Family Friendly Farm

FDA at it again – Action required

The Food and Drug Administration (FDA) is up to their old tricks.  They have the mistaken notion that keeping wild birds and mice away from chickens will stop the transfer of Salmonela to eggs. Did I just hear your jaw drop? logo

Read more about it. The proposed guidance is called: Draft Guidance for Industry: Questions and Answers Regarding the Final Rule, Prevention of Salmonella Enteritidis in Shell Eggs During Production, Storage, and Transportation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)

As you can see it is intended only for those who raise the chickens outside. Hmm.. That would be all pastured poultry producers and organic farms. In theory it is for larger farms but the reality is once the guidance is in effect it will be pushed on all producers.

Recommendations include but are not limited to:20130225-223209.jpg

  • netting over all the pasture
  • 6 feet of gravel around all the edges of the pastures
  • sterilization every time we add in new chickens to the flock
  • trapping and baiting for all the wild mice, manual and glue boards are suggested
  • walls around the pasture
  • confining the chickens to the inside during times of the day when birds are migrating
  • cannons to scare off migrating birds
  • mechanical and physical fly traps

These may be very good measures to take and they may even be effective at reducing illness but I doubt it. Looking at the 2010 Salmonella outbreak (that caused 62,000 people to get sick and recalled 550 million eggs) more regulation would not have made a difference. Their hens were not even outside! AND they knew about the Salmonella problem for four months before the recall. This sounds like they just didn’t care to me.

For us, the small family farmer, to have a burdensome regulation placed on on is nonsense. We sell our eggs to the local people in our area though our on-farm store and area grocery stores. We know many, many of the people that buy them. They are our friends and loved ones. We work hard everyday to produce quality food that builds health. Regulations will not make us better farmers nor will it change the ethics of big agribusiness farms.

You can stop it, though. Comment by Monday! See my comments at the very bottom of the page.

We need you (and everyone you know) to comment by MONDAY, September 23rd, 2013. To comment you need to go to  http://www.regulations.gov/#!documentDetail;D=FDA_FRDOC_0001-4090. There is a spot on the upper right side where you can click to comment on this proposal. Look for the link at the top of the page it is BLUE and says Comment Now! The direct link is here but I can’t guarantee it will work.

Please forward this on to family and friends. There are only 1230 comments right now. Let’s show them the nonsense of the idea.

Let me say thanks in advance. We have some of the best customers. We are glad to serve you.  (See my comment at the very bottom of the page)

Broilers on pasture

Moved daily to fresh pasture, these chickens really get around. Can you imagine putting a roof or net on this? Ridiculous!

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My comment:

I am a small family farmer who has raises chickens for both meat and eggs. Although our flock size is under 3000 at this time I would hate to feel I need to limit it in the future. As such, I feel all the regulations and guidance do apply to me.The guidance is obviously intended only for those who raise chickens outside. That would be all pastured poultry producers and organic farms. In theory it is for larger farms but the reality is once the guidance is in effect it will be pushed on all producers. Additionally, there is a certain amount of scare tactic used in the wording implying there is a huge risk when keeping chickens outdoors. I haven’t seen the evidence of that over the course of time.
Recommendations that concern me include but are not limited to:*netting over the top of all the pasture
We have smaller flocks that roam large many acres. We move them daily to weekly. This would be ridiculously burdensome and impractical.*6 feet of gravel around all the edges of the pastures
This wouldn’t stop anything.

*sterilization every time we add in new chickens to the flock
Our mobile egg coops are designed to move with the hens. New hens are regularly rotated in and out a little at a time not all at once. The labor to do it all at once is impractical even at the small level we are at. A full overhaul is burdensome and impractical when direct marketing the older hens. Who would raise up such large batches of chicks and manage the huge egg volume fluctuations. We need a much more reliable supply then that would allow for.

*trapping and baiting for all the wild mice, manual and glue boards are suggested
You could never dent the population of rodents. Even if you did, what would move in their place? Think ecosystem. What happens when you take one part of the equation away? Imbalance is never good in the long run.

*walls or fences around the pasture
We use electrified netting to guide the chickens to the small part of the pasture where they should be on that day. There is no need for a full farm fence. Very costly and not useful. Smaller portable fences are the way to go.

*confining the chickens to the inside during times of the day when birds are migrating
Perhaps it was envisioned to let the chickens out at night when they are roosting? Nonsense! Surely this idea was not from an actual chicken farmer but a city dweller?

*cannons to scare off migrating birds
And what will the neighbors think? We have people all around us. What if a cannon hit someone! Not a reasonable suggestion at all. Maybe there are just noise making cannons, well you still have the neighbors and their children take naps. Then they would hate me.

*mechanical and physical fly traps
For what? We do see flies but it is hardly a problem. Not to mention the chickens would get stuck to they sticky traps and they wouldn’t be effect after a short time any way.

These may be very good measures to take and they may even be effective at reducing illness but I doubt it. Looking at the 2010 Salmonella outbreak (that caused 62,000 people to get sick and recalled 550 million eggs) more regulation would not have made a difference. Their hens were not even outside! AND they knew about the Salmonella problem for four months before the recall. This sounds like they just didn’t care to me.

For us, the small family farmer, to have a burdensome regulation placed on on is nonsense. We sell our eggs to the local people in our area though our on-farm store and several area grocery stores. We know many, many of the people that buy them. They are our friends and loved ones. We work hard everyday to produce quality food that builds health. Regulations will not make us better farmers nor will it change the ethics of big agribusiness farms. These regulations/guidelines that are a one size fits all don’t work. There is too much diversity in a well run farm to apply agribusiness principles and practices. Farmers who care will always go the extra mile to make their farm and food the best they can. Farmers (or agribusiness corporations) who don’t care just won’t won’t make the effort no matter how much regulation there is. That is the bottom line.

Thank you for your consideration to this matter.

Comments are closed.

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