The National Chicken Council (NCC) recommends revising or clarifying several key aspects of the proposed rule from the National Organic Program (NOP), announced in April, to enhance bird health, protect food safety, and maintain a viable organic program.
"NCC is concerned that the proposed rule imposes unreasonable costs and requirements of doubtful benefit on organic farmers, presents grave risks to animal health… and undermines ongoing international efforts to develop poultry welfare standards," said Ashley Peterson, Ph.D., NCC senior vice president of scientific and regulatory affairs, in comments submitted July 13 to the U.S. Department of Agriculture.
Mortality rate concerns
The proposed standards are assumed to increase the mortality rates for laying hens and broiler chickens from 5 to 8 percent, a 60 percent increase. Mortality rates are a key indicator of animal welfare and flock health, yet the proposed changes, according to NCC, would increase mortality, significantly decreasing bird welfare and farmer economic viability.
The proposed standards are also in direct opposition to Animal and Plant Health Inspection Service (APHIS) recommendations for biosecurity, NCC believes. In light of the recent, devastating outbreak of highly pathogenic avian influenza (HPAI), it is vital farmers retain the ability to make timely preventive measures to protect their flocks. Under the current proposed rule, a "documented occurrence of a disease in the region or relevant migratory pathway must be present before outdoor access can be restricted," with unclear definitions of what constitutes a region or documented occurrence.
Potential cost to producers
Peterson also noted the proposal drastically underestimates, or neglects to estimate, the cost of the requirements and the impact of those costs. "NOP does not include the cost of an avian illness outbreak, the likelihood and magnitude of which is materially increased through the proposed outdoor access requirement." In other words, avian illness outbreaks like the 2015 HPAI outbreak will be more likely to occur, and the effects will be more likely to be greater, under the proposal. The direct economic consequences of the 2015 HPAI outbreak were estimated to be approximately $3.3 billion, far overshadowing the anticipated maximum benefit of $62.6 million per year in the proposed rule.