Animal Welfare Institute comments on GAP certification standards

From ANIMAL PEOPLE,  January/February 2011:

The Animal Welfare Institute (AWI) supports the development of third-party certification programs that improve the lives of animals, however, we have serious concerns about the standards of the Global Animal Partnership (GAP) program and the processes by which they are implemented. Since only Step 1 is required of all producers, the program must be judged by this standard.

In a recent presentation, GAP’s executive director Miyun Park described GAP Step 1 as signifying meaningful welfare improvement to conventional, industry confinement production. AWI is concerned about the veracity of this claim, particularly in the case of its standards for meat chickens and beef cattle. Compare, for example, GAP Step 1 for chickens and Perdue Farms, which uses the USDA to audit its compliance with very thin National Chicken Council guidelines for some of its chicken products.  Neither GAP Step 1 nor Perdue standards address rapid growth rates. Neither requires outdoor access or an enriched environment indoors. GAP standards are actually weaker than Perdue’s in terms of dark periods, ammonia levels, and catching. GAP also falls below Perdue in terms of space: while Perdue has inadequate maximum density requirements, GAP does not have a maximum density requirement.  Instead, the GAP space requirement for chickens uses a performance standard which states that “Chickens must be able to express natural behavior,  including standing,  spreading their wings,  turning around,  flapping their wings,  and preening, without touching another bird.” However,  flapping wings requires about two square feet,  and GAP Step 1-2 birds don’t receive anywhere close to two square feet each.  A performance standard such as this should state that all,  or a measurable percentage, of the birds,  must be able to engage in the behavior simultaneously–or a minimum engineering standard (a space requirement) must be tied to the performance standard.   Clearly, since the Perdue standards for animal care are unacceptable, then so too are those of GAP Step 1.

Current package labels and promotional materials for other GAP steps are misleading. For example, a brochure describing GAP offered in Whole Foods stores advertises “independent 3rd-party audits of farm, transport and slaughter/processing plants.”  While Whole Foods has a slaughter standard for the meat it sells, slaughter is not currently covered under GAP standards.

Step 5+ chicken meat is labeled “entire life on same farm,” yet the standard allows transport off the farm for up to two hours. Step 3 chicken and pig meat is labeled “enhanced outdoor access,” yet vegetation is not required at this level, and there’s nothing “enhanced” about small concrete slabs which are acceptable under the standards. Similarly, the label claim for Step 4 beef is “pasture centered,” yet confinement in a feedlot for up to 4 months a year is allowed. GAP’s executive director claims she did not play a role in the production of the Whole Foods brochure that made the misleading claims. This raises questions about the authority of GAP to control the use of the GAP logo and to ensure the accuracy of the program description by participating producers or marketers, which further undermines the credibility of GAP.

Routine auditing is a fundamental component of certification programs; it is the means by which the program’s standards are enforced. GAP offers consumers no information about its audits. We don’t know how often audits are conducted or even if all farms are audited, and if not every farm, what percentage of farms is inspected to ensure compliance with even their minimal requirements. GAP’s response to criticism seems to be that the program is a work in progress. But all certification programs are in a constant state of research, review and revision. The program should not be marketed based on future plans but rather on what the standards and audit processes are today. If after years of testing, a significant financial investment, and input from a broad range of individuals, the program still is not ready for prime time, then the launch should be delayed until it is ready.

Not only is GAP not a transparent, third-party certification program, it has conflict of interest issues. Several members of its board are producers or retailers with a vested interest in the outcome of decisions. And, to our dismay, GAP is not granting reciprocity for farmers participating in one of the existing animal welfare certification programs, meaning an additional financial burden to family farmers with limited resources who will have difficulty paying the $1,900 inspection fees required to participate in GAP.

A fatal flaw of GAP is the premise that producers will voluntarily improve their animal care practices in order to move up to a higher step. Since there is no requirement that producers move to a higher step (it is optional), and the financial incentive appears negligible, we see no motivation for a producer to expend the time and money required to advance.  In addition, AWI suspects that consumers lack both the knowledge and the patience to differentiate between animal welfare claims at the various GAP levels.

Little will be accomplished if GAP standards remain low, consumers shop at the bottom of the scale, and producers fail to move up.

–Cathy Liss,  president, Animal Welfare Institute
900 Pennsylvania Ave.  SE, Washington,  DC 20003
Phone:  202-337-2332

Humane Farm Animal Care comments on the GAP standards

The Global Animal Partnership multi-tiered animal welfare certification program on close inspection is a disappointment. When the Humane Farm Animal Care “Certified Humane” program was founded,  the purpose was to improve the lives of farm animals in food production in both indoor and outdoor housing systems.  The Animal Welfare Institute’s “Animal Welfare Approved” program was founded to improve the lives of farm animals exclusively through pasture-based family-owned farms.  Both programs now make an enormous difference in the day-to-day lives of the farm animals raised under those standards.

For the last few years,  Whole Foods’ leadership has been talking about the creation of its own farm animal welfare program and claimed it would have the highest standards of all.  With Whole Foods being an $8 billion dollar retailer,  that was believable.  With their buying power,  it was thought that they could make a real difference to benefit farm animals by requiring their suppliers to meet high welfare standards.  McDonald’s and Burger King made a huge difference to humane slaughter by requiring the slaughterhouses where their beef was processed to meet the American Meat Institute Guidelines written by Temple Grandin;  those slaughterhouses must be audited by trained inspectors to ensure compliance.  If those slaughterhouses do not meet the standards,  McDonald’s and Burger King will not purchase meat from their plants.  With their buying power,  McDonald’s and Burger King facilitated change.  Whole Foods has a similar opportunity to facilitate change in order to improve the lives of farm animals.   Considering Whole Foods Market’s potential leadership ability,  the numbers of advisors who were brought together (including animal welfare experts,  scientists,  and farmers),  and the number of years it took to put this program together,  GAP should be able to achieve higher animal welfare standards than either McDonald’s or Burger King.  However,  the GAP standards fall short. It is inexplicable that prominent leaders of the humane community are embracing a program within which some standards are lower than those of the industry it routinely denigrates.  In order to be GAP-certified,  a producer only needs to achieve Step 1 standards.  If a producer meets Step 1,  there is no requirement for the producer to continue making improvements in order to achieve higher Step levels (2-5).

GAP standards have not addressed some of the most egregious practices of the meat industry.   For example,  chickens need sleep. Chickens raised only for their meat (not egg-layers) live a short period of time,  usually six to seven weeks,  before they are slaughtered.  Current industrialized chicken farming practice is to leave the lights on 24 hours a day,  seven days a week,  so that the chickens will eat continuously and get to market weight as fast as possible.  Unfortunately for the chickens,  they gain too much weight too fast,  which causes leg problems and constant pain.   To remedy this,  chicken industry standards require barns to have a dark period to enable the chickens to sleep.   The GAP Program has no requirement at all–in any of their five steps–for a dark period.

This is only one example.  GAP as of yet has no standards for egg-laying hens or dairy cattle.  The space requirement for beef cattle in feedlots is less than current industry recommendations, and there is no space allowance for pigs–even though it is claimed that crating gestating (not farrowing) sows is forbidden in the GAP program.  There are no slaughter standard requirements at all for the GAP program. Why would a producer who has secured GAP certification by meeting Step 1 spend the money and make the effort to move up to another Step?   GAP is giving industrial-type operations recognition for minimal standards which in some cases provide no benefit to the animals – and, through GAP,  these factory operations are securing humane community endorsement too!  There is no incentive to meet the requirements of any Step other than the Step at which a producer entered the program.   Farm Forward is a separate non-profit organization that works with GAP.  Farm Forward and GAP have mutual board members (Miyun Park of GAP and John Mackey of Whole Foods on the Farm Forward Board,  and John Mackey and PETA representative Steve Gross of Farm Forward on the GAP Board).   Farm Forward is collaborating with GAP to try to persuade more retailers to require GAP certification for their suppliers.   Since there are no slaughter standard requirements for GAP,   these retailers have to arrange for separate slaughter inspections and traceability audits if they are going to meet other standards.

Retailers who sign onto the GAP program can sell their GAP-approved products to consumers who genuinely care about how farm animals are treated–yet it does not cost the retailers anything, since their producers and suppliers do not have to make any real changes to participate.  The GAP standards appear to accommodate industry,  and not the well-being of farm animals. There have been many retailers who have required producers to make genuine efforts to improve animal welfare.   Many producers have spent large amounts of money to make the changes required by the Certified Humane and Animal Welfare Approved programs in order to actually make a difference for farm animals.  Unfortunately,  the GAP program runs the very real risk of undermining that work and lowering the bar for farm animal welfare.

–Adele Douglass,  founder and president, Humane Farm Animal Care
1039 Sterling Road #201, Herndon,  VA  20170
Phone:  703-435-3883

Global Animal Partnership responds to AWI & HFAC criticisms

Thank you for introducing ANIMAL PEOPLE’s readership to Global Animal Partnership and our signature initiative,  the 5-Step Animal Welfare Rating Standards.

The primary mission of GAP,  a 501(c)(3) nonprofit organization,  is to facilitate and encourage continuous improvement in animal agriculture.  GAP strives to change the landscape of animal agriculture through a positive,  engaging,  multi-stakeholder approach.

We were born from such an orchestrated collaborative effort, initially led by Whole Foods Market leadership,  who brought together advisors over a number of years to help guide them in the creation of what would be their own corporate farm animal welfare standards. Whole Foods Market then recognized that greater positive impact could be achieved by working with an international organization.  In 2008, Global Animal Partnership was formed as an independent, nonprofit organization with the charge of further developing these standards-and disseminating them beyond Whole Foods Market’s own stores.

Our Board of Directors and Welfare & Farming Advisory Council include expert leadership from farming, ranching,  retail,  science, and advocacy.  We’re extremely proud and continuously inspired that individuals from such different backgrounds have come together with the commonality of wanting to reduce the suffering of animals in agriculture. We firmly believe that any improvement in the welfare of farm animals is to be lauded,  which is why we have tremendous respect for the important work and successes of Humane Farm Animal Care’s Certified Humane and Animal Welfare Institute’s Animal Welfare Approved programs.

Each assessment program plays an important role in promoting higher animal welfare.  However, given the structure of our 5-Step Animal Welfare Rating Standards,  we don’t believe that a comparison against other schemes is in order.  Our signature initiative was developed as multi-tiered standards that,  through their very design, promote continuous improvement in animal agriculture.  In contrast to single-tiered, pass/fail schemes,  our 5-Step Program encourages and inspires producers to continually move up the welfare ladder and thereby afford higher welfare to animals.  Additionally,  we believe this multi-tiered structure better informs consumers,  as well as acknowledges and rewards producers for their welfare practices, which is critical.

Each set of tiered standards (e.g., Step 1,  Step 3,  Step 5) has its own requirements that must be met before certification to that particular Step level is assigned,  if appropriate.  Producers have the freedom to aim for any Step level they choose.  Each Step rating has its own distinct label-from Step 1 to Step 5+-affixed on products that identifies the particular Step level achieved.  I’m thrilled to share that even in our early days, approximately 1,000 farms and ranches have already been certified from Steps 1 to 5, positively impacting the lives of more than 140 million animals annually.  It may also be of interest to ANIMAL PEOPLE readers to know that the majority of Step-certified producers are Step 2 or higher.

In order to maintain the highest level of credibility and objectivity,  Global Animal Partnership elected not to conduct our own audits and verification of farms and ranches, but rather to work with independent,  third-party certification companies.  In this way, as the standard-setter,  we are best positioned to remain objective and maintain the integrity of our 5-Step Program.

We recently welcomed the successful completion of a two-year, exclusive pilot program with Whole Foods Market of our first three sets of multi-tiered standards-for chickens raised for meat,  cattle raised for beef,  and pigs.  During this period, we have been extremely fortunate to have had the opportunity to test,  refine, and grow the initiative,  develop processes and set protocols,  and engage with and learn from truly welfare-minded farmers.  As Wayne Pacelle shared in the article, we are now in the process of revising the original three sets of standards based on key learnings from the pilot and new science,  as well as developing three new sets of standards,  for egg-laying hens,  turkeys,  and sheep and lambs.  In the near future, we will make the program even more robust by developing breeding and slaughter standards.

Despite our relative infancy and newness in the marketplace, there is already steadily increasing interest in our 5-Step Animal Welfare Rating Standards Program from others in the retail sector, varying from independent local stores to regional and even national chains.

I hope to soon share with ANIMAL PEOPLE readers the announcement of our newest collaborators in the effort to improve the welfare of animals in agriculture.

–Miyun Park,  executive director, Global Animal Partnership
P.O. Box 21484
Washington,  DC 20009

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