Comments Due Today! (Sep. 23, 2013 before midnight Eastern)
|Pastured poultry farms with 3,000 or more laying hens will be affected adversely.
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The U.S. Food and Drug Administration (FDA) is yet again putting burdens on farmers who use healthy, sustainable practices, and justifying them with fear-based assumptions rather than data. The agency’s latest move is a draft guidance document that will make it all but impossible for farmers with 3,000 or more laying hens to keep the birds on pasture.
Click here for more information about how to take action; keep reading to learn more about the history behind FDA’s guidance document.
The stated goal is to prevent the spread of salmonella from wild birds and other animals to the hens. But there is absolutely no evidence that pastured chickens pose a food safety threat. To the contrary, all the major incidents of salmonella in eggs have come from confinement factory farms.
Back in 2007, FDA issued a rule to address the problem with laying hens carrying salmonella and passing it into their eggs. Under that rule, farms with more than 3,000 hens must take extensive steps to address the risk of salmonella contamination, including testing both the birds and the hen houses. Thanks to this mandatory testing, FDA now has several years of data on where salmonella has occurred—yet its new guidance document doesn’t refer to any cases of salmonella being connected to hens having access to pasture.
Hens that spend time outdoors in the sunlight, eating plants and insects, are healthier than hens crammed closely together inside a building. Informal testing has also shown that eggs from pastured hens are more nutritious than eggs from hens kept indoors and raised exclusively on grain.
But FDA’s draft guidance document creates new burdens specifically for farmers who allow their hens to have access to pasture. Despite the lack of evidence, FDA assumes that exposure to any wild animal creates a health risk, and that farmers should have to somehow keep their hens away from wild birds and other creatures.
|Video: Pastured Egg Difference|
The FDA guidance document suggests that farmers must cover their outdoor pastures with either roofing or netting, or use noise cannons to scare away wild birds. Of course, roofing a pasture is not only cost-prohibitive, but would also prevent sun and rain from reaching the plants and animals in the pasture, defeating the whole purpose of having pastured hens. And the noise cannons that would scare away wild birds would also scare the laying hens.
FDA, as usual, is favoring the mainstream industry practices. Although eggs labeled “organic” must allow birds outdoor access, the large-scale industrial operations simply connect small “porches” to their facilities and claim that this is enough. FDA’s guidance document gives the green light to this substandard process, while penalizing the producers who seek to provide true access to pasture.
TAKE ACTION – SUBMIT COMMENTS TO FDA
FDA is accepting comments on its proposed guidance until September 23, 2013.
Please submit comments to FDA
(Docket ID: FDA_FRDOC_0001) via the online system at
TIP: We recommend that you write your comment ahead of time and save it on your computer — there is a time limit when using the Federal Register System, and you may get timed out if you write your comment from scratch. (See sample comments below.)
1. If your comment is less than one page, you can copy and paste it into the comment box. If it is longer, you can instead write “see attached” and UPLOAD a separate document, such as a Word or PDF file, with your comments.
2. Uncheck the box that says “I am submitting on behalf of a third party,” so that you do not have to enter an organization name.
3. For category, select “individual consumer” or “private industry.”
4. Click “continue.”
5. Check the box that you have read and understood the statement, and be sure to click “submit comment.” You should be taken to a new screen with a confirmation number.
SAMPLE COMMENTS – PLEASE PERSONALIZE
It is very important that you personalize these comments! Form comments will all be counted as a single submission.
Just a couple of sentences at the beginning—who you are and why this is important to you—make a difference. If you have a personal story to share, about your farm or a farm you buy food from, that’s even better!
- The FDA needs to base its requirements on science, not fear and speculation.
- There is no evidence that letting hens have access to pasture increases the risk of salmonella contamination in their eggs. The provisions of the draft guidance document are unnecessary and unfairly target pastured producers.
- While not improving food safety, the requirements will drive many pastured producers out of business. Building a canopy over a pasture is extremely expensive; even protecting a small part of it would cost more than most farms’ profits. Any structure that cut off sun or rain would quickly turn the grass-covered pasture into dry dirt, defeating the purpose of raising hens outdoors on pasture. Having to extend the fence below the surface of the ground would make it impossible to have movable fences, making it harder to do rotational pasture management. And using a noise cannon would scare the hens.
- FDA’s new outdoor egg rules aren’t necessary for food safety, but it will hurt farmers and consumers who want to have truly pastured eggs. I urge you to revoke all of the provisions in the draft guidance document that include requirements on the pasture portion of a pastured laying hen farm.
Although you can comment on any guidance at any time (see 21 CFR 10.115(g)(5)), to ensure that the Agency considers your comments on the draft guidance before it begins work on the final version of the guidance, submit electronic or written comments on the draft guidance by September 23, 2013.
Draft Guidance Document:
Draft Guidance for Industry: Questions and Answers Regarding the Final Rule, Prevention of Salmonella Enteritidis in Shell Eggs During Production, Storage, and Transportation (Layers with Outdoor Access)
Similar document referred to as the December 2011 Guidance:
Guidance for Industry: Prevention of Salmonella Enteritidis in Shell Eggs During Production, Storage, and Transportation
To submit written comments by mail, send to:
Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Rm. 1061
Rockville, MD 20852
To request single copies of the draft guidance, send one self-addressed adhesive label to:
Division of Plant and Dairy Food Safety/Office of Food Safety
Center for Food Safety and Applied Nutrition (HFS-315)
Food and Drug Administration
5100 Paint Branch Pkwy.
College Park, MD 20740
OR Fax your request to 301-436-2632