The recent proposal by the National Organic Program to impose extensive outside access requirements on producers does not appear to have any scientific basis. There is a
perception that the proposal to require an as yet undefined area of outside access is a thinly veiled attempt to restrict marketing of NOP certified eggs to small flocks. Large-scale producers who have invested extensively in aviary housing installed in in-line complexes will be disqualified since they will not have sufficient space to accommodate the proposed requirements.

The question arises as to whether the National Organic Program has any justification to establish welfare standards which have no bearing on the organic status of feeding, quality or handling or identification of product. The American Humane Association Certified Farm Animal Welfare Program has established standards for aviary, confined-floor and free-range systems. These specific standards were developed by a panel of scientists with extensive knowledge and experience in aspects of welfare. The program has drawn heavily on the EU LayWel program, which is science-based and represents an impartial approach to establishing standards of welfare and well being for flocks.

The proponents of the proposed NOP space requirements might be interested in the article by Stokholm et al of the University of Copenhagen, dealing with mortality rates in Denmark for flocks housed under alternative housing systems [Stokholm et al. Causes of Mortality in Commercial Egg Layers in Denmark. Avian Diseases. 54:1241-1250 [2010]. This peer-reviewed publication recorded the results of a longitudinal study of mortality in free-range organic layer flocks, confined flocks and incorporated historical data on cage housing as a comparison. Fifteen organic flocks from 11 farms with flock sizes ranging from approximately 2,200 to 6,000 layers were followed from 2001 to 2003, from transfer at 18 weeks to depletion at 70 weeks of age.

Flock mortality on free-range extended from 2% to 91% during the review period. When the two flocks with the highest mortality were excluded from the comparison the average mortality was 12%. In comparison, flocks confined to barns on deep litter averaged 7% mortality with a range of 2% to 16%. Corresponding data for the period 1995 to 2007, prior to the banning of cages in Denmark, showed a range of mortality of 4 to 6% in caged flocks.

The principal causes of mortality included cannibalism, which can be effectively suppressed by appropriate beak trimming, disallowed after 10 days according to NOP requirements. In the flocks with exceptionally high mortality, infections associated with free-range housing included pasteurellosis, erysipelas and histomoniasis. The last two infections were common under free-range conditions in the U.S. poultry industry prior to the adoption of confined housing in the 1950s. If the proponents of outmoded, inefficient, primitive and retrograde systems of production insist on reversion to practices reflecting pre-WWII systems, livability will be compromised with no tangible benefit to consumers in terms of nutritional content or the welfare of flocks.

The administrators of the National Organic Program should carefully ponder the possible consequences of their intended welfare and space requirements. The results could be devastating to the organic egg industry since produces adhering to the new regulations will be faced with additional costs which will drive up the retail price of eggs to a level that would ensure consumer rejection. The large-scale producers of organic eggs under current regulations would either convert to cage-free production or develop a new branded category, outside the NOP, to satisfy demand for a product from hens fed organic feed with an assurance of freedom from pesticides and non-organic additives.