The Queensland Egg Farmers Association is concerned by increasing demands from animal rights groups who are seeking to ban the production and sale of eggs produced by caged laying hens.

The following response to Animal Liberation and RSPCA demands for the banning of caged hen egg production in Queensland was issued by the Queensland Egg Farmers Association on 28 July, 1999:

The RSPCA and Animal Liberation movements' recent campaign raised many highly emotive issues. The QEFA believes these to be either false or highly misleading:

These organisations claim that:

• Hens spend their lives with between three and seven other flock mates.
  This is false! The correct numbers are usually from two to four flock mates.
• Hens' feet and legs are crippled.
  This is false!
• Hens stand for life on an area no larger than an A4 page.
  This is False! Hens can and do sit when housed in cages and while the space occupied by a laying hen varies from time to time, they generally enjoy an area larger than an A4 page.
• Battery hens are prone to bone breakages.
  This is false! Studies conducted by Dr. Greg Parkinson at the Victorian Institute of Animal Science show that:
  • the incidence of bone breakage in caged layers as opposed to barn laid and other non-free range floor system layers is similar. No similar studies appear to have been carried out on free-range birds.
  • most fractures occurring in the caged system are during depopulation.

Dr. Parkinson concluded that the caged system has the potential to reduce bone fractures and that any problems using the caged system are management related, rather than system related.

• Claims regarding 'debeaking' are either incorrect, highly exaggerated or based on outdated information. Chickens are by nature cannibalistic and will attack another sick, injured or disabled bird. Beak trimming overcomes this natural instinct. Recent industry research, mostly Australian and part funded by industry, indicates that the nerve endings of trimmed beaks do not re-grow and that birds are able to eat and drink normally.
• Claims regarding prolapse and tumors are exaggerated. Dr. Parkinson advises that prolapse and tumors occur in all production systems.
• Claims regarding "birds being dragged from their cages" are exaggerated. However, the QEFA is working to improve the handling practices of some external industry contractors.
• Half of all chickens hatched are male. Claims that most are killed at day old are True!
  Unfortunately, male chickens don't lay eggs. However, due to lower rates of egg production under non-caged systems, if we were to insist that all eggs be produced under these systems, more male chicks would have to be hatched and killed.
• Food safety concerns implied by Animal Liberation are questionable.
  Queensland's egg industry abides by a clearly defined Code of Practice developed by the Australian Egg Industry Association. This quality control system covers all aspects of grading, packaging and distribution of eggs within Australia. It is designed to ensure that only those eggs considered fit for human consumption in shell form reach the consumer.
• Claims about industry policy in other countries are misleading.
  Caged egg production remains in Sweden and we question the methodology, sample size and validity of survey results regarding the banning of caged egg production.
• 'Unhappy' hens do lay eggs. True!
  But caged hens generally lay more eggs than non-caged hens and well managed flocks have higher rates of lay than poorly managed flocks.
• The citations referred to by Animal Liberation are at least 10 years old. Considerably more research and information is known about animal welfare in laying hens than is implied by Animal Liberation.

Comparison of Various Egg Production Systems

Reports of studies conducted overseas strongly indicate that the cage system is the least expensive form of egg production, while the free range system is the most expensive.

While the QEFA believes similar results would be found from research conducted in Australia, it would be unwise at this stage to rely on overseas comparisons due to differing land costs, shedding, stock feed prices, bird varieties, labour rates and other cost inputs.

In its Biennial Report 1996-1998, the Queensland Poultry Research and Development Centre undertook research to assess the effects of cage modifications to meet possible code of practice variations, especially relating to stocking density. The findings of this research may have relevance to the proposal that Australian producers adopt the same Edinborough Modified Cage (EMC) system as Europe. After 52 weeks of lay, the findings showed that the low density cage systems produced less favourable conditions for the hens, lower quality eggs and higher production costs. It was concluded that the EMC system used for this experiment required significant redesign in the cage configuration to be considered as a practical alternative to traditional housing systems.(QPRDC Biennial Report 1996-1998, pp 30 & 31)

Other financial considerations relating to free range production in particular include the need for extensive areas of land on which to house the birds, extensive fencing requirements to protect the birds from predatory attack and additional labour costs to feed and care for the birds and to collect eggs.

In Switzerland, where caged bird egg production was banned in 1987, eggs continue to be imported from other European countries using caged bird systems. These countries have now captured over 50% of the Swiss market and by September of 1998, retail egg prices had risen to the equivalent of US$6.68 per dozen.(Currently approximately AUD$10.28 per dozen), placing eggs in the 'luxury' food category. Swiss retail egg prices are thus about four times higher than those currently enjoyed by Australian consumers.(AEIA Submission to the Productivity Commission, September 1998, pp 32)

In EU countries, where farm ministers recently voted to phase out all caged hen egg production by 2012, the cost to British egg producers alone is conservatively estimated to exceed A$725 million and there is considerable doubt that the industry will be able to comply with the 2012 production ban.

Public Health Concerns

Public health concerns relating to eggs in Europe and North America have increased in recent years. While the underlying reasons for this do not presently exist in Australia, there is increasing community awareness and concern relating to public health and food safety issues. The level of community concern in Australia is clearly evidenced by recent media reaction to food poisoning incidents involving peanut butter, salami and even water.

The presence of salmonella in eggs in the U.K. in 1988 led directly to the resignation of a cabinet minister from the Thatcher government and resulted in world-wide adverse publicity for the UK government's health standards and the egg industry in general.

Queensland egg production methods deliver safe, nutritious eggs under the most hygenic systems available. The risks of contamination from salmonella are considered to be greater in floor based systems than the caged system. This risk has been recognised by microbiologists for many years.

The QEFA believes that the excellent quality of Queensland's eggs is more likely to be compromised to the community's and industry's detriment if a ban is placed on the production and sale of eggs from caged birds.

Environmental Considerations

It is estimated that Queensland would require a minimum of 5,000 acres of land to accommodate the State's existing 2 million hens using free range production methods and a minimum of 10,000 acres to accommodate this number of birds without risking environmental damage.

Considerable additional shedding and other protective measures would also be required to safely house existing flocks. Both barn and free range birds must be protected against predatory attacks from dogs, snakes, lizards and wild birds and unfortunately, it is costly and difficult to convert existing caged sheds to barn or free range production.

Conflicting land use demands, especially in areas that are in close proximity to major markets in city centres, also mitigate against any major expansion of barn or free-range egg production.

All things being equal, these aspects point to caged bird production methods delivering a more environmentally friendly and efficient system of egg production.

Consumer Attitudes

To date, no studies have been conducted by the QEFA seeking to measure consumer awareness or attitudes relating to egg production or price elasticity under alternative production methods.

While Animal Liberation claims consumer research indicates support for its cause, the size of the survey represents less than one tenth of one percent of Queensland's population (approximately the same number of people who currently purchase free-range eggs). We are currently seeking to commission independent, unbiased research into this issue.

We intend stepping up our own consumer awareness programs to ensure that the public has access to factual information that is free from media bias and sensationalised comment. Our aim is to guide consumers and to provide factual information that will assist them with their egg purchasing decisions.

Egg Carton Labelling

QEFA members have responded to Animal Liberation's demands for egg carton labelling to include a description of the production system of origin. In principle, the QEFA members have no objection in this proposal. Eggs are now clearly labelled as being 'caged eggs', 'barn' eggs or 'free range' eggs. There is no confusion in this, although there is no legal precedent among other food products for this form of labelling.

However, Animal Liberation's labelling demands do raise legal questions in relation to other egg products. What might be the labelling requirements for the sale of eggs on key trays to hotels, hospitals, defence forces or take-away food stores? Will those eggs need to be labelled and if so, how? What rational policy base exists for any difference in the approach to customer type or the purpose for which eggs are used?

Finally, how will authorities enforce any legislation? Will government officials be employed to check retail outlets to ensure that eggs are not sold from caged bird farms, or to verify that eggs contained in 'free range' or 'barnyard' cartons are in fact produced under those methods? How will authorities verify that imported eggs sold as 'free range' or 'barnyard' eggs do not contain caged hen eggs? Perhaps the government will need to legislate an enforceable definition.

Uniform Food Regulations

Uniform national food regulations and moves towards self-regulation are two of the underlying principles that have emerged in Australia in recent years. These developments recognise that a broad shift in public administration is underway in Australia, whereby uniform policies developed at a national level are delivered through other tiers of Government assuming responsibility for implementation. A recent review of food regulation undertaken by a committee chaired by Dr Bill Blair makes it clear that:-

"the Commonwealth, State, Territory and local governments act together to:- 'give significantly greater impetus to achieving a well integrated, streamlined and cost effective co-regulatory system to effectively protect public health and safety across the whole food supply chain...." (Recommendation 1).

"Commonwealth, State and Territory governments should develop and implement a nationally uniform food safety regulatory framework that adopts a preventative approach, applies to all agrifood businesses and places a legal obligation on these businesses to produce safe food." (Recommendation 10A).

"The food safety regulatory framework should be supported by a nationally consistent and transparent system for assessing food safety risks and categorising business and industry sectors according to risk." (Recommendation 10 B).

"In developing the national food safety regulatory framework, governments should pay particular attention to minimising costs incurred by business in implementing and maintaining preventative food safety programs, and to ensure the benefits of this approach to food safety regulation outweigh the costs." (Recommendation 10 C).

"The governments of Australia to agree that all domestic food laws in Australia should be developed nationally and enacted uniformly. All existing food laws should be reviewed with the aim of improving national uniformity." (Recommendation 11).

These recommendations contrast sharply with the strategies currently being adopted by the RSPCA and Animal Liberation and it is clearly evident that their strategies are contrary to the committee's viewpoints in relation to a number of issues.

World Industry Trends

The Queensland egg industry is small in a global context. The US based organisation Watt Publishing Company estimated that world egg production in 1996 totalled 44.71 million tonnes, an increase of 4% over 1995 and three times the production output of 1961. In that period, growth was strongest in third world countries.

Asia now accounts for over half of the world's egg production.

Asian countries are now moving strongly towards caged bird egg production.

All countries now recognise that in all industries, participants need to be well organised, well trained and well integrated. In Australia, the caged system of egg production offers the best opportunity for this to be achieved and to best serve the interests of consumers.

It follows that preventing producers from producing and selling eggs from the caged system will lead to more complex demands in terms of farm production, storage, handling, grading and distribution.

Undoubtedly pressures will continue to mount for the Australian government to ease quarantine restrictions which will allow the importation of cheaper eggs from foreign countries.While most other countries provide assistance to their egg producers, the QEFA recognises that there is little likelihood that the Australian government will follow their lead. Thus, it is imperative that producers maximise their international competitiveness. The most logical way to achieve this is to ensure that there is a public policy climate that encourages long term investment to improve industry efficiency, human welfare and bird welfare.

Future Directions

Provided there remains an absence of any legislation to ban caged bird egg production the QEFA predicts that:

Demand for barn and free range eggs will be driven by population trends and regional household demographics. There is an underlying societal need for the elderly and socially disadvantaged to be able to continue to purchase quality, safe, nutritious eggs at the least cost.

Research into alternative egg production methods in Queensland and in Australia has been minimal to date. However, Queensland's producers are now demonstrating their willingness to fund appropriate research that will benefit both the industry and consumers.

Growth will continue in the non-cage sector of the egg market. However, this growth will require extensive animal husbandry training programs as additional producers attempt to enter an industry in which they have little or no prior experience or knowledge.

The QEFA will continue to work closely with the Australian Egg Industry Association to set and maintain national egg production standards that are recognised as delivering world's best practise methods.

Within the next 10 to 15 years, it would not be surprising to see an industry dominated by caged systems in which hens are housed in fully controlled environments. With appropriate guarantees that will reinforce the viability of egg producers continuing to invest in the welfare of their flocks, it is likely that many sheds will contain features only dreamt of today.

The caged system offers the greatest scope for the development of all aspects of egg production, including animal welfare, animal health, environmental sustainability, food safety and economics.

The QEFA believes the banning of caged bird egg production will result in severe industry rationalisation resulting from unwanted and unintended consequences of such government intervention. The worst case scenario would see Queensland's egg production move offshore with the inevitable degradation of the freshness, quality and safety standards Queensland's egg consumers have enjoyed for so many years.

Compensation

The QEFA believes any amendment to State laws that precludes the production or sale of caged bird eggs will impose severe financial hardships on the State's egg producers and the Association will vigorously seek compensation for loss of assets and loss of income from the Queensland government.

The QEFA believes that extensive consultation between government and producers will be required before any revisions are made in relation to the production, packaging and distribution of eggs in Queensland.

(The QEFA acknowledges the valuable contributions made by Hugh McMaster, Executive Director of the Australian Egg Industry Association Inc. who provided information contained in his Submission to the Productivity Commission in Relation to the Banning of Battery Egg Sale and Production in the ACT. Information prepared for this report has been included in sections of this response.)

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