Trade magazine Feedstuffs offers first livestock industry critique of GAP standards

From ANIMAL PEOPLE, May 2011:

MINNETONKA, Minnesota–The March 28, 2011 edition of the
agribusiness trade magazine Feedstuffs offered the first extensive
critique from within the conventional livestock industry of the
five-step Global Animal Partnership standards for raising cattle,
pigs, and chickens for slaughter.
Introduced on November 15, 2010, the GAP standards were
rolled out in January 2011 by the 300-store Whole Foods Markets
chain, whose founder, John Mackey, also founded GAP.

The GAP standards and the multi-stepped approach to
certifying farm animal welfare were immediately controversial among
animal advocates, but major livestock producers and organizations
representing producers–though repeatedly asked for comment–said
little for 135 days.
Feedstuffs columnist Mark Klaus broke the silence by
summarizing correspondence that he said came from “A number of
agricultural producers and industry leaders,” whom he did not name.
The criticisms came from three different directions:
producers who suspect GAP is a mechanism for conveying funds from
agribusiness to animal advocacy; producers who believe GAP merely
slaps a seal of approval on present practices; and producers who
object to specific GAP standards, for what they claim are animal
welfare concerns.
“Most were alarmed,” Klaus wrote, “by the obvious
association between GAP and various animal rights organizations,
including the Humane Society of the United States–the general theme
being that leaders, past or present, of such an organization should
not be trusted. More concerning to some,” Klaus assessed, “is that
fees collected from GAP certification and auditing could be used, in
the future, as sources of funding for organizations such as HSUS or
People for the Ethical Treatment of Animals.”
John Mackey formed the umbrella for GAP, the Animal
Compassion Foundation in 2004, 26 years after he founded Whole Foods
Markets. The GAP standards debuted with the endorsements of Humane
Society of the U.S. president Wayne Pacelle, World Society for the
Protection of Animals director general Mike Baker, Compassion in
World Farming director of public affairs Joyce D’Silva, and PETA
corporate consultant Steven Gross. All have seats on the GAP board
of directors.
The GAP standards have been vigorously denounced, however,
by Humane Farm Animal Care founder Adele Douglass and Animal Welfare
Institute president Cathy Liss. Douglass started HFAC in 2003,
after leaving the American Humane Association farmed animal product
certification program, which she founded in 2000.
The HFAC farmed animal certification program was the largest
in the U.S. before GAP, including 54 producers as of mid-2010, with
annual output of more than 25 million animals. GAP, however,
started with nearly 1,200 producers, including all animal product
suppliers to Whole Foods Markets, with annual output of about 140
million animals.

Standard practices

“Many view the [GAP] rating system as a watered-down attempt
to create a false illusion of ‘standard’ industry practices,” Klaus
summarized in Feedstuffs. For example, Klaus wrote, “Most comments
expressed confusion as to how Step 1 differentiates a producer [of
chickens for slaughter] from common broiler industry practices
already in use.”
To qualify for GAP Step 1, Klaus noted, poultry must not be
in transport to slaughter for more than eight hours. “This gives the
impression that chickens outside the GAP program often travel for
much longer times and greater distances. Transport time within the
industry is more commonly a half-hour to one-and-a-half hours,” said
“The GAP program also states that for broiler chickens, at
all step levels, there can be ‘no physical alterations of birds
raised for meat (including beak trimming, de-spurring, dubbing and
caponization).’ This also gives the impression that these are common
industry practices,” Klaus continued.
“The GAP rating system stipulates ‘no antibiotics, no animal
byproducts, no added growth hormones,'” Klaus added. “Again, this
makes it appear as if all of the industry outside the GAP program
uses these products or feed components. USDA regulations do not
permit the use of growth hormones in raising poultry. Hormone use is
prohibited for all production of broiler chickens, turkeys, hogs
and egg-laying hens.
“As with the requirements for broiler chickens, many of the
GAP standards for pigs make it seem like they are somehow different
from standard industry practices,” Klaus observed. “Again, there
is a transport time requirement of fewer than eight hours, except
for Step 5+, which requires ‘on-farm or local slaughter.’ Most hogs
outside the program are not transported that long anyhow.”
Klaus did not mention, however, that animal welfare
standards might reasonably forbid harmful practices even if they are
used only by a minority of producers, to try to prevent such
practices from gaining acceptance.
Klaus cited concern that the GAP standards for ammonia
exposure in poultry barns “address hock burn,” instead of “foot pad
integrity,” which he called “a better indication of problems
resulting from constant contact with litter. A more common and
perhaps more accurate assessment is air quality,” Klaus suggested,
“with a maximum ammonia content of 25 parts per million as the
industry standard. GAP does not address ammonia content in regard to
air quality or litter management,” Klaus said, “and some industry
sources are concerned that eye damage could occur perhaps even before
the tolerance level for hock burn is reached.
“There is no guidance for how to maintain birds at a
comfortable temperature while still providing access to the
outdoors,” Klaus observed, “which could prove to be an animal
welfare concern, not an improvement.”


Continued Klaus, “Industry members who assessed the GAP
program were alarmed by the fact that many of the standards actually
could prove to be detrimental to the health and well-being of the
animal, compared to more commonly used industry practices,” but
several of the purported examples that Klaus cited amount to
rationales for practices which are harmful to animals.
Klaus objected that “segregated early weaning,” meaning
early separation of piglets from their mothers, “is a valuable tool
producers use to eliminate instances of illness and disease in young
pigs, yet this practice is prohibited in the GAP program.” In
actually, early separation of piglets from their mothers is a way to
accelerate the reproductive cycles of breeding sows, so as to
produce more litters in less time.
“GAP allows ‘no tail docking, tooth clipping, de-tusking
(or) disk nose rings’ for any steps of the rating system,” Klaus
continued, “leading consumers to believe that these practices are
detrimental to the well-being of the animal when, in fact, they are
standard practices used to decrease rates of injury.”
But the injuries that tail docking, tooth clipping,
de-tusking, and nose-ringing prevent are largely caused by keeping
pigs in excessively close confinement, unable to escape aggressive
behavior by others, and without things to do besides harass each
The need to dock pigs’ tails and clip their teeth if the pigs
are kept in close confinement “may be evident even to GAP,” Klaus
wrote, “because its producer guidelines state, ‘Docking the tail of
an individual animal for health or welfare reasons is permitted.’
Likewise, it states, ‘Modification of teeth is permitted when
necessary for welfare or health reasons.’ The general thinking,”
said Klaus, “is that tooth clipping and tail docking also will be
done within the GAP program.
“Nose rings are not a standard industry practice,” Klaus
added “but were historically used to reduce the extensive
environmental damage hogs do when placed outdoors on dirt.” In
recent years, however, nose rings have been used to help discourage
pigs from biting each other, and to keep pigs from injuring
themselves by trying to follow their instinct to dig when kept on
concrete floors. Though most pigs today are kept on slatted floors,
which permit better drainage, older pig barns may still have
concrete floors, especially if they were converted from dairy use.
“Animals may be isolated from the herd only after being
injured,” Klaus further objected, “thus barring the standard use of
individual housing systems,” which may also be described as
solitary confinement, “which prevent animals from injuring each
other during dominance fighting.”


Wrote Klaus, “One standard for all steps in the GAP program
is that cattle are not allowed to be dehorned or have their horns
tipped, which creates obvious animal welfare concerns,” but horn
injuries to other cattle are rare, except when cattle are closely
packed in transport, or are aggressively herded in a manner that
causes collisions.
“Perhaps the GAP beef cattle standard that most alarmed
respondents,” Klaus said, “was prohibiting castration of bulls in
order to achieve steps 5 and 5+. Many said this is impossible–that
such a standard might prove to be too dangerous to producers who must
care for these animals.”
Even though 77% of the bull calves born in the U.S. are
castrated before the age of three months, bulls have killed five
U.S. farmers in the past three years.
ANIMAL PEOPLE in March 2011 editorially expressed concern
that the GAP standards at Steps 1 and 2 are so low that almost any
producer meeting the requirements of existing agribusiness
certification systems can qualify. Once admitted to GAP, no
mechanism requires producers to make improvements to rise to higher
GAP data released in February 2011 demonstrated that
participating producers are clustered overwhelmingly at the lower end
of the GAP standards, with 81% of the meat chicken producers and 85%
of the pig producers at steps one and two. Including beef cattle
producers, 72% of all GAP-certified producers were at the lowest
steps-and appeared to be the producers who raise the most animals.

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