State veterinarians across the nation are reviewing a recently proposed U.S. Department of Agriculture rule that eliminates the approval of outdoor porches for hens from the National Organic Program, instead requiring direct exposure of hens to the outdoors. Recently, California state veterinarian Dr. Annette Jones expressed concern with the rule in a comment to USDA.

Jones urged USDA and its Agricultural Marketing Service (AMS) to reconsider this proposed rule, especially the outdoor access requirements that may pose serious animal health and food safety concerns.

“This proposed change may demonstrate a lack of coordination between federal agencies and will likely stimulate further criticism and frustration from those trying to comply with the cobweb of sometimes conflicting rules and regulations,” Jones wrote on behalf of the California Department of Agriculture. “Not only would eliminating porches seriously curtail the ability of organic egg producers to comply with USDA Veterinary Services’ request to enhance biosecurity barriers to disease introduction from wild birds, but it will also make it difficult for them to comply with the U.S. Food & Drug Administration’s requirements to prevent the introduction of Salmonella enteritidis from wild birds and other sources.”

Current organic production methods protect birds from disease and allow careful management to protect hen health while still allowing access to the outdoors. The proposed rule would eliminate the use of porches, which are a reasonable option for organic egg producers to prevent the spread of disease, Jones wrote.

The new rule would require direct outdoor exposure and contact with birds and animals that spread disease. Last year’s massive, deadly outbreak of highly pathogenic avian influenza came from wild birds.

In its analysis of the proposed rule, USDA noted that, if implemented, the rule would cause an increase in hen mortality, in part due to disease.

“AMS assumed that the mortality rate for hens would increase from 5% to 8% if this proposed rule is finalized,” according to the USDA analysis included in the proposed rule. “The increased mortality would chiefly be attributed to increased predation, disease and parasites from greater outdoor access.”

This analysis does not seem to contemplate increased exposure to less frequent but more devastating diseases like influenza and exotic Newcastle disease, Jones wrote. “Regardless, many veterinarians would consider a 3% increase in mortality rate too high,” her letter stated.

Many poultry experts have indicated that the USDA estimates are considerably below the experience of many production systems where hens have outdoor access without protection. Notably, a study by North Carolina State University showed that mortality in free-range egg-laying hens ranged from 13.5% to 30.7%.

The comment period on the USDA rule closes June 13. For more on the rule, read our initial coverage as well as concerns raised by those on Capitol Hill.