Indecent Eggsposure: How Canada's Eggs are Laid -- by Syd Baumel. Who's Minding the Hens?

Thanks again for your very detailed and informative reply to my questions. I have many follow-up questions. Please excuse me if what follows may seem like a cross-examination. But the paucity of nonpolarized public information about livestock production has created a demand for probing and skeptical questions if the general public is to get an accurate handle on the realities of the industry. My follow-up questions are in red type, with relevant portions of your first answers in black.

Registered egg farms in Manitoba are randomly inspected a minimum of once a year under the Canadian Egg Marketing Agency’s (CEMA) Animal Care Certification Program. The third party inspectors are the same individuals who conduct inspections under the national on-farm HACCP-based food safety program, Start Clean – Stay Clean^TM. This program has been accredited by the Canadian Food Inspection Agency.

By random, do you mean without notice or do you mean random selection? If random selection, how does that ensure that every farm is inspected at least once a year? In its 2004 annual report (http://www.canadaegg.ca/data/1/rec_docs/331_CEMA-2004-Field-e.pdf), CEMA describes their "new Animal Care Program" as a "voluntary program." Is it mandatory in Manitoba? If not, do you know how many or what percentage of Manitoba’s registered egg farms subscribe to it and how many or what percentage of the hens in the province’s registered flock are covered by the program? In an earlier answer, you referred to the provincial government’s "responsibility to ensure" that layer hens are treated according to the recommended code of practice, as with "all other animals that are inspected under the Animal Care Act." But you only mention the egg industry’s apparently voluntary inspection program. How can a voluntary audit program administered by the industry itself suffice to provide that assurance to Manitobans concerned about the welfare of the province’s millions of egg-laying hens?

The public, however has the opportunity to view hens in cages and learn about husbandry and care from farmers at three annual events during the year. The current concern with respect to Avian Influenza has heightened the intensity of security at laying hen facilities to protect both hen and human health.

Which events are these? Red River Ex? Agricultural fairs? Do any of them fairly portray the inside of a typical registered egg barn with respect to stocking density, stacks of open-floored wire cages, partially defeathered birds with skin lesions, the stench of ammonia, the noise of many thousands of birds in one shed, and other conditions that might make a negative impression on the public? Are older layers ever put on display or just young "show birds" that have not yet suffered crippling bone loss or breakage, foot and claw deformities, significant feather loss, etc.?

The Manitoba Farm Animal Council has established an Animal Care Line as a forum to address public complaints/concerns about the way farm animals are treated. This number is distributed by all livestock commodity organisations to their producers and is it is expected to be posted in a prominent place for all employees to see and it does work. All incidents are investigated by veterinarians from the Office of the Chief Veterinary Officer of Manitoba Agriculture, Food and Rural Initiatives. This phone is answered as required by the administrator of the Animal Care Act.

The MFAC hotline is described as "confidential." Does that mean complainers never have to worry about their identity being revealed at any stage of an investigation or legal action? Is it mandatory for producers to post the notice in a prominent place? If so, is there monitoring to ensure compliance, and what are the consequences for noncompliance?

Complaints received from the rural areas come to this office. You will note, we have had an increased number of complaints since 2001. This likely reflects an increased confidence of the public in the complaints system. Overall we are quite confident that animal distress when it does occur is get addressed as livestock producers and their neighbours are very concerned about animal welfare issues.

Could you give me a representative description of the kinds of complaints your office receives for layers, the kind of people who make the complaints (e.g. barn workers) and how the complaints are resolved? There were 12 cases in 2004 – about one for every 15 registered egg barns (2002 statistics), corresponding to 175,000 hens out of the 2.46 million in registered egg barns. To what extent does your office encounter repeat offenders who, perhaps, consider the penalties to be "the cost of doing business," and how are repeat offenders dealt with? What is the most serious offence your office has dealt with in the past 5–10 years?

The osteoporosis and layer fatigue that you have referred to is not a result of inadequate exercise it related to the fact that eggshells have a high content of calcium and phosphorus and birds in high egg production will tend to remove those minerals from the bone. The egg production industry is well aware of this issue has been quite concerned about addressing it because of the welfare and economic implications. The corrective action is nutritional research and diet adjustment. This has been done and the issue has been resolved. The current nutritional profile of laying hen diets has virtually eliminated the occurrence of cage layer fatigue.

Do you disagree with other authoritative sources that cite lack of exercise (typically in caged as opposed to free run hens) as a cause of cage layer fatigue and osteoporosis, along with mineral depletion? For example: http://www.agr.gov.sk.ca/DOCS/livestock/poultry/EggChicken.asp#9; http://www.msstate.edu/dept/poultry/dismisc.htm;
http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=
pubmed&dopt=Abstract&list_uids=10901207&query_hl=6; http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=
pubmed&dopt=Abstract&list_uids=14979568&query_hl=2. These sources – particularly the latter, "Welfare implications of avian osteoporosis" by A. B. Webster of the Department of Poultry Science at the University of Georgia – give the impression that osteoporosis and cage layer fatigue continue to be a common cause of pain, suffering and death in battery hens as well as osteoporosis-related fractures during depopulation and transportation to slaughter. Do you find any inaccuracies in the section on "bones" (page 8) in the recent report on Battery Cages and the Welfare of Hens in Canada: A Summary of the Scientific Literature by the Canadian Coalition for Farm Animals (http://www.humanefood.ca/docs/BatteryReport.pdf)? When you say the issue been resolved, are you referring to Manitoba alone or Canada as a whole? By resolved, do you mean near zero incidence of these disorders? If not, what is the incidence? How has this resolution been scientifically verified? (Anecdotally, I’m told by Stephanie Brown of CCFA that layers still commonly arrive at Canadian processing plants with broken wings and legs.)

Beak trimming is conducted by trained professionals in the most humane way at a young age according to "Code of Practice" standards. Beaks are trimmed to prevent hens from feather pecking each other. It should be noted that the beak in birds is somewhat like the finger nails in that there is little or no nerves or blood vessel in the distal end of the beak. If the beak is trimmed too short nerves and blood vessels are present. This is why trained professionals do this work. In contrast, a cat will suffer far greater pain as a result of the de-clawing procedure, which to be effective must remove the claw as well as the germinal or growth tissue.

In a 2000 report to the Animal Care Committee of the University of Guelph titled "Guidelines to the Use of Beak Trimming in Poultry" (http://www.uoguelph.ca/research/acs/acs/guidelines/GuidelineHTMLFiles/BeakTrimmingInPoultry.shtml), Ian Duncan suggests that neuromas that form on the beak stump after trimming appear to cause chronic pain, including phantom pain. He concludes that "the decrease in welfare to the individual bird caused by the pain of beak trimming will conflict with any increase in welfare to the flock." Has the egg industry in Manitoba in 2005 discovered a better way to trim beaks than the one employed by the industry in Ontario in 2000?

Assuming that beak trimming, even by well-trained professionals, can result in neuromas and chronic pain and that a certain percentage of hens continue to suffer pain and fractures from osteoporosis and to develop skin lesions secondary to feather pecking, pulling and abrasion – how does the government fulfil its obligation under the Animal Care Act to "[provide] adequate medical attention" for these ill and suffering hens?

Is there a governmental responsibility to prevent avoidable illness and suffering? I’m thinking, for example, of the argument made by some poultry scientists that feather pecking/pulling and cannibalism could be very greatly reduced – and the need for beak trimming eliminated – if producers were compelled to use chickens genetically selected not only for productivity but for low aggression and pecking. I’m also thinking of the superior bone quality and greatly decreased tendency to osteoporosis, fractures on the farm or during depopulation and transport and layer fatigue in hens housed in environments that allow them to move freely, to perch and roost, etc. Shouldn’t Manitoba’s most powerful consumer advocate – our provincial government – be encouraging and, if necessary, compelling our egg industry to institute scientifically credible reforms that would relieve avoidable illness and suffering in millions of hens every year? Would you not agree that the government has legal grounds, if not a responsibility, to implement such changes based on the "provision of adequate space" and "opportunity for exercise" provisions of the Duties of the Owner in The Animal Care Act of Manitoba?

[In answer to my previous question re Duties of the Owner: "Is being showered with excrement from the cages above them considered adequate sanitation?"] This is basically a cage design issue and when this is a problem it is being addressed. Furthermore it is a potential disease source for birds when they have access to their excreta.

How is this being addressed and how does the government know it’s being addressed wherever it’s a problem?

As noted above the average floor allocation maybe 67 or 75 sq. in. but the effective allocation is actually some greater when birds are in a shared space, they do not use all of their space at the same time. It was also noted the osteoporosis is a nutritional issue and not an exercise issue. Osteoporosis has largely been addressed through adequate formulation of diets with increased levels of dietary calcium and phosphorus.

How big are the cages used in Manitoba egg barns and how many birds are usually housed per cage? I’ve seen 16" x 18" cited as a standard size; but with the Code calling for as much as 67 or 75 square inches per bird and a maximum of seven birds per cage, this would permit no more than four birds per cage.

Given that each hen will sometimes have much more than her "mouse pad" of floor space (and for the same reason, sometimes much less), to put it in real life terms, have you ever seen a hen flap her wings in a battery cage without disturbing her cagemates? Is it something she can do often, rarely, ever? What about just stretching her wings?