Biofuels Contribute to Excess Evolution of Carbon Dioxide

Dec 9, 2016


The intent of the U.S. Biofuels Program initiated by Congress in 2005 to establish energy independence has proven to be deleterious to the environment. Applying “national interest” and environmental considerations to bolster intensive lobbying from proponents of corn-based ethanol, Congress progressively extended the Renewable Fuel Standard from 7.5 billion gallons of ethanol to be blended into gasoline by 2012 to 15.4 billion gallons in 2015.


A recent study conducted by Dr. John DeCicco, a research professor at the University of Michigan rebuts the environmental benefits from corn-based ethanol.  The study took into account the reduction in atmospheric carbon dioxide associated with cultivation of corn on all farms in the U.S. Corn removes approximately two tons of carbon dioxide per acre during a growing season.  Total reduction of carbon dioxide by U.S. farmland cultivating corn amounted to 49 teragrams (49 million metric tons) of carbon dioxide.

DeCicco calculated the release of carbon dioxide associated with cultivation of corn including fuel, fertilizer and other inputs, in addition to the carbon dioxide released from the fermentation production of ethanol and the burning of ethanol added to gasoline at a rate of 10 percent.  The evolution of carbon dioxide amounted to 132 teragrams meaning that only 35 percent of biofuel-related carbon dioxide emissions from 2005 through 2013 were offset by the program of biofuel production from corn.

Given the availability of natural gas and oil from newly discovered fields and the application of fracking the question of energy independence has been largely resolved. This is especially the case now that the U.S. is exporting both oil and gas. The second justification for the biofuels program relating to environmental advantages has also been scientifically discredited. 

The Renewable Fuel Standard persists as a manifestation of political expediency benefiting farmers in corn states and ethanol producers to the detriment of consumers.  Ethanol from corn was intended as a stopgap measure until fuel could be produced from biomass.  Despite investment of billions of dollars in projects, fuel from biomass has proven neither practical nor financially viable leaving a Congressionally-mandated program as a gift to vested interest and as an environmentally unacceptable alternative.


DeCoster Appeal Important to Food Industry Executives?

Oct 28, 2016


Quality Egg, an oxymoronic name for a commercial entity owned by Austin “Jack” DeCoster, pleaded guilty to three charges arising from the 2010 outbreak of Salmonella Enteritidis. 

The charges included a felony violation for bribing a U.S. Department Agriculture inspector, a felony violation for introducing misbranded eggs into interstate commerce with the intent to defraud and mislead and a misdemeanor violation for introducing adulterated eggs in to interstate commerce. 


The company paid fines approaching $7 million for the three guilty pleas.  “Jack” DeCoster and his son Peter pleaded guilty to misdemeanor violations as responsible corporate officers.  In addition to a token fine, the defendants were sentenced to three months imprisonment.

The basis of the appeal against the prison term to the 8th Circuit Court was based on the representation that they had no prior knowledge of SE contamination of flocks in their Wright County, IA complexes.  The sentence was however upheld by the 8th Circuit Court in July and the defendants have appealed to the Supreme Court. 

The Court has not yet ruled on whether it will hear the case which has profound implications for executives of food companies involved in disease outbreaks.  This is especially of importance since the Department of Justice has adopted a more aggressive attitude towards individuals at various levels of management within companies responsible for foodborne disease events.

Of interest to the egg production industry is the assertion by the DeCosters that they had no knowledge of SE contamination prior to traceback of the outbreak which was responsible for approximately 50,000 cases of SE. Given the evidence concerning the duration over which SE was present in Wright County flocks the DeCosters should be gratified that the Court accepted their assertions of ignorance and did not impose the possible one-year imprisonment option.

Readers of EGG-CITE can contemplate the probability that the DeCoster’s were “ignorant” of the presence of SE in their flocks and their apparent lack of awareness of the proven effects of prolonged storage, possibly with thermal abuse, on proliferation of SE within eggs, as these factors relate to possible infection of consumers.


Has Ketchum Got it Right?

Oct 14, 2016


An October 9th report in Food Business News reviewed a presentation to the North American Millers Association on September 9th by Linda Eatherton, Managing Director and Partner in the Global Food and Beverage Practice at Ketchum, a multinational public relations organization. The subject of Ms. Eatherton’s presentation was Food eVangelists whom she maintains comprise an influential a group of activists using the social media to demand changes in food industry practices and products.

Ketchum regards Food eVangelists as “passionate, change agents and leaders in the community”. This is an understandable but narrow appreciation from the perspective of a public relations professional and may overstate the influence of this category of manipulators of the social media.


From a broader and more real-world view from walking food store floors and analyzing recent quarterly reports of supermarket chains and retailers it is evident that consumers are focused on price rather than the issues raised on the internet by activists. This is denoted by the rise in importance of house brands, market gains by deep discount retailers and aggressive but belated price promotions by traditional store chains. Secondary and lesser attributes motivating purchase decisions include safety, taste, quality and presentation.

Shoppers buy their produce, groceries and refrigerated items at the supermarkets and stores of their choice often splitting their purchases according to price, perception of value and availability. If they do not find the products they want in a store they select an alternative house or national brand or buy elsewhere. This is a relatively easy option given proximity of competing stores and mobility.

The reality we are seeing from the social media is less an “army” of concerned consumers attempting to influence choices than a core of semi-professional representatives of activist organizations or even paid bloggers, with a vested interest in creating concern and anxiety where there is nothing to fear. 

Many of the websites, blogs and tweets emanate from avowed environmentalists, animal rights activists, and others who are not representative of the broad base of consumers.  In many cases activist organizations have less to do with the cause they purport to represent than a preoccupation with raising funds and creating job security for themselves.

Implicit in the presentation by Ms. Eatherton is the message that individual food manufacturers and distributors require professional help with their public relations and Ketchum is just the organization to assist with countering an obviously exaggerated situation.  Appeasing activist organizations offers no solution since concessions invariably result in subsequent demands.  There is no army of Food eVangelists, but there are agents of organizations with agendas which are contrary to intensive agriculture and processed food.  These groups make use of individuals selected for their ability to develop a disproportionate megaphone through the social media. 

Direct response to posts and attempts at countering criticism are generally unproductive.  Proactive publicity coupled with eschewing obviously unacceptable livestock practices, eliminating undesirable additives and components is far more productive than attempting to placate critics. Perhaps this is where a professional PR company can assist. The food producers and distributors have first to put their respective houses in order otherwise counsel from a specialist PR company, promotional posts and advertisements rise to the level of putting lipstick on a pig.



Oct 7, 2016


EGG-CITE has previously reported on cases of Salmonellosis associated with the backyard chicken movement.

From 1990 through 2005 only one outbreak of salmonellosis was recorded by the Centers for Disease Control and Prevention (CDC) from backyard chickens.  From 2005 to 2014 the incidence rate increased to four outbreaks annually.


From 1990 to 2014 the CDC reported 53 outbreaks of confirmed salmonellosis attributed to live contact with poultry, responsible for 2,600 illnesses, 387 hospitalizations and 5 fatalities.Investigations have demonstrated that 60 percent of patients had been exposed to immature poultry of which 74 percent occurred in a home.

The CDC identified inappropriate practices which bring poultry into intimate contact with owners of chickens and especially children. These included snuggling baby birds (49 percent reported) or kissing baby birds (13 percent of patients).  Approximately 46 percent of patients admitted that live poultry were allowed access to homes including the living room (22 percent) and bedrooms (10 percent).  It is considered significant that most of the cases investigated involved ownership of chickens for less than a year.

In recent years, a specific male-order hatchery specializing in exotic breeds and supplying the backyard market has been responsible for many outbreaks of salmonellosis acquired from chicks. This source of numerous infections bears the oxymoronic name of Mt. Healthy Hatcheries in Ohio.www.mthealthy.com. This enterprise has been frequently implicated in trace-back investigations by the CDC.

As with turtles, iguanas and snakes which have the potential to carry Salmonella, chickens make inappropriate pets, especially for children. 

Basher, C. et al. Outbreaks of Human Salmonella Infections Associated with Live Poultry, United States, 1990-2014. Journal of Emerging Infectious Diseases. In press October 2016.

On line pre-publication DOI: 10.3201/eid 2210.150765 October 2016



Sep 30, 2016


Janice Dale writing in Delmarva Now on August 27th encapsulated the inherent conflict between traditional and long standing hog and poultry farming operations and residents moving from city suburbs to enjoy a rural lifestyle. This trend is evident on the Maryland Eastern Shore which has a high concentration of broiler productions.


New residents seek an idyllic existence free of odors, vehicle traffic and any factor which could detract from their perception of pristine agriculture.

The reality is that land and water are limited resources and there are mouths to be fed both in the U.S. and in developing nations, which represent our export market.

At the offset it must be recognize that intensive livestock production is more sustainable than less concentrated alternatives and is infinitely more productive in terms of resources applied.  It must be also recognized that the farmers were there first.  Many of the units on the Delmarva Shore and in Northeastern States are third or fourth generation family enterprises connected through vertical integration.  The principle of primacy is incorporated into Pennsylvania statues recognizing the rights of existing farmers.

Throughout the U.S. there is a rising trend to oppose erection of poultry and swine housing irrespective of location and with denial that technology is able to reduce odor, housefly infestation or degradation of water quality.

 New England was once the center of a thriving poultry industry.  Due to a number of factors including an unfavorable climate, high price for land, non-availability of both labor and contract farmers, poultry breeding and commercial broiler and egg production migrated southward. Today, remaining vestiges of a once thriving industry are represented by relatively small-scale specialist egg and broiler producers.

Ms. Dale correctly points out if onerous restrictions are placed on farmers, migration will occur leading to the inevitable loss of jobs and public revenue.

There has to be a balance between effective land use and individual rights.  Tolerance is required, citizens cannot expect to move into an area with intensive livestock production and then demand a moratorium on erection of new buildings on the basis of aesthetics and the presumption of odor and contamination.

The problem of opposition to intensive livestock production is not limited to the high density areas of the northeast.  Witness the problems encountered by the Costco surrogate, Lincoln Premium Poultry, to obtain approval to establish a new broiler complex, first in Nickerson and then in Fremont, NE. (see Aug 10th and 17th 2016).  Sanderson Farms encountered intense opposition to erect a processing plant in Nash County, NC in 2014.  Sonstegard Farms was the subject of concerted opposition following their application to establish an egg production complex in Parker, SD (see Feb. 20th 2015; July 29th 2016). Allen-Harim was blocked in their attempt to convert a disused pickle factory into a processing plant in Delaware (see June 8th 2016)

Intensive livestock operations are more welcome in economically depressed areas than in locations favored by urban transplants. Perhaps the actions of a few “bad eggs” in the past has complicated the applications of current farmers. Obviously good public relations, design features to limit nuisance and involvement in the community are beneficial if not essential for a project to be approved and accepted.


Omega-3 PUFA Supplementation for Diabetics

Sep 23, 2016


Enriched eggs may have an important role in preventing diabetic retinopathy, a degenerative condition invariably encountered by late middle-aged patients with Type-2 diabetes.

Long-chain omega-3 polyunsaturated fatty acids (PUFA) serve as the progenitors of oxylipins which are required to preserve retinal function.


In a recent trial conducted in Spain*, approximately 3,500 participants with a mean age of 67 were evaluated for diabetic retinopathy with most of the patients requiring surgical intervention to preserve vision.

The study which was based on the traditional Mediterranean diet involved supplementation with additional olive oil to boost PUFA intake during the period 2003 through 2009. It was determined that an intake of 500 mg per day of long-chain PUFAs reduced the relative risk of retinal degeneration.

There is a growing market demand for a specialty egg directed to seniors enriched with DHA, lutein, vitamins A and E to support ocular function and to maintain the immune system.

It is possible to achieve levels of 400 mg PUFA in the form of DHA and some EPA in a single egg using a dietary algae supplement.  Increasing the omega-3 content of an egg to approximately 250 mg by supplementing diets with flaxseed, flax oil or canola oil will increase the ALA content with approximately 20 percent conversion of dietary ALA to EPA and DHA by the hen.

With appropriate supplementation, quality control, packaging, and directed promotion, the U.S. egg industry could develop a significant market among Seniors for premium-priced nutraceutical eggs following innovations in Japan, New Zealand and the EU.

*Sala-Vila, A. et al.  Dietary Marine Fatty Acids and Incident Sight-Threatening Retinopathy in Middle-Aged and Older Individuals with Type-2 Diabetes: Prospective Investigation from the PREDIMED Trial. JAMA Ophthalmol, August 18, 2016 DOI: 10. 1001/jamaophthalmol. 2016.2906



National Labor Relations Board Creates “Joint Employment” Precedent

Sep 16, 2016


The U.S. egg production industry has profited from the extended servings of our product by the major QSRs as all-day breakfasts have gained popularity. It is a matter of fact that variable costs for fast-food restaurants comprise one-third each for ingredients, labor and occupancy. 

During the past two years there has been a concerted movement lead by unions to increase the minimum wage paid to relatively unskilled workers in QSRs. Values of $15 per hour have been proposed in pursuit of a “living wage”. High minimum rates in Seattle and other cities have led to both closures and decisions by some chains not to expand in areas where profitability is limited.


In 2015 under the guidance of Steve Easterbrook, McDonald’s Corporation made the decision to raise wages for employees in company-owned stores.  In many cases this resulted in a knock-on response on the part of franchisees.

The question arises as to the actual legal employer of workers in franchisee-owned stores.  In 2014 Plaintiffs sued both the owner of a franchise and McDonald’s Corporation, the corporate entity, for overtime when working after midnight and for time expended in the equivalent of “donning and doffing” as required.  In the event the case was settled out of court and McDonald’s denied liability as a “joint employer”.

The California Supreme Court in August 2014 held that franchisors were not liable for how franchisees remunerated workers since they were not responsible for decisions relating to hiring, supervision or termination of workers.  This decision was rendered notwithstanding the fact that franchisors may impose standards relating to hygiene and other operational procedures to maintain brand uniformity.

Following a recent decision by a Federal judge rejecting claims against McDonald’s as a direct control joint-employer, the National Labor Review Board (NLRB) has reframed standards to allow for the concept of indirect control. This is in part based on computer systems which are used to calculate wage payments, according to the Wall Street Journal.

The reclassification of McDonald’s by the NLRB as an indirect employer is based on the concept of “ostensible agency”.  This vague legal principle is based on the theory that McDonald’s could be held liable if the employees held a reasonable belief that their working conditions were in fact controlled by the franchisor.

It is expected that the powers which have been unilaterally assumed by the NLRB will create an environment in which the plaintiff bar can initiate claims against franchisors on behalf of their clients creating the potential for inflation in the cost of labor.  To maintain profitability in a competitive environment characterized by promotions resulting in relatively thin margins, franchisees will have to raise prices which in turn would depress demand.  During the past quarter, the national average change in same-store sales compared to 2015 declined by 0.1 percent for twelve QSR chains.  Any further decline in demand, irrespective of whether due to a price increase or some other factor would reflect adversely on egg producers.



Resistance Gene mcr-1 Placed in Perspective

Sep 9, 2016


Dr. Beth Mole, Health Reporter for ARS Technica recently published a perspective article relating to the emergence of the mcr-1 gene which allows bacteria to resist colistin, an antibiotic considered to be a drug of last resort to treat some infections. In her article, Mole refutes some of the inflammatory and extremist headlines appearing in lay articles and on the web relating to drug resistance.

It is now widely accepted that the mcr-1 gene occurs in pathogenic bacteria isolated from four continents.  Three isolates of E. coli carrying the gene have been identified in the intestines of food animals at slaughter in the U.S.


A single case has been diagnosed in a patient in Pennsylvania presenting with a urinary tract infection.  Since surveillance was only initiated in 2015, studies have yet to be concluded to determine when and how the mcr-1gene was introduced into North America.

There have been a number of previous instances when drug-resistant bacteria resulted in public health problems in the U.S. Enterobacter resistant to vancomycin emerged in 1991. An extensive outbreak of carbapenem-resistant Klebsiella pneumonia (CR-KP)was responsible for nosocomial infections in a hospital in New York. Subsequently in 2011, cases of CR-KP followed transfer of patients to the National Institute of Health Research Hospital in Bethesda, MD.  This facility recorded 18 cases of the infection with11 fatalities, albeit in patients with compromised immune function or underlying conditions requiring referral.

It remains to be seen whether there is an epidemiologic relationship between the mcr-1 gene associated with nosocomial and possibly community infections and in pathogens isolated from livestock.  Although there is currently only indirect evidence that there is a direct connection between the mcr-1 gene in livestock and in human patients, the gene is widespread in the livestock industry of China and in their hospitals and is now identified with greater frequency in Asia and the EU.  

Increasing concern over antibiotic resistance has attracted the attention of legislators, funding agencies and scientists in the field and laboratories. The September 2016 edition of Emerging Infectious Diseases (Vol.22. No 9), a peer-reviewed journal, is dedicated to antimicrobial resistance. A total of 13 research articles or case reports are included in the issue. The topics considered the epidemiology of clinical infections and the results of whole genome sequencing of isolates of Shigella, Staphylococcus, E.coli, Campylobacter and Enterobacter resistant to a range of antibiotics.

 Irrespective of the science and epidemiology associated with the mcr-1 gene which many regard as the “smoking gun” linking food and companion animals to humans, public perception is fueling resistance to the use of antibiotics in livestock production.  This is reflected in Congressional concern and actions by the Food and Drug Administration the principal regulatory body, and the CDC, the Agency concerned with public health.

Any food producer who ignores either the science or public perception of antibiotic resistance does so at their own peril.


Will Anything Satisfy Them?

Sep 2, 2016


The dismissive approach by animal welfare organizations to progressive concessions by the Industry is exemplified in an item by Dan Nosowitz in the Modern Farmer on August 10th.  The lead paragraph confirms that major UK supermarkets will transition to sourcing eggs from flocks that are reared and housed in other than conventional cages by 2025, following a similar trend in the U.S.  


Regrettably the change from conventional cages which will involve an investment of up to $10 billion over a 10 year period in the U.S. in addition to incremental costs to consumers of up to $2.5 billion annually, does not appear to satisfy the opponents of intensive livestock production.  Nosowitz states, “Going cage free doesn’t mean chickens will be living a bucolic life picking at grubs in sunny fields”.  The article states that in the U.S., cage-free eggs come from hens in aviaries which he characterizes as “essentially giant versions of the battery cages which many hens are kept in a single space” Nothing can be further from the reality.

The article claims that in aviaries, birds have very little room to themselves and illness and fights are common.  This is also a misperception but unfortunately believed by those unfamiliar with housing and management of flocks.  A new twist to the anti-egg production movement appears to be the introduction of human welfare.  It is claimed that aviary housing stirs up dust which is “dangerous to the farmers who keep flocks”.

It is regrettable that the deviations from acceptable rearing management and husbandry of flocks used in the comparative studies of alternative housing completed by universities under the auspices of the Coalition for a Sustainable Egg Supply have become entrenched in literature. (See postings March 11th 2014; February 27th 2015 and May 27th 2016 by entering “Aviaries” in SEARCH tab). The various problems which were encountered and documented in the Coalition-funded comparison could have been avoided had the university scientists heeded the advice of experienced technicians successfully operating aviaries under commercial conditions.

The flawed results are   now held against the aviary system which has proven to be compatible with the needs of flocks. Appropriately designed buildings equipped with well-managed aviaries satisfy the requirements for ventilation, nutrition, and husbandry as exemplified in excellent performance including livability and egg production corresponding to the genetic potential of commercial strains.

The perception of aviaries has not been helped by dissemination of biased data by the National Association of Egg Farmers, a splinter group of the U.S egg industry intent on preserving conventional cages for their membership. In various releases their spokesperson Ken Klippen has invoked inferior welfare, egg contamination and dust as problems relating to aviaries. Quoting from the EGG-CITE May 27th posting “This is disingenuous and self-serving. Promoting spurious objections to cage-free production represents some vain hope of a reset on policy of sourcing eggs over the next decade.  Simply disparaging cage-free production runs counter to the interest of the mainstream egg-production industry which has recognized the need to follow market demand and is responding accordingly.

It is an unfortunate reality that there will be no placating the opponents of intensive production since they are guided by some idyllic concept of chickens roaming in pasture eating grass and scratching for worms.  Even if the industry were to convert completely to outside access, which would be totally uneconomical and impractical, the vegan adherents will still not be satisfied since we would be exploiting a sentient being.


Hampton Creek to Undergo SEC Scrutiny

Aug 26, 2016


Nick Wingfield reporting in the New York Times on August 19th indicated that the Securities and Exchange Commission (SEC) has initiated an inquiry into the activities of Hampton Creek.

This action arises from press reports based on disgruntled ex-employees that in 2014 Hampton Creek apparently initiated a program of purchasing quantities of Just Mayo™ from store shelves.


This was allegedly to generate a false impression of customer demand. Industry observers discount the explanation of “quality control” advanced by Joshua Tetrick, founder and president of Hampton Creek, as contrary to industry practice. The prevailing impression was that the activity was in all probability a deceptive practice despite assertions to the contrary.

The alleged program of buy-backs was initiated prior to Hampton Creek apparently raising $90 million from private investors, claimed to include Mark Benioff, Vinod Khosla and Bill Gates.  Their names, and accordingly reputation are frequently invoked by Tetrick as endorsements of the philosophy of the company which is to replace all animal protein including eggs with plant-based ingredients based on  both environmental and welfare considerations.

Although the New York Times article stated that a 30-ounce jar of Just Mayo™ was on the shelf for $3.66 at an unspecified Walmart supermarket on Friday August 12th, on the same day a Harris-Teeter store in Durham, NC had marked the same item at $7.00, almost twice the price of a competing nationally-branded bottle of genuine mayonnaise.

Hampton Creek has been beset with published accusations of deception with regard to staging visits to laboratory facilities, extravagant claims bordering on “puffery” and questionable personnel policies. These could in a charitable sense be ascribed to managerial inexperience although Tetrick is a lawyer by training. The image of the Company and its founder benefitted from the David and Goliath conflict with Unilever and it is a matter of record that Hampton Creek was unjustly opposed by senior employees of the American Egg Board. Hampton Creek came into conflict with the FDA concerning health claims on a Company website although the Agency conceded on the brand descriptor, allowing the trade name Just Mayo™ for a product devoid of eggs but contrary to the legal definition of “mayonnaise”. 

It now appears that Hampton Creek intends to raise $220 million from investors.  The major question is not whether or not the buy-backs of Just Mayo™ in 2014 were deceptive, this consideration is probably more an inconsequential lapse in ethics than a substantial issue.  The real question is how the Company spent investors’ funds and what Hampton Creek has to show for the $100 million apparently expended to date?

The company has eerie similarities with Theranos which has been unmasked as a fraudulent concept.  Both companies were founded by outspoken entrepreneurs claiming to be disruptors of existing technology and they both made extensive use of the media.  Neither company employed or retained credible scientists or consultant specialists in their respective fields who could add integrity to claims.  Both companies have absorbed considerable venture capital from private investors with little to show in the form of accepted commercial products offering commensurate financial returns. Hampton Creek has made a lot of promises to revolutionize food production. To date it has marketed egg-free cake mixes and a “me also” ersatz mayonnaise which is simple to formulate but expensive to produce, given the artificial restraint of GM-free ingredients.

Neither company has issued audited financial statements but recent press reports based on “leakage” suggest the company is unprofitable.  Although this situation is common to many start-ups, there appears to be a negative differential between the variable cost of production and the prevailing wholesale price. Perhaps Tetrick is following the Henry Ford dictum of “losing money on every Model T but making it up on the volume”.

EGG-CITE would like to see the success of Hampton Creek which has approximately one percent of the current U.S. mayonnaise market. EGG-CITE does not wish Josh Tetrick and his colleagues any ill will, despite his close connections to the HSUS and his earlier statements vowing to eliminate the egg industry and intensive livestock production.

His standing among the investment community will be enhanced if he were to open his facilities to a group of impartial food scientists to evaluate his much-vaunted research capability.  Concurrently releasing his business plan and following the conventions of other companies which have been in operation for over five years, would be beneficial to both his personal image and that of his Company.  As Elizabeth Holmes discovered, it is not possible to fool all of the people all of the time and certainly not a Federal agency. To attempt to raise an incremental $220 million and claim a market value of $1 billion suggests a greater level of disclosure and a positive track record. A projection of intended capital investment and financial performance in the form of a comprehensive business plan should be demanded of Tetrick and his management team to satisfy the Board of the company which must represent the interests of shareholders.

Perhaps based on recent experience, the SEC is becoming more proactive in protecting investors. After-all it is held that “fools rush in where angels fear to tread.” Why is it that aggressively promoted concepts with the terms “disruptor”, “environmentally friendly” and “sustainable” appear to attract investment capital in the 2100s like “dot com” did a decade ago?

Joshua Tetrick or a representative of Hampton Creek is welcome to respond to this Editorial. Any reasoned, factual rebuttal will be posted.



Aug 19, 2016


The Law of Unintended Consequences may impact the intent of the USDA to encourage Supplemental Nutritional Assistance Program (SNAP) beneficiaries to improve their diets.

An article in the June 29th edition of The Wall Street Journal, details proposed USDA regulations to modify conditions under which stores can participate in the program.


There is considerable justification for the White House to promote increased purchase of fruits and vegetables by SNAP beneficiaries.  Low-income segments of our population consume diets high in fat, salt and calories resulting in a high incidence of obesity and metabolic syndrome.

Currently SNAP carries an annual cost of $74 billion.  There are now 45 million recipients with an average monthly support level of $127.  This compares to the 1969 “food stamp” program which paid $42 using inflation- adjusted values. 

The USDA in their attempt to promote consumption of fruits and vegetables will require that all stores participating in SNAP must stock a wider variety of vegetables, fruits, meats and dairy items. Concurrently they must reduce less healthful products including pizza, canned soups and frozen meals. 

This initiative will represent a problem for smaller stores including corner markets and tiendas which represent 195,000 of the 265,000 participating food outlets.  Complaints advanced by these small stores include a lack of space, inadequate refrigeration and display counters for the required foods. Operators of small stores justifiably claim that they would have losses associated with dated produce and spoilage.  In the words of one convenience store operator in a mid-west city, “most of the customers buy chips and soda”.  The owner added, “we tried that a long time ago but it didn’t sell much”.

From the perspective of consumers, disqualifying many corner stores and tiendas will create hardship since there will be fewer outlets in their neighborhoods. This will require frequent trips to conventional supermarkets and effectively extend the areas classified as “food deserts”.

Perhaps the intended SNAP regulations represent an opportunity to introduce eggs into corner stores and other outlets since most of the locations already have coolers for beer and drinks.

The Obama Administration should carefully review what they hope to achieve and recognize the problems inherent in restricting rather than in promoting the consumption of nutritious food.  The USDA, in conjunction with the Department of Health and Human Resources has a long way to go to promote sensible food choices. The problem of high fat and calorie intake with minimal exercise lies in existing social norms and ignorance in some demographics benefitting from SNAP.

Schools and community centers in addition to medical establishments have a role in promoting health through adequate diets.  Simply restricting the number of outlets using a bureaucratic hammer will be counterproductive.


Avian Influenza Shedding by Waterfowl is Limited in Duration

Aug 12, 2016


World expert on avian influenza Dr. Robert Webster of the St. Jude Hospital Department of Infectious Diseases has reported on a collaborative study to ascertain the prevalence of avian influenza in migratory waterfowl. 

The study relates to 23,000 samples from wild ducks and aquatic birds collected before, during and after the avian influenza epornitic in the spring of 2015. 

Collaborators included Dr. David Stallknecht and Rebecca Poulson of the University of Georgia and Dr. Richard Slemons and colleagues from The Ohio State University and Dr. Scott Krauss of St. Jude.


The study confirms previous observations made by Dr. Stallknecht in Louisiana during the 1990’s denoting that intestinal infection and shedding by migratory waterfowl is transitory, measured in weeks.

The obvious implication from the study is that waterfowl transiting the four almost parallel flyways over the U.S. have the potential to introduce avian influenza, transmitted to commercial flocks if biosecurity is defective. Field observations made during the later stages of the HPAI outbreak in Minnesota failed to show shedding by wild birds despite the fact that there were ongoing outbreaks among turkeys and laying hens.  This suggests that infection may be introduced by migratory waterfowl but that subsequent dissemination of virus is facilitated by movement of commercial poultry, products, personnel and vehicles.

In concentrating laying hens on large farms with populations in excess of a million million hens, industry practices such as operating combined in-line and off-line packing, collection of dead birds and garbage from many farms using common vehicles and failure to effectively decontaminate feed delivery and poultry transport vehicles are factors contributing to the extent and severity of outbreaks.  The 2015 epornitic in retrospect involved approximately eight companies most of which were involved in egg breaking. 

Within the poultry meat industry, individual turkey grow-out farms appeared extremely vulnerable.  It must be remembered that within the affected counties in Minnesota, one major egg producer and a large broiler producer were unaffected, despite outbreaks in the same localities where they operated. This implies more effective levels of structural and operational biosecurity.

A characteristic of the 2015 outbreak involved the emergence of a recombinant virus containing genes from the highly pathogenic H5N8 virus originating in Asia combined with genes from North America waterfowl.

The study published in the Proceeding of the National Academy of Sciences has relevance to predicting outbreaks based on surveillance of waterfowl at the beginning of the migratory season. The results emphasize that waterfowl are not permanent reservoirs of avian influenza but that introduction of novel AI strains can be expected in subsequent seasons.


Increased Concern over Antibiotic Resistance in the UK

Aug 5, 2016


The May 21st edition The Economist devoted the cover and a feature article to antibiotic resistance.  The thrust of the commentary placed the onus for antibiotic resistance on misuse by the medical profession and made no reference to livestock production.

Concern over antibiotic resistance has been growing for the past decade leading to the appointment of a review of antimicrobial drugs led by Lord O’Neill of Gatley, formerly an economist at Goldman Sachs and a major personality in the City. 


The Committee headed by Lord O’Neill documented that 700,000 deaths occur worldwide each year as a result of drug resistant pathogens and parasites. Projections suggest that if the trend in emerging resistance continues, the impact may reduce global Gross Domestic Product by 2 to 3 percent. It is estimated that treating drug-resistant infections in the U.S. amounts to $20 billion annually.

The most significant challenges facing the medical profession include Clostridium difficile which is responsible for colitis and is frequently a result of dysbacterosis caused by injudicious administration of antibiotics.  The second most significant threat to public health involves carbapenem- resistant Enterobacteriaceae.  Recently PBS aired a program dealing with nosocomial (hospital-related) carbapenem-resistant Klebsiella infection in the NIH Research Hospital in Bethesda MD. 

The third drug-resistance threat involves Neisseria responsible for gonorrhea.  A number of other organisms that have become resistant to one or more antibiotics  pose a serious threat. According to the review these include Acinetobacter, Pseudomonas, Shigella and methicillin-resistant Staphylococcus aureus (MRSA).  Multi-drug-resistant Mycobacterium tuberculosis is an emerging problem in Asia and strains of Mt are entering Western Europe and North America with migration of infected carriers.

It is evident that the U.S. intensive livestock industry will have to comply with existing and proposed legislation to restrict the use of antibiotics to therapeutic administration under veterinary supervision.  This approach when realized will not however make any impact on emergence of drug resistant pathogens associated with human infections.

Egregious misuse of antibiotics in livestock production occurs in China where colistin, a polymixin class of antibiotic used as a last resort, is injudiciously used in hog and broiler production. (See postings December 2nd 2015 and June 1st 2016. Insert ‘colistin” in SEARCH block) The emergence of the plasmid-associated mcr-1gene in China with subsequent dissemination worldwide, including the U.S. demonstrates the need for stricter control over manufacture and use.  It is a matter of record that colistin is manufactured in industrial quantities approximating 12,000 tons annually in plants located in China, India and Denmark in the full knowledge that it will be abused, since the requirement for colistin in human medicine is extremely small.

As noted in the O’Neill report, addressing the issue of drug resistance will require a multifactorial initiative.  Immediate action should include:-

  • Training of physicians to use antibiotics according to the principles of prudent use.  This will involve laboratory diagnosis and evaluation of susceptibility of organisms to selected antibiotics.
  • Indiscriminate sale and use of antibiotics should be restricted in non-industrialized nations.
  • Surveillance of antibiotic resistance among human pathogens must be intensified and the epidemiology of emerging resistance should be defined.
  • Improvements in hygiene in medical facilities is necessary to reduce the level of infection.
  • Public awareness campaigns should be intensified to reduce the “pester power” which pressures physicians into prescribing antibiotics for clients and their children when they are not required.

Concurrent with obvious remedial action, longer term solutions should be evaluated.  The O’Neill report recommends government support of research into new antibiotics since currently there is little incentive for a pharmaceutical company to expend up to one billion dollars over five years to develop a new class of drugs and to wait 10 to 15 years for payback. At the present time the pipeline of new products undergoing clinical trial suggests few clinically acceptable products coming forward over the next five years.

Future approaches to control of bacterial infections may include bacteriophages which are being used under experimental conditions. Their commercialization appears only to be in the distant future.

It is ironic that Sir Alexander Fleming who identified the antibacterial action of an extract from Penicillium fungus which led to the antibiotic revolution of the late 1940’s, categorically warned of the dangers of resistance developing among bacterial pathogens.


Disparity between DSD and Retail Prices

Jul 29, 2016


Statistics circulated by the Egg Industry Center (EIC) incorporate collated data released by the USDA-Agriculture Marketing Services. EGG-CITE reviews and posts the monthly report and supplements this data with the USDA Egg Market News Report each week.

The magnitude of the drop in wholesale direct-store delivery (DSD) prices during the second quarter of the current year is documented in the table below.  During 2016 nest- run price plummeted from 91.7 cents during January to 31.8 cents in June, a decline of 66 percent. 


Production costs remained almost constant between 59 and 60 cents per dozen for nest-run based on feed costs, pullet depreciation, housing, labor and related overhead.  Escalation in the price of both corn and soybean meal reflecting the balance between world supply and demand increased nest run production cost to close to 66 cents in June. 

The resulting contribution margin at the nest-run level declined sharply from 33 cents per dozen in February to 7.6 cents in March.  Thereafter contribution margin turned negative attaining an average of -28.7 cents per dozen for the second quarter

The DSD price calculated by the USDA incorporates nest-run, packaging, processing and delivery.  The DSD value declined from 112.2 cents per dozen in January to a low of 61.8 cents in May representing only 55 percent of the price prevailing at the beginning of the year.

Retail prices declined from 232.8 cents in January to 168.4 cents per dozen in May as released from USDA surveys.  The Markup column in the table below represents the difference between DSD and retail price.  This has declined over the period extending from January through May by 11 percent.  Effectively retailers have taken advantage of low prices directly set through their buyers, to maintain high margins.  If demand had increased in relation to supply, prices would have risen during the second quarter through the entire supply chain extending from nest-run, through wholesale to DSD for generic eggs. 

The status of the egg industry can be discerned through the fourth quarter and fiscal 2016 financial results of Cal-Maine Foods, a bellwether pure-play shell egg producer. Expressing a realistic view of the future, Dolph Baker, Chairman and CEO of the company noted that flock numbers are approaching pre-2015 HPAI levels and Egg Industry Center forecasts suggest as many as 315 million hens producing collectively for the shell and liquid segments of the industry in December.  Increasing supply without a proportional rise in consumption would simply prolong the present agony.

The industry has allegedly attempted to regulate production in past years but events have disclosed that the criminal and civil penalties for collusion in any industry are severe.  Production levels will have to be moderated by individual action by producers. Possible distortion in pricing inherent to the widely-used benchmarking system will have to be investigated and if present must be resolved. 

There are limited opportunities for synergy through mergers and acquisitions and the regulatory restraints on large companies pooling their shareholdings is a doubtful reality given the oligopoly among the top ten producers collectively representing approximately 65 percent of total production.

Those producers not affected by HPAI in 2015 generated a capital reserve from their higher to be devoted to conversion of existing facilities.  Given the headlong rush to transition from conventional cages, expenditure will have to be devoted to conversion at $35 to $40 per hen. It is evident many existing small producers with obsolete high-rise housing and conventional cages will probably cease production and supply to processing plants will be reduced.


Questions over Federal GM Label Legislation

Jul 22, 2016


The 11th hour compromise in the Senate Agriculture Committee which allows for a uniform Federal standard of labeling with respect to GM ingredients has been hailed by the food industry as a solution to the problem raised by Vermont Law 120, mandating the designation of GM status on food labels for other than exempted animal-derived foods.

The compromise negotiated between Senator Pat Roberts (R-KS), Chairman of the Senate Committee on Agriculture, Nutrition and Forestry and the ranking member, Senator Debbie Stabenow (D-MI) involves Smart Label® technology promoted by the Grocery Manufacturers’ Association.  Consumers wishing to determine the GM status of a food item can scan a code to establish whether GM-derived ingredients are incorporated in the product.  Alternatively accessing a company website will provide the required information.


It must be noted that various state and local initiatives to enforce GM labeling on the basis of the claimed “right to know” are effectively aimed at GM technology with the intention of demonizing foods derived from genetically engineered cultivars.  Accordingly the solution proposed in the Federal bill will in no way satisfy the opponents of GM technology.  Vani Hari a prodigious blogger and disseminator of misinformation, suspicion and pseudo-science has tweeted “it is not true transparency – it is another way to hide the truth.”  In a second tweet she ominously noted “mark my words; food companies that decide to use Q.R. codes will be targeted by major on-line campaigns to shame them.”

Cognizant of the power of the manipulative bloggers, and uncertainty and timing of federal legislation, food manufacturers have responded according to their perceptions of customer desires.  Campbell Soup Company commented that they remain committed to on-package label disclosure and in anticipation of the advent of Vermont legislation introduced a label descriptor indicating the presence of GM ingredients.  Other major manufacturers including ConAgra Foods and General Mills, while applauding the Senate comprise which has yet to be voted on, may have second thoughts when the internet barrage is activated.

The primary issue of labeling is contested against the reality that foods containing GM-derived ingredients are wholesome, nutritious and do not differ in safety or nutrient value from generic counterparts.  The second issue is whether average consumers really care about GM.  The Pew Charitable Trust, an activist organization, in applying their survey approach maintains that 90 percent of respondents are in favor of labeling.  However when consumers were asked by researchers at Oklahoma State University to list the attributes they considered important to appear on labels only 7 percent cited GM as an issue of concern.

As expected a uniform Federal labeling bill will emerge.  The value will be in preventing individual states and local jurisdictions from establishing their own labeling regulations resulting in an uncoordinated patchwork of requirements which would prove disruptive and expensive to the food industry and ultimately to consumers.

All foods other than those certified by the USDA Organic Program or the soon to be introduced USDA GMO-Free certification could be labeled “May Contain Ingredients Derived from GM Technology” paralleling the situation with nuts and other allergens.

The scientific Luddites opposed to GM technology will not be satisfied with the Senate compromise.  It is expected that the controversy will continue and that some companies will attempt to generate a competitive advantage through their labeling and from spurious and implied claims relating to health and safety.



Jul 15, 2016


It is not often that EGG-CITE finds common ground with the HSUS but we apparently both support the recent passage of S.7345/A.10170 which places a moratorium on new store- front wet markets.

The HSUS maintains that these operations “expose animals to filthy, cruel and inhumane conditions”.  Whether this is valid or not is subject to opinion given the regular inspections by state and local public health and veterinary officials.


EGG-CITE is strongly opposed to live bird markets since they represent the double risks of disseminating avian influenza back to live-bird operations and laterally to consumers.  Without live-bird markets there would not be an established network of producers with multi-age farms and dealers representing a potential hazard to the commercial poultry industry.

Over the past two decades, attempts have been made by the USDA and State Agencies in New York, New Jersey, Minnesota and California to “sanitize” and regulate store-front wet markets. Strategies include compulsory decontamination, one day per week depopulation and constant surveillance for low- pathogenicity avian influenza. 

This is all for the good but represents a cost to the public sector.  The questions arises as to who benefits?  This is the U.S. in 2016.  It is not China, it is not India, and it is not Pakistan.  No one will starve to death if they are obliged to purchase their chickens or red meat in supermarkets or specialty stores.  Shutting down store-front wet markets will create an opportunity for small regulated processing plants under the inspection procedures and standards imposed by USDA-FSIS.  Individual production companies or cooperatives could produce birds to be slaughtered under halal or kosher rules. 

Store front wet markets are an acronism and should have disappeared in the 1940s.  The entire live bird production and marketing system is fraught with risk for avian influenza and other infections some of which are foodborne. The very existence of live bird markets places the entire poultry industry in jeopardy.  China and Hong Kong have employed an on-again-off-again policy on wet markets, depending on the incidence rate of H7 Avian Influenza which is innocuous to birds but infectious to consumers. More than a decade ago Jordan banned wet markets in urban centers including Amman, resulting in improved hygiene and the establishment of regulated abattoirs.

The risk involved with the live bird production and marketing system far outweighs the advantages enjoyed by a small proportion of our urban populations. We should build on the action of the New York State Legislature and start phasing out wet markets.  An appropriate way will be to quantify the public sector fixed and variable costs involved in supervision and regulation to be applied directly as a fee to the purchase price of poultry slaughtered in U.S. wet-markets.


Preventing Intrusions by Agents of Animal Rights Organizations

Jul 8, 2016


Recent news reports documented the intrusion by an agent of Mercy for Animals onto an egg production complex in Washington State. Based on the pay record pasted on the Mercy for Animals website site, the name used by the agent was determined to be Brian Nevels.

Intrusion videos and allegations by animal rights organizations including Mercy for Animals and the Humane Society of the United States and its surrogates are responsible for negative publicity both for the industry and the implicated company.


Videos and still images are selected to illustrate alleged deviations from acceptable housing and management may not represent the actual situation in a house or the farm depicted.  Audio commentary is frequently unrelated to the images and is invariably inflammatory, intended to evoke emotion and sympathy among viewers to support fundraising activities of the organization concerned.

Companies are well advised to intensify their screening of applicants at the time of employment to identify potential agents. Subject to state law, it is advisable to include a statement on the employment application form requiring prospects to attest to the fact that they are not an employee, agent or volunteer of an animal welfare or rights organization or are affiliated with media as an employee or freelance contributor.  In the event of a subsequent civil or criminal action, the signature of an agent on an application form could be construed as perjury and may cast doubt on the veracity of their images or testimony.

Screening procedures should obviously include E-Verify but should also involve a careful review of past employment with direct communication with a previous employer using appropriate precautions to avoid deception.

A photocopy of the applicant’s driver’s license should be retained on file. Some companies are issuing identity cards with a photo image with a duplicate copy available for subsequent publication if necessary.

In interviewing an applicant, the HR or line manager should determine that the apparent social status and education of the applicant appear consistent with the position and wage rate.  Factors such as dress, footware, applicant’s vehicle, demeanor, vocabulary and hands should be considered in the evaluation.

Many companies will only employ new workers if they are vouched for by an existing employee in addition to the background check.  Employing workers provided by agencies is always problematic with regard to introducing agents affiliated to animal rights organizations.

It would appear that agents now seek positions on work crews involved in movement of pullets vaccination or depletion of flocks since this provides an opportunity to move among houses on a complex and to stage images of cruelty or mishandling. Assigning a new employee to a task such as servicing bait stations or maintenance allows a potential agent to obtain images whether real or contrived through the entire complex which could then be used to discredit the operation.

New employees should be carefully supervised and should confine their activities to a specific task and area. Employees who appear to wander from their assigned work location, engage in conversation with other employees outside their areas of involvement and who manifest inquisitiveness should elicit suspicion.

All houses containing poultry and break rooms should have a sign depicting a telephone number to be called in the event of observing any deviation from acceptable welfare or management.  Instructions to the employee during the orientation period should emphasize the need to report any unacceptable practice to a supervisor and to describe problems immediately using the telephone number indicated.  In many cases, agents claim that unacceptable practices including neglect continue for weeks. Essentially if deviations from approved management are observed, they should be reported immediately to prevent suffering.

It should be anticipated that Mercy for Animals and other organizations will intensify their efforts through summer and fall months to discredit the industry since Massachusetts voters will in all probability be considering a ballot initiative reflecting California Proposition #2.

Since it is impossible to cull every sick bird or to remove all dead birds from cages within 24 hours or to prevent an agent obtaining images which can be edited or exaggerated out of context, it is advisable to screen applicants to exclude agents from operations. This will ultimately be beneficial to the company especially if supplying eggs or distributing under a brand name which in itself represents a vulnerability.


NAS Report on Genetic Engineering

Jun 30, 2016


The National Academy of Sciences issued a report on May 17th noting that the distinction between genetic engineering and conventional plant breeding is becoming less evident.

The National Academies of Sciences, Engineering and Medicine has concluded after an extensive review that there is no health hazard associated with genetically engineered (GE) crops and that there is no evidence of any deleterious effect on the environment.

The NAS Committee reviewed 900 research publications on the development and cultivation of GE corn, soybeans, and cotton representing the majority of modified crops.


The Committee considered the benefits derived from GE technology with specific reference to:-

  • Effects on Human Health – Studies on animals and research on chemical composition did not reveal any differences between conventional and GE-derived foods nor any relationship between consumption of GE foods and chronic health effects.  There are however indirect benefits from GE crops since the levels of pesticides and insecticides are lower than with conventional cultivars.
  • Effects on the Environment – The use of insect-and herbicide-resistant crops did not affect diversity of plant and insect life.  No example has been documented of an undesirable outcome including the unintended transfer of genes from GE crops to wild species.
  • Effects on Agriculture – The Committee determined that the extensive use of GE cultivars to produce corn, soybeans and cotton has been beneficial especially for small-scale farmers.  Quantifying the benefits of GE cultivars is difficult given the diversity of farming practices, availability of fertilizer, agro-economic considerations and government policy.

The Committee did however note that emerging resistance to glyphosate may limit the advantages from crops modified to be resistant to this herbicide.

The strict definition of “Genetically Engineered” must be expanded to include gene deletion and suppression not involving transfer of genes between species. New varieties of apples and potatoes with beneficial attributes have been approved by the FDA, EPA and USDA for commercial production developed applying techniques which “silence” specific genes. Should these varieties be considered as GE?  Their development parallels natural breeding but is accomplished over a shorter time period.

The Committee was of the opinion that mandatory labeling of foods as to GE content is not justified since there are no public health issues involved.

The study was sponsored in part by The Burroughs-Wellcome Fund, The Gordon and Betty Moore Foundation, the New Venture Fund and the U.S. Department of Agriculture with additional support from the National Academy of Sciences.

For further information and a copy of the report, access www.nap.edu


Mercy for Animals Releases Video

Jun 24, 2016


On June 22nd, Mercy for Animals (MFA) posted a video alleging deviation from acceptable production practices and welfare at an egg production complex in Washington State. In this instance, MFA unjustifiably implicated a nationally distributed brand since the owners of the complex are franchisees of the marketing cooperative.


The producer confirmed that no eggs destined for the brand were in fact derived from the flocks depicted in their clandestine video. The release of the video was accompanied on Wednesday morning June 22nd by a telephonic media event comprising a reading of a prepared statement by Matt Rice, Director of Investigations for Mercy for Animals.

The MFA allegations closely follow the claims relating to a similar intrusion using an agent on an egg production complex in Maine as reported in a June 17th posting on EGG-CITE. The principal thrust of the MFA complaint involved housing of flocks in cages. This is a standard objection by MFA despite the fact that hens were held in accordance with the 67 square inch stocking density as accepted by the U.S. industry. 

Alleged deviations from acceptable practices included birds entrapped in cages by loose wire, decomposing dead hens in cages and individual birds showing prolapse or visible external lesions. As with all intrusion videos the MFA allegations are not supported by any quantitative data regarding the prevalence rate of alleged abnormalities. Based on performing audits and providing consulting services to the U.S egg industry for over 30 years as a board- certified poultry veterinarian, individual hens are encountered with tumors, injuries and cutaneous lesions. These birds should be culled and humanely euthanized. It must be accepted that age-related feather loss, injuries to hens and mortality are not specific to cage housing but will be observed in non-confined flocks including barns and free-range systems.  In fact mortality due to aggression and predation are higher in flocks housed in alternatives to conventional cages.

The management of the farm in question has requested an evaluation by a UEP auditor and the farm will be visited by a poultry extension specialist affiliated to Oregon State University.

If determined to be valid and representative of the producer the allegations are clearly an aberration and not representative of the U.S. industry

The recent actions by MFA represent an intensification of their efforts to generate support for the cage-free initiative similar to California Proposition#2, which may be placed before voters of Massachusetts in a ballot in November, subject to ongoing litigation. It must be expected that press releases relating to alleged deviations from acceptable welfare and housing will be announced over the next few months instituted by the HSUS and its surrogates.

Producers would be well advised to review training and supervision of workers and above all concentrate on removing injured, sick or dead birds from cages.  Procedures associated with handling birds during transfer, placement in cages or depletion should be supervised.  Greater care should be exercised in vetting potential employees to identify and exclude agents of animal rights organizations responsible for deceptive video images which may reflect adversely on housing and management.  At the end of the day it is always possible to obtain an image of a sick or dead bird in any house containing upwards of 25,000 hens with the intention of creating the perception that a rare or occasional observation is reflective of the entire flock, farm or producer.

Based on websites maintained by so-called animal welfare organizations it is evident that they are pursuing a vegan agenda and their ultimate goal is to abolish all intensive livestock production.  The intent of animal rights activists and their ilk is to satisfy their own motivations and desires, without concern for the impact on production of food required by consumers, many of whom depend on low-cost protein from eggs and poultry.

The poultry industry and its customers represented by the National Restaurant Association, the National Association of Chain Restaurants and the Food Marketing Institute have committed to an orderly and extremely expensive transition to cage-free housing or enriched colony modules over the proximate ten years.  Manipulation of the mainstream media and posting of contrived, spurious or edited videos by animal rights organizations does a disservice to the responsible industry, their customers and consumers.


What Does the Cornucopia Institute Really Want?

Jun 17, 2016


On June 1st, Mark Kastel circulated a release promoting the concept that scale of production is somehow contrary to the principles of organic production.  The four-page diatribe was aimed at the proposed organic standards for poultry production which Kastel characterized as “a cynical excuse for the USDA to delay addressing widespread violations of the current law in the interest of supporting industrial farming.”


In his commentary, Kastel introduces the new descriptor “family-scale” to characterize the membership of the Cornucopia Institute which collectively produces less than 25 percent of eggs marketed as USDA Certified Organic.  Previously Kastel has beaten the drum of “family-farms”.  Herbrucks Poultry Ranch is a family-owned and managed enterprise which employs workers in Western Michigan and in addition contributes to the agriculture economy by purchasing corn and soybeans grown by Midwest farmers.  The company also provides a livelihood to independent owners of farms that contract with the company in Indiana, Pennsylvania and Michigan.

The Cornucopia Institute is also opposed to what they refer to as “industrial-scale production on factory farms”.  The commentary specifically mentions Delta Egg Farm in Chase, KS. owned by Cal-Maine Foods.  This public-traded company is effectively family controlled with a high proportion of the equity held by individual investors and institutions.  Irrespective of ownership, organic eggs are organic eggs and are identical in nutrient content and other characteristics if produced in accordance with the current rules of the National Organic Program.  The size of operation has no influence on the quality or integrity of the product other than price.

Effectively the Cornucopia Institute would like to disqualify almost 70 percent of current organic production. This would then enable their membership to supplythe market at high prices following an imbalance between availability of product and demand.

By eliminating the production from in-line high density operations, organic eggs would soar in price to $7 to $8 per dozen at retail, enhancing the margins generated by “family-scale” producers-but only over the short term.  Kastel is apparently oblivious of the relationship between supply and demand and the reality of price equilibrium.  The effective market for organic eggs which has grown annually by double digits for a number of years would shrink markedly depriving consumers of available product.  The Law of Unintended Consequences would also result in the emergence of an “organic-light” alternative product from flocks fed GMO-free grains retailing at approximately $4 per dozen, effectively cutting into the market coveted by members of the Cornucopia Institute. 

Logistically there is no way that individuals farmers can supply and service large retail stores. They lack the ability to purchase feed at a competitive price or to maintain effective quality control and marketing programs.  It is only by establishing either cooperatives or vertically integrated enterprises relying on contractors that individuals organic egg producers with up to 30,000 hens will be able to survive under existing or proposed organic rules.

Support for the proposed mandatory outside access, whether 2 square feet or 5 square feet per hen is based on anthropomorphic considerations, unsubstantiated by science.  The position of the Cornucopia Institute is characterized by author Joel Salatin who is quoted in the commentary. He avers that “To pretend that chickens can enjoy their lives and display their chickenness on a foot or two of concrete, gravel and bare dirt covered with waste is a very bad joke.”  Since Salatin is neither a chicken nor a behavioral scientist, he has no way of confirming that chickens do or do not enjoy outside access.  Given personal experience and observation of organic and pasture units, hens are generally disinclined to expose themselves to an open sky since they are inherently programmed to avoid raptors. Predation loss among flocks with outside access was clearly documented in the most recent North Carolina Random Sample test.

Kastel serving as the mouthpiece of his segment of egg production would be well advised to be more realistic in his assessment of organic egg production.  Criticizing the USDA-AMS and constantly sniping at Miles McEvoy the administrator of the National Organic Program, is unproductive. At best the strategy of issuing voluminous commentaries creates a level of self-satisfaction for Kastel and entrenches his position among adherents to the Cornucopia Institute.

The proposed National Organic Program regulations which incorporate mandatory outside access is now the subject of public comment with input from operators of in-line production housing with sun porches and those that favor unrestricted mandatory outside access. Hopefully valid economic and financial considerations together with scientific facts advanced in public comment will be incorporated into the Final Rule.  Continuing to pursue a parochial and self-satisfying approach to regulating organic production is essentially non-productive and ultimately will be to the detriment of the “family-scale” producers whom the Cornucopia Institute purports to represent.