,
starting with the prohibition of debeaking and forced molting,
and the implementation of a cage-free housing system. The Food
and Drug Administration should prohibit the practice of forced
molting, a vicious practice which causes suffering,
contamination, and disease (United Poultry Concerns).
Works Cited
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