The Cornucopia Institute, based in Wisconsin, has issued a report Scrambled Eggs: Separating Factory Farm Egg Production From Authentic Organic Culture. The major issue raised in the report relates to outside access by flocks. Many existing producers of organic eggs restrict their flocks to the interior of houses, since they do not have sufficient pasture space or, in some cases, have no provision for outside access.

Economic and practical considerations have led to the concentration of organic egg production among a relatively small number of efficient producers using aviaries and “sun porches,” as in the European Union. Some of these complexes can house up to 500,000 hens. These volumes are required to satisfy the current demand of supermarket chains that require consistency of supply, large volumes, stable prices and SQF certification.

When the original National Organic Program (NOP) requirements for egg production were developed, it was not envisaged that large producers would commoditize organic eggs. The current move to increasing outside access is effectively “moving the goal posts.” There is no scientific evidence that access to pasture in any way improves the nutritional value of eggs.

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It is also accepted that outside access may increase the risk of exposure to diseases, such as avian influenza and Newcastle disease which may be carried by migratory and free living birds. Flocks allowed outside access have higher susceptibility to parasites and bacterial infections including salmonellosis, pasteurellosis and erysipalis.

If the NOP adopts the 1.5- to 2.5-square-foot standard for outside access the production of eggs under the organic program will be seriously curtailed, resulting in extreme increases in retail prices to levels estimated to exceed $6 per dozen. This will effectively limit purchases to a small segment of consumers.

The demand for organic eggs will be filled by a new category of product which is fed according to the current Organic Rule, following guidelines for stocking density and other management requirements. This product would not be eligible to carry the U.S. Department of Agriculture-NOP Organic Seal but would retail at the current $4 per dozen.