Pastured Poultry News

The American Pastured Poultry Producers Association (APPPA), on behalf of our members, submits these comments relevant to the clarification of the label claim of “free range” for poultry products [Docket Number FSIS-2016-0021].

Based on consultation with the AMS, FSIS currently deems the terms “Free Range,” “Free Roaming,” “Pasture Fed,” “Pasture Grown,” “Pasture Raised,” and “Meadow Raised” to be synonymous. By treating all these potentially different management scenarios as synonymous, the proposed directive opens the door for confusion on the part of the producer as well as the consumer.

In their discussion about how the specific claims around these terms are to be made, the proposed FSIS directive states that the documentation “must describe the housing condition for the birds” and “must demonstrate continuous, free access to the outside throughout [the birds’] normal growing cycle.”

However, FSIS has also been clear that it does not want to engage in a definition of these terms, nor in prescribing and auditing specific husbandry practices.

The wording of the proposed directive allows poultry products to be labeled as “pastured raised,” even if the birds have never been outside on pasture in their lives. Additionally, being “outside” is not synonymous with being “on pasture.” Pasture implies vegetation rooted in soil, which is either actively growing or that has been stockpiled for use in the non-growing season.

Access to the Outside / Being Outside Should be Defined more Clearly

Poultry group dynamics ensures that birds who have “access to the outside” may never actually leave their social groups and their area of the house to walk to – and then venture through – the (typically very small) access doors to gain access to open outdoor air.

Additionally, the FSIS directive states, “During winter months in northern climate, birds are not free range if they stay in poultry housing or coops all winter.” While APPPA and our members commend FSIS for clarifying the difference between winter and other seasonal housing, this part of the directive does not offer enough clarity.

In this situation, FSIS deems birds are not free range if they stay in the coops and housing all winter, but does not differentiate this situation from the birds who, by virtue of their normal social behaviors and / or relative lack of access to suitable doors (size, number and location), do not move outside using the pop doors in other seasons. This seems incongruous.

Pasture Raised Eggs and Chicken are Nutritionally Different

There is evidence to support that poultry raised on viable, rooted-in-soil pasture display a nutritional profile that is different than poultry raised in confinement and / or in dirt-lot situations. Multiple research papers, supported by privately funded nutritional testing of poultry raised on growing pastures in a management system that incorporates movement across those pastures, show that there are differences in the nutritional profiles of the pastured birds.

Because of this evidence and because there is additional research currently in progress, APPPA requests that FSIS reconsider their opinions. This research compares the nutritional components in the meat and eggs of pasture-raised birds compared to that of birds raised in other circumstances, including free range.

Logic and laboratory work indicate that claiming “Free Range” as equivalent to “Pastured Raised” would construe and support misleading and untruthful claims.

This lack of clarity and specificity is misleading to consumers and contributes to labels that are not truthful and misleading.  The consumer who is seeking out pastured poultry products specifically because of the differences in nutritional value has expectations about the way the label on the poultry accurately reflects the product contained within the packaging. Continuing to consider these different management practices as equivalent could result in products that are negligently misbranded using fundamentally incorrect labels. 

APPPA proposes that FSIS continue to collate and study the available data and make an empirical assessment of the differences in nutritional content among the meat and eggs from birds raised in different husbandry models, including but not only, pasture-raised and free range. Further APPPA proposes that the final rule be delayed until such time as the research is more fully completed.

Pasture Raised Not Synonymous with Free Range

Since the mission of FSIS includes “ensuring the nation's commercial supply of poultry is correctly labeled and packaged,” it seems self-evident that the guidance offered regarding “Free Range” and “Pasture Raised” should include a clear definition of the claims being made on the labels.  

The current definition of free range is inherently accurate: poultry are “Free to Range,” meaning they can stay indoors or go outdoors as they so choose.  In the Free Range system, a bird can stay indoors its entire life and still be accurately labeled as free range.  That would be an accurate and correct use of the Free-Range label, but it would not represent a Pasture-Raised bird.

We also realize that most poultry must spend their first weeks in a very controlled environment (the brooder) in order to survive. (This is similar to the weaning period for ruminants.). It is unreasonable to propose that requirements for poultry that are “pasture-raised” include the provision that they “[must] demonstrate continuous, free access to the outside through [the birds’] normal growing cycle.”

An accurate description of “pasture raised” is that each bird lives more than 50% of its life on pasture that is covered by rooted-in-soil vegetative cover, which is typically achieved by flock movement to fresh pasture.

APPPA recommends that FSIS does not consider “Pasture Raised” synonymous with “Free Range” based on a growing body of research and fundamental differences in the approach of each system. APPPA proposes further discussion and collaboration with FSIS to more accurately define pasture raised poultry and eggs as a product that is inherently different than free range.

The APPPA member response to the COVID 19 outbreak has been filled with grace, compassion, and strength in community. I (Mike Badger) have been checking in with people throughout this last week and everyone is busy serving their communities with access to locally produced food.

Farms are literally shifting sales models on the fly from wholesale to direct sales with delivery routes, shipping, and running hard to meet an increased demand. They are forming collaborative sales groups quickly and sorting out the details as they go. Farms are holding prices stable despite high demand.

It's too early to know what the new normal will look like for pastured poultry farms after this outbreak subsides.

Here is something I do know.

Farmers, you are essential.

Communities are rediscovering how essential you are.

When the store shelves are bare, it is APPPA members and farmers like them who are stepping in and bringing a reassuring face to their food.

I am not surprised. I am thankful.

This is the type of rapid, personal, food secure approach a local and regional economy promises. While you're running and shipping, you should know people notice your actions, and we appreciate them.

--Mike Badger

Jacksonville, FL—APPPA welcomes Dr. Michael Fisher, retired United States Department of Agriculture (USDA) Food Safety and Inspection Services (FSIS) veterinarian, to the Professional Pastured Poultry Conference from January 21-22, 2020. Dr. Fisher will be available to help small family operations avoid regulatory problems with FSIS.

Dr. Fisher will lead a discussion on getting the hazard analysis right by focusing on the most common and significant problems he has encountered. “Get the hazard analysis right and life can be good.  Get it wrong, and life is an unending series of regulatory problems for which there is no solution,” says Dr. Fisher.

APPPA will solicit questions from registered attendees prior to the conference, so that Dr. Fisher can come to Jacksonville with answers prepared for those questions. While in Jacksonville, Dr. Fisher will be available for one-on-one consultation and discussion.

Dr. Fisher writes a blog series sharing his expertise with FSIS regulatory issues on the Farm-to-Consumer Legal Defense Fund website. This will be the second APPPA conference he has attended as an expert resource.

American Pastured Poultry Producers Association is a member-based trade organization advocating for pastured poultry through farmer specific resources and consumer education.

Learn more about the Professional Pastured Poultry Conference.

Contact Mike Badger at grit@apppa.org or 888-662-7772.

Jacksonville, FL—Nathan Bonds, Lean Management expert will provide in-depth training at the Professional Pastured Poultry Conference in Jacksonville, FL on January 20-21, 2020. By leveraging the principles of Lean, Nathan will help farmers become more efficient, reduce waste, and improve quality across all phases of the farm.

The systematic approach of Lean will provide customers the three things they want: quality, cost, and service.  Nathan says, “As farmers, we want to meet what our customers want, but we also want to lead them to what they need. Lean is about people. We’re going to focus on the people who focus on the process. It’s about our relationships.”

Nathan will teach workshops on how to get started improving your processes and strategies for managing your labor force (employees) on the farm. He will also lead breakout discussions and be available as an expert resource on both days of the conference.

Pat McNiff, Owner of Pat’s Pastured, says, “In only three days, Nathan helped us cut our daily labor moving chicken shelters by half when everyone thought it couldn’t be done.” Nathan’s consultation, methodical approach, and endless passion has been instrumental in the continuous and steadfast improvement of Pat’s Pastured, Maple Wind Farms, and other pastured poultry farms in New England.

Nathan is a Project Manager with Polaris MEP, a Rhode Island organization that helps companies refine processes, build talent pipelines, and break into new markets. An article summarizing Nathan’s 2019 conference presentation can be read at this link. You can watch Nathan Bonds deliver his “Lean Tip of the Week” on YouTube.

American Pastured Poultry Producers Association is a member-based trade organization advocating for pastured poultry through farmer specific resources and consumer education. Learn more about the 2020 Professional Pastured Poultry Conference.

Direct questions to Mike Badger at grit@apppa.org or 888-662-7772.

Jacksonville, FL—American Pastured Poultry Producers Association (APPPA) welcomes Resaca Sun Feeds as the “Partner Sponsor” for the 2020 Professional Pastured Poultry Conference in Jacksonville, Florida, on January 19-21, 2020. Resaca Sun Feeds specializes in the production of high quality, pastured-raised poultry feeds using Non-GMO Project Verified ingredients. They are a family-owned feed mill located in Resaca, Georgia.

Sponsors play a vital role in the Professional Pastured Poultry Conference by helping to create robust conference experiences at affordable registration prices and by providing attendees personal access to industry leaders. APPPA encourages all our sponsors to be involved with the conference programming as participants and contributors. The flexible and spontaneous nature of the conference facilitates a more natural engagement between supporting businesses and the farmer attendees.  

Andrew Moore, third generation farmer and feed mill manager will lead a session on sourcing feed ingredients and working with feed mills in the “Profitable Pastured Poultry” pre-conference course (January 19, 2020).

American Pastured Poultry Producers Association is a member-based trade organization advocating for pastured poultry through farmer specific resources and consumer education. For more information about the Professional Pastured Poultry Conference can be found at apppa.org/Conference.

Additional sponsor and exhibitor opportunities remain open through December 1, 2019. Contact Mike Badger at grit@apppa.org or 888-662-7772 for additional information.

Jacksonville, FL—APPPA expects international attendance by pastured poultry farmers at the Professional Pastured Poultry Conference, scheduled for January 19-21, 2020, at the Lexington Hotel and Conference Center in Jacksonville, FL. The conference brings independent, family-owned pastured poultry farms together for three days of peer-to-peer learning opportunities. Conference organizers encourage attendees to bring their struggles and their success stories because there’s someone in the room who has solved your problem or needs your help.

American Pastured Poultry Producers Association (APPPA) has been providing farmer education and networking opportunities to the community since 1997. As the pastured poultry community grew more experienced in the production, marketing, and processing segments, APPPA identified an unfilled need. Experienced community members needed advanced conference programming that went beyond the basic startup and the how-to information provided by the typical conference workshops. The Professional Pastured Poultry Conference fills that need.

In 2017, the Professional Pastured Poultry Conference was launched in a rodeo arena in Hillsboro, Texas. Those two days flipped the conference script and made the attendees the keynote speakers as several dozen farmers discussed issues in real-time without a single PowerPoint. In 2020, the conference format is expanding to be welcoming and relevant to farmers at all scales and experience; however, spontaneous, attendee-led discussion remains the event’s signature attraction.

American Pastured Poultry Producers Association is a member-based trade organization advocating for pastured poultry through farmer resources and consumer education. More information about the Professional Pastured Poultry Conference can be found at apppa.org/Conference.

Contact Mike Badger at grit@apppa.org or 888-662-7772.

Washington joins California and Massachusetts by signing legislation that prohibits eggs from caged hens to be sold within the state. While the Washington law won't be fully enacted until 2023, American Pastured Poultry Producers Association (APPPA) would like to remind everyone that pasture-raised hens always lay cage-free eggs.

Cage-free pasture-raised eggs are available now throughout the United States using our find-a-farmer directory.

The clear message for egg producers is that as consumers become educated about industry practices, they reject many of the practices the industry markets as necessary. 

(H/T Feedstuffs)

A recent news release announced the formation of a chicken company that claims to be the only company at scale to raise slower growing heirloom chickens in an integrated pasture-raised model. The American Pastured Poultry Producers Association (APPPA) would like to offer the poultry community a better understanding of what the current pastured poultry community looks like and what it really means to be pasture-raised.

Pasture-Raised Chicken Is Movement Based

To provide clarity, pasture-raised poultry describes a farming method that builds on the core idea of outdoor production and flock movement. The simplified version is that the chickens or turkeys are raised outside in portable shelters; the shelters and the flock are moved to fresh pasture regularly, allowing the previously grazed area to rest and regenerate.

In modern chicken company marketing (and some third-party certifications), you will see terms like “outdoor access” or “access to pasture.” These phrases warn the consumer of a non-pasture raised method of production. Visual inspection provides the verification. If you see a fixed location confinement animal feeding operation (CAFO) style house with a few doors around the building opening into a small fenced in area, you’re not looking at a pastured poultry model. Those types of facilities meet the USDA definition of free range (read more about the difference).

The distinction among the models must be swift and clear for consumers because it is the movement-based model that puts the birds outside on the grass in the sunshine. This builds nutrition in the chicken and eggs. Movement-based pastured poultry ensures healthy chicken that can be raised without coccidiostats or other antibiotics. The model of regular movement followed by a period of rest regenerates the land by building soil and improving fertility.

In other words, the difference that consumers expect are a result of the farming model. When chicken and egg companies short-circuit the pasture raised model by not incorporating flock movement or real outdoor production, they short circuit difference. Consumers are left paying the price.

A Diverse Pasture-Raised Poultry Community

In January 2019, independent pastured poultry farmers from 36 states, two Canadian provinces, and Haiti attended the APPPA Professional Pastured Poultry Conference in Greenville, TX. At that meeting, you could find farmers who were raising broilers, layers, turkeys, heritage birds and commercial birds. You could find producers at a variety of scales including farmers raising 1,000 birds or 300,000 or any number in between. There were farmers, feed manufacturers, breeders, processors, marketers, and distributors.

Inside the diverse APPPA membership, we have farmers raising slower growing broilers in a pasture raised model for processing in an on-farm USDA facility. There are on-farm processors working in exempt facilities. Some APPPA members have been refining nationwide mail order shipping as significant sales channels.

There are APPPA member farms raising fast growing hybrids, heritage breeds, and the slower growing hybrids in between. The diverse configuration of farms that comprise the pasture raised chicken and egg community is too difficult to name inclusively. That diverse community of APPPA farmers, however, is firmly rooted in the movement-based pasture raised model of farming.

Access to Pasture Does Not Equal Pasture-Raised

Pastured poultry farmers and members of APPPA have worked hard to cultivate the pasture raised chicken and egg difference over the last 20+ years as an association. The farmers who spend a lifetime perfecting their craft demand that pasture-raised chicken and eggs means more than “access to pasture.” Access alone is not good enough to capitalize on the decades of innovation inside the community.

American Pastured Poultry Producers Association has been advocating for pastured poultry production, processing, and consumption since its founding in 1997. We encourage farmers to keep the model movement based. We encourage consumers to watch the “Pastured Poultry: Better Way Forward” and view the Pastured Poultry Consumer Buyers Guide.

For questions, contact Mike Badger, grit@apppa.org or 888-662-7772.

In March 2018, the Office of Inspector General (OIG) released a report detailing $1.8 billion in ineligible loans that the Small Business Administration (SBA) guaranteed for contract poultry growers to build barns. Specifically, the OIG reviewed loans to determine if they were compliant with regulatory, statutory, and SBA requirements for eligibility.

The bottom-line result, as stated in the report, was that the “loans made to growers did not meet regulatory and SBA requirements for eligibility. The large chicken companies (integrators) exercised such comprehensive control over the growers that SBA Office of Inspector General believes the concerns appear affiliative under SBA regulations.”

SBA loans can be made for up to $5 million to fund startup costs, expansion, equipment purchases, and other uses. The SBA guarantees the loans, which means U.S. taxpayers are ensuring that the lenders will have loan repayment. It’s a subsidy by U.S. taxpayers to fund a production model that primarily benefits the integrator by offloading the risky grow out portion of production to the farmer and to the public through the subsidy.

At the heart of this discussion is the determination of affiliation. SBA in it’s public recommendations to update the loan program, is proposing that small businesses must meet an affiliation test. If more than 85% of a small business’ revenue comes from another business, then that small business would be affiliated with the other company and not an independent small business. Note that this has nothing to do with legal structures of the business. Instead, this is assessing the relationship between the contract poultry grower and the integrator.

If you want further reading of the OIG’s report, look up the report titled “Evaluation of SBA 7(A) Loans Made to Poultry Farmers.”

As you might imagine, this affiliation test is deeply opposed by the large chicken companies because funding the grower houses is expensive and high risk (that’s why they need to be guaranteed by the federal government).

APPPA submitted comments in support of the affiliation test being proposed by SBA in the Federal Register on Friday, September 28, 2018. APPPA responded to these parts:

SBA proposes to expand the principle of affiliation arising from “identity of interest” to include common investments and economic dependence through contractual or other relationships between any two or more individuals or businesses, reinstate the “newly organized concern” rule, reinstate the “totality of the circumstances” analysis when determining affiliation between an Applicant for financial assistance and other entities, and clarify affiliation based on a franchise or license agreement.

If a small business Applicant derived more than 85% of its revenue from another business over the previous three fiscal years, SBA would find that the small business Applicant is economically dependent on the other business and, therefore, that the two businesses are affiliated.

Our comments follow.

The American Pastured Poultry Producers Association (APPPA) welcomes the Small Business Administration’s (SBA) attempt to establish and enforce an affiliation test for contract poultry farmers. Recognizing affiliations in the 7(A) loan applications protects the farmers, the public, and a fair marketplace.

APPPA is a non-profit membership-based organization that provides educational resources to pastured poultry farmers who are operating small businesses in rural America. The association represents approximately 1,000 member farms. APPPA was formed in 1997 to support a renewed interest in pastured poultry.

The growing pastured poultry industry does not rely on single grower contracts to produce chicken, eggs, turkey and other poultry; it instead relies on regional, decentralized, and direct-to-consumer markets. The pastured poultry business model stands in stark contrast to the consolidated and disconnected model of the contract poultry farmer.

The Office of Inspector General (OIG) report “Evaluation of SBA7(A) Loans Made to Poultry Farmers” (report number 18-13) from March 6, 2018, is clear in its finding that “7(a) loans made to growers did not meet regulatory and SBA requirements for eligibility” because the poultry integrators exercised complete control over how and when contract growers raised poultry.

The OIG details $1.8 billion in guaranteed funds that were loaned to pay for single use facilities designed for the needs of one “customer.” In a contract poultry environment, the farmer doesn’t even own the birds. The contract grower makes the facility available to house flocks from the integrator through short-term contracts and often with no contractual assurances that the grower will have flocks to pay for the facility in the future. While poultry integrators may be able to find contract growers to hold up as successful examples, the aggregate findings of the OIG paint a bleak economic picture and business model.

Based on the OIG reporting, APPPA has the position that by approving 7(A) loans for contract poultry, SBA is:

1. Allowing the American taxpayers to assume substantial risk and cost to raise the poultry while allowing the poultry integrators to become the primary beneficiary of a tightly integrated business model.
2. Perpetuating a decline in the rural American economy by encouraging high risk business practices through the approval of 7(A) loans for contract poultry growers.
3. Facilitating a competitively disadvantaged marketplace in favor of poultry integrators who can keep costs low by shifting the riskiest part of poultry production onto family farms. Those risks are guaranteed by the public.

Affiliation Rules

Regarding the Summary of Proposed Changes to Affiliation Principles for the Business Loan, Business Disaster Loan, and Surety Bond Guarantee Programs (Section II B), APPPA supports the proposed affiliation principles outlined in Section 121.30.

This is an opportunity to make SBA aware of commercially viable poultry farming businesses that do not follow the contract grower model. Pastured poultry businesses, as a guiding principle, rely on a diverse number of customers to reduce risk from the loss of any single source of revenue. In addition, pastured poultry farms build infrastructure to be as multi-purpose as possible, so that the farm can be responsive to growth opportunities and market changes while proactively leveraging previous investments.

The very nature of the poultry contract model is one of continued consolidation with farms growing larger in terms of animal concentrations and loan requirements (Figure 6: Growth in Annual Average 7(A) Poultry Loan Size, FY 2012-2016 of OIG Report). This consolidation of ineligible loans ultimately reduces the availability of SBA loans to competing businesses, such as pastured poultry farms, thereby enabling an unnatural competitive advantage in favor of the poultry integrators.

Regarding proposed affiliation principles in Section 121.30, APPPA recommends:

1. SBA determine that two businesses are affiliated if one business (e.g., contract poultry grower) receives more than 85% of its revenue from the other business (e.g., poultry integrator).
2. SBA provide clarity to lenders by stating that the relationship between a poultry contract grower and an integrator is an affiliation, and that the poultry contract grower is not acting as an independent small business when applying for loans to build a single purpose facility to receive revenue from one source. According to the OIG’s report, the contract grower’s facility loses between 62% and 94% of its value without a contract from the Integrator (Table 1 from Office of Inspector General (OIG) report “Evaluation of SBA7(A) Loans Made to Poultry Farmers”).

Summary

APPPA encourages the SBA to enact the affiliation thresholds and clearly define the relationship between poultry grower and poultry integrator as a dependent business relationship. In so doing, APPPA believes the SBA will do its part to remove unequitable subsidies that create unfair pricing advantages for the consumer while unburdening the taxpayers from guaranteeing these poultry contract grower loans.

Of all the things I like about the pastured poultry community, the diversity of business models is perhaps one of my favorites.

In 2017, APPPA assembled a group of producers to have a meeting about pastured poultry. We primarily sought people who were “scaled up” or in the process of scaling up.

Two things struck me coming out of that meeting. First, the idea of scale is ambiguous. Every person will have a different idea or a caveat.

Second, was the diversity of business models, and this is my favorite thing. We had a producer in his retirement years cranking out a total of 3,000 broilers a year and loving life. His claims were more profit, better lifestyle, and an off-season, to name a few.

He was turning each chicken into $30-$40 through a value-added product approach. He had been raising and selling poultry for something like 30 years. He did the scaled-up numbers thing through wholesale and retail outlets. Now, I guess you could say he was scaled up in experience.

What I want you to see is the contrast. There are people plugging away with larger numbers, hiring people, creating generational businesses, and making the vision work.

We admire larger farms because they’re unmistakably entrepreneurial, and they’re often driving necessary change in the marketplace.

But in our community, these larger producers are operating alongside the people who are intentionally and deliberately finding ways to be make pastured poultry a successful part of a farm business with modest scales.

At any pastured poultry conference where we’re tackling the issues of the day, I want both groups of people; experienced and scaled up. The challenge is speaking to people in a way that gets experience and volume in the same room. Often, those two characteristics end up being inversely related.

That’s why I think in terms of “professional” pastured poultry producers. That’s not a term I derived. I think Grady Phelan used it to describe the meeting we held in 2017.

When we start thinking in terms of “professional,” some of these things come to mind:

• You have a livelihood at stake.
• You associate with peers because those relationships enhance your business.
• You consistently invest in your education, your business, and your community.

That’s the heart of who we want to attend the Professional Pastured Poultry Conference in Fayetteville, AR, in January. We'll have producers with experience, producers with scale, and producers who have both. 

At any rate, now is the time to register for the Professional Pastured Poultry Producers Conference in January.