January 28, 2011
Dear Director Zehringer and members of the Ohio Livestock Care Standards Board,
Thank you for the opportunity to submit comments on behalf of the Ohio Ecological Food and Farm Association (OEFFA) for your consideration at the meeting scheduled for Tuesday, February 1. Our comments pertain to the general considerations, swine, and poultry sections of the standards which the board will consider at this meeting.
While food safety and Salmonella reduction are vitally important, we would recommend the removal of the new language dealing with “Quality Assurance,” which reads “If food is produced for the human food chain, the responsible party must consider quality assurance” (901:12-3-03)(Management) with quality assurance defined as “steps taken to ensure safe, wholesome, and high quality products” (901:12-3-01)(Definitions). Although this language is relatively innocuous since it simply requires the responsible party to “consider” quality assurance, we believe this vague reference to quality assurance is out of place in a document designed to regulate humane animal care and that federal, state, and local food safety laws already exist, with more being developed, to regulate on-farm quality assurance.
In section 901:12-8-02 (Management) (G) and (H), there is no mention of outdoor housing systems for post-weaning, breeding, gestating sows, or gilt housing. As a result, for example, if one reads section (G), “Post weaning housing system must meet the following conditions,” the two conditions are “In mechanically ventilated facilities…” and “Indoor systems that have no mechanical heating…,” leaving a producer with an outdoor system out of compliance with the standards, since they fall into neither category. Is this simply an omission, or is this saying that outdoor, pastured housing for these production stages is not permitted? In order to clarify, we would recommend changing (G) to read: “Post weaning indoor housing systems must meet the following conditions” and changing (H) to read: “Indoor breeding, gestating sow, and gilt housing must meet the following conditions.”
Layer, Broiler, and Turkey Standards
In sections 901:12-9-02, 901:12-10-02, and 901:12-11-02 (Feed and Water), language appears which allows water to be restricted based on “specific management practices, according to the farm’s operating procedures.” Does this imply that there must be documented, written protocols in place? A farmer may regularly restrict access to water at night, for example, but not have formal operating procedures. We would recommend removing the words, “according to the farm’s operating procedures.”
In sections 901:12-9-03, 901:12-10-02, and 901:12-11-02 (General Housing and Housing), we have concerns about the language that reads, “Must provide a clean and safe environment” (this language appears as, “clean, safe, and comfortable environment” in other species). All three terms are highly subjective and not defined within the document. What is clean or comfortable to one person, may not be to someone else. To give one example, if a fox or hawk predates a hen in an outdoor housing system, is that housing considered unsafe? Despite electrified poultry netting and shelter, birds are lost to predation from time to time, but these housing methods should not be considered “unsafe.” We believe that the issues of cleanliness, safety, and comfort are addressed more specifically elsewhere in the standards, that this sentence is therefore redundant, and that removing this language does not weaken the document.
In these same sections, we are also concerned about the language that reads, “Environmental moisture must be managed, whether birds are housed indoors or out of doors, to promote flock health and welfare.” Humidity and rain are natural phenomenon and cannot be controlled in outdoor systems. If the intent is to ensure that poultry are kept dry, we would recommend the language be changed to: “Housing and bedding moisture must be managed to promote flock health and welfare.”
Next, in sections 901:12-9-03, 901:12-10-03, and 901:12-11-03 (Management), we have concerns about the language that reads, “Environmental management must be designed to control parasite infestation, rodents, and non-beneficial insects.” We would recommend this language be changed to, “Environmental management must seek to minimize parasite infestation, rodents, and non-beneficial insects, as it applies to the flock’s housing system.” Parasite, rodent, and insect management are important, but the way these issues are controlled vary greatly by housing system. Some would argue that the best way to fully control these three issues is in a system without access to the outdoors. By adding the words, “as it applies to the flock’s housing system,” it is clear that all housing systems are acceptable and that within each system, steps should be taken to minimize these issues. Otherwise, one could argue that outdoor systems to not control exposure to insects, rodents, and parasites. Essentially, we want to avoid comparing one housing system to another.
Finally, although OEFFA’s primary goal throughout this process has been to represent the interests of small-scale, diversified, and organic producers and ensure that animal care standards protect and encourage all forms of animal agriculture in Ohio, we also represent consumers who are growing increasingly concerned about controversial confinement practices in animal agriculture.
In light of this, we have concerns about the house/barn averaging language which appears in section 901:12-9-03 (Conventional Battery Cage Systems), which reads, “For systems installed prior to the implementation date of these standards, house/barn averaging must result in a minimum average of 67 square inches per layer five years after the implementation date of these standards.”
The problem as we see it is that averages, of course, are mere statistical abstractions. This means that an existing facility could expand its battery cage system after the implementation date and give 10,000 birds 89.33 square inches while doing nothing to address the space provided to another 10,000 birds at the same facility who may be occupying existing battery cages which provide them 44.67 square inches of space. The house/barn would average 67 square inches per layer, but yet 10,000 birds would not be afforded the space requirements specified in the standards. Sixty seven square inches, itself, is only equivalent to two-thirds the size of a standard sheet of notebook paper.
We would also like to repeat our concern related to allowing existing farms continued expansion using current conventional caged housing systems. The rationale for this allowance is unclear, and this would result in a competitive disadvantage for new facilities, while paving the way for expansion of those “grandfathered” facilities. If “enriched cage systems” represent Ohio’s humane care of livestock, then giving permission for an unlimited expansion of those current systems which fall below this standard is not appropriate.
Thank you for your time and consideration. Please do not hesitate to contact us if we can provide more information, answer any questions, or if we can provide assistance in addressing these concerns.
Sincerely,Renee Hunt, Program Director 41 Croswell Rd., Columbus, Ohio 43214 (614) 421-2022, firstname.lastname@example.org