January 15, 2003

The Honorable Ann M. Veneman
Secretary
United States Department of Agriculture
Washington, DC 20250

Via USPS and Fax (202-720-2166)

Re: Mass Euthanasia of Poultry for Disease Control

Dear Secretary Veneman:

The Humane Farming Association (HFA), on behalf of its 170,000 members nationwide, is very concerned about the inhumane methods utilized by U.S. Department of Agriculture (USDA) personnel in their mass killing of chickens and other birds during disease eradication programs such as those currently being conducted to control an outbreak of Exotic Newcastle Disease in the state of California.

HFA’s concerns are based, in large part, on incidents occurring during the mass killing of more than 4 million turkeys and chickens conducted last summer in Virginia. The methods employed by the USDA to eradicate a large-scale avian influenza outbreak in that state prompted numerous serious complaints. HFA received reports from reliable sources – including poultry farmers, independent workers and private veterinary practitioners assisting with the killing of birds, and USDA personnel themselves - expressing alarm and even outrage over the cruel and inhumane methods utilized in killing these animals. In addition, an HFA investigator was present during the killing of tens of thousands of the birds and witnessed behavior inconsistent with humane veterinary euthanasia standards.

Administration of carbon dioxide gas was the primary euthanasia method used in the Virginia depopulation program. However, according to reports received by HFA, serious lapses in proper gassing procedures resulted in extreme animal suffering. Many turkeys failed to lose consciousness or regained consciousness, and as a result were subjected to repeated gassing. Turkeys who didn’t die during gassing were disposed of alive or were bludgeoned to death with baseball bats, ax handles, sticks, and broom handles. Ineffective gassing procedures also resulted in personnel resorting to other, inappropriate methods of killing:

• Crushing the heads of young chickens between the handles of scissors.
• Placing chickens in plastic bags that were attached to vehicle exhaust pipes. Simply suffocating other birds.
• Breaking the necks (cervical dislocation) of chickens by personnel untrained and/or inexperienced in the procedure, resulting in painful and lengthy deaths.
• Slitting the throats of birds by only cutting deep enough to sever the trachea without severing the cervical cord – again resulting in a prolonged, agonizing death.

All of these methods are considered unacceptable according to the American Veterinary Medical Association’s (AVMA) 2000 Report of the Panel on Euthanasia. Moreover, all the above activities were participated in, witnessed, or supervised by USDA personnel.

• The gassing procedures, even when successfully employed to kill birds, were flawed and caused the animals to experience unnecessary stress and suffering prior to death. The HFA investigator witnessed and documented the following violations of the AVMA humane euthanasia standards in the depopulation effort conducted by USDA personnel:
• Laying hens were roughly handled in being removed from their cages, causing broken wings and legs.
• Laying hens were literally crammed into the gassing cages, leading to severe overcrowding and inadequate gas distribution.
• The gassing compartments were not adequately sealed and the gas flow rate inadequately controlled, resulting in a prolonged time to loss of consciousness.
• Gas was pumped directly on the bodies of some birds, causing painful burning.
• he gassing compartments were completely covered by a black tarp, preventing observation of the animals for signs for distress.

Videotape shot by the HFA investigator documents very loud squawking for the first three minutes after gassing begins, with some vocalization still audible several minutes later. The volume, intensity, and duration of the vocalizing indicate the birds were being subjected to an unacceptable level of suffering during the procedure.

USDA and California officials have indicated that the primary euthanasia method being used in the California depopulation program is the administration of carbon monoxide gas. While AVMA guidelines deem carbon monoxide to be an acceptable euthanasia agent, it must be properly administered. In fact, concerns regarding its application prompted the California Legislature in 1998 to outlaw the killing by any person of any animal by the use of carbon monoxide gas (CAL PENAL CODE 597u). The legislative analysis of the bill includes the following rationale for the prohibition:

[T]he depressant effect CO has on an animal’s respiratory system can cause it to feel the effects of suffocation before it loses consciousness. Veterinarian Michael McCoy reports that autopsies on animals euthanized by CO frequently exhibit a type of hemorrhaging associated with intense struggle before death…. CO chambers are often misused. Most typically, too many animals are placed in a chamber. When this happens, it takes longer for the animals to die and the presence of other struggling animals can cause … tremendous anxiety.

HFA has learned that a meeting was held during the Virginia depopulation program to discuss methods of euthanasia. At that meeting personnel from the USDA’s Animal Care division made recommendations and voiced concerns regarding specific euthanasia procedures to personnel of the Veterinary Services division who were conducting the killing program. Supervisory staff of the Veterinary Services division rejected the suggestions of the Animal Care staff and, furthermore, instructed Animal Care personnel not to file reports addressing their concerns about the poultry depopulation program. The disagreement between Veterinary Services and Animal Care regarding euthanasia practices was so great that Animal Care felt compelled to abruptly withdraw from further participation in programs involving the monitoring and advising of Veterinary Services in reference to humane issues.

The USDA has a responsibility to the American public to ensure that mass euthanasia programs are accomplished in as humane a manner as possible. HFA also believes it is essential that the USDA supervise and control the entire process of depopulation and not permit abusive or cruel treatment of animals by the poultry industry, such as the intentional withholding of food and water from flocks after the birds have been ordered killed and, therefore, have lost their economic value.

We are requesting information from your office detailing how the USDA intends to ensure the humane euthanasia of birds during its depopulation efforts in California to eradicate Exotic Newcastle Disease (and for all future depopulation efforts conducted by the USDA). In addition, HFA is requesting information regarding staff qualifications for participating in or supervising euthanasia programs, as well as information about any training currently being provided USDA staff involved in these programs.

The Humane Farming Association is appalled by the cruel and inhumane methods used to kill large numbers of animals by, or with the knowledge and consent of, the U.S. Department of Agriculture. Due to the serious nature of the cruelty and the magnitude of suffering affecting literally millions of animals in disease eradication programs, HFA expects a swift response to our concerns and an immediate end to behavior that if conducted by private citizens would surely qualify as criminal animal cruelty.

Sincerely,

Dena M. Jones Outreach Director

cc: William Lyons, Secretary, California Department of Food and Agriculture Via Fax (916-654-0403)