Both in the news and on the internet, there’ve been a lot of misleading claims made about Foie Gras and its method of production. As people who work on the farms every day, we’d like to set the record straight about how the ducks are raised and handled, educate those looking to find out more accurate information, and clear up some erroneous you may have read.
Misconception: The feeding process is painful to the ducks.
Reality: No, it isn’t. Ducks have unique physiology, much different than humans. They don’t have a gag reflex. Their esophagus is designed to swallow whole, large, and often sharp fish. Our hand-feeding methods are stress-free, non-invasive, and cause no discomfort. We use a short plastic tube to deposit a small amount of wet, natural food in a feeding sac at the base of the duck’s throat. Ducks are never fed more than 9-ounces of grain at a time, which is less than half the capacity of their feeding sac.
Misconception: The livers used to make Foie Gras are diseased.
Reality: This is simply not true. Why would we serve anybody diseased livers? While it’s true in mammals that extra fat in the liver can be a problem, in waterfowl, a fatty liver causes no pain or sickness and is reversible. Ducks are uniquely adapted to store fat in their liver. They do it to save energy reserves for migration and times of scarce food supply, such as winter. A California court decision found that duck livers are not diseased. In addition, our farms regularly pass USDA inspections.
Misconception: Ducks are only raised for their livers.
Reality: That doesn’t make any economic sense. We make sure we use all parts of the duck including meat, feathers, and offal in high-quality duck meat, natural pet food, and other products. Nothing is wasted. We even donate our duck droppings to local farmers that they can use as fertilizer.
Misconception: Ducks are mistreated on the farm.
Reality: A mishandled duck risks getting bruised, which actually lowers the value of its meat. That’s why our employees are incentivized to be gentle with the birds. They are paid bonuses for delivering ducks that provided Grade A meat products. Up until the time of processing, our ducks are treated with the utmost care and compassion. They are housed in open spaces that are routinely cleaned and disinfected. Sick or hurt ducks are not good for business, so we take steps to prevent that from happening.
Misconception: Female duck chicks are killed just weeks after hatching.
Reality: This makes no economic sense. While it’s true female Moulard ducks don’t grow livers as well as males, it doesn’t mean they can’t be used for other meat products or for producing more ducklings. The truth is, our main focus is on Foie Gras production, so we sell a majority of our female ducks to other farms, where they are raised for meat. We do not wastefully kill them.
We are proud of the Foie Gras and other duck meats we produce at our family-run farms, as well as the innovative methods we have developed to raise our fowl in the cleanest, most stress-free environments possible.
Thanks for taking the time to learn the facts behind the production of our Foie Gras.
]]>The following scientific paper outlines the evidence around the processes that are used to produce Foie Gras.
Report By: Guémené Daniel 1 , Guy Gérard 2 , Servière Jacques 3 and Faure Jean-Michel 1
- INRA, Centre de Tours-Nouzilly, URA, F-37380 Nouzilly,
- INRA, UE-PFG, 1076 Route de Haut Mauco, Artiguères, F-40280 Benquet.
- INRA-INA PG, UMR-PNA, 16 Rue Claude Bernard, F-75231 Paris.
The debate over foie gras has been marked by much emotion. Opponents of foie gras refer mainly to personal feelings and observations rather than from experimental approaches. Opponents generally assert that the “cruelty” is quite obvious and there is, therefore, no need for scientific investigation. In an effort to answer factually questions about the science of foie gras production on geese and ducks, French researchers, particularly from the National Institute of Agronomic Research in Nouzilly, France, have conducted numerous studies to objectively gauge the actual impact of foie gras production on animals and to scientifically assess the claims of foie gras opponents.
In this paper, we explore the hard science as it relates to three broad allegations made by opponents of foie gras. First, our paper will focus on scientific studies conducted into the occurrence of stress in ducks and geese and whether foie gras farming is “cruel” as opponents assert. Second, we will examine the pathological state of the livers produced. Third, we explore research done into whether or not foie gras is or is not “natural.”
I. Scientific Examination of Stress, Pain and Fear Levels in Force-Fed Ducks
While so much of the debate over foie gras has focused on how the force-feeding affects the birds involved, there has been relatively little examination of the available empirical scientific studies conducted. There does exist substantial data regarding whether and to what extent feeding techniques create stress, pain and fear in farmed waterfowl.
A. Does Force-Feeding Cause Stress?
latory systems of any organism in order to adapt to the new situation. This response involves several biological systems and emotional components. Stress may result in a permanent negative outcome, or it may involve energy expenditure in order to reach a new homeostatic status. When the stressing agent is sudden and does not last, one refers to acute stress. Chronic stress, on the other hand, refers to a lasting challenge. The main physiological indicators of stress are the modifications in corticosterone levels and changes in heart rate and arterial blood pressure, which are related to autonomic nervous system activation.
Stress levels in birds can be gauged through the measurement of corticosterone blood levels. (Faure et al., 1998, Guémené et al., 1998; 2001; 2006). The production of foie gras implies force-feeding, which requires placing a tubing in the esophagus in order to introduce a large amount of food in a few seconds, 2 or 3 times a day during a two to four week period, depending upon the species and procedure. In designing a study to measure stress induced by force-feeding, our research team developed a hypothesis that this practice could be at the origin of both acute and, due to its repetitive nature over time, chronic stress.
Clinical experimentation has shown that force-feeding does not induce any significant increase in plasma corticosterone levels in ducks kept in individual cages. In addition, 2 additional experiments have demonstrated that the corticotrope system remains fully functional during the force-feeding period. The ducks were still able to secrete corticosterone after a physical stress such as 15 minutes constrained in a net, demonstrating that the physiological status induced by overfeeding did not result in a blunted responsiveness of the alarm system (Guémené et al., 1998; 2001). In measuring corticosterone levels of ducks kept in group pens, clinical study showed no significant increase in stress levels except after the first instance of force-feeding and strongly suggested that increased stress measurements resulted from holding the ducks rather than from the actual force-feeding.
A similar conclusion regarding the absence of stress perception was drawn after recording the heart rate, as no acceleration was detected when the tubing was introduced in the esophagus (Serviere et al., 2002). Although, it was not our initial experimental hypothesis, our research concluded that force-feeding is not perceived as a major source of acute or chronic stress by the waterfowls.
B. Assessing Claims that Force-feeding Induces Pain
The presence of pain in animals may be difficult to measure scientifically because animals can only express themselves through behavior. Neuroscience, however, provides information about the nervous system that can help us to assess the incidence of pain. Experiments involving the visceral nervous system, which computes sensory and motor information from organs including the digestive tract and related secretary glands, have been carried out to assess potential signs of pain in ducks at different stages of the force-feeding period (Servière et al., 2002).
Neural activation indicating the presence of pain signals were never detected in the sensory visceral brain centers of force-fed ducks (Servière et al., 2003). Although there is a need for further scientific investigations, the data provided do not demonstrate the presence of major pain-induced signs in the nervous system of force-fed mule ducks.
This absence of pain indicators likely results from anatomical specificity of the waterfowl involved in foie gras production. For example, ducks and geese, like many other bird species, are able to swallow large preys. Consequently, the inside diameter of the upper part of the esophagus, which is essentially an expandable elongated pouch in waterfowl, the pseudo-crop sac, is comparatively larger than in mammals and is not circled by cartilaginous rings, explaining the capacity to swallow large objects. Its volume ranges from 600 to 800cm 3 in mule ducks (Guy), while it is reported to be smaller in geese (below 500 cm 3 ) (Leprettre et al., 2002). For this reason, each meal with geese will have a smaller volume than with mule ducks, though the number of daily meals with geese will be higher. In addition, this pouch is located at the level of the neck (25-35cm long) allowing full expansion under the elastic skin of the neck, without any compression of the organs present in the thoracic cavity. It also allows the birds to potentially absorb large amounts of food, which is stored there before being progressively released. The pseudo-crop sac membrane is covered with keratin, which provides a mechanical resistance capacity much higher than the epithelium of most mammals. Another specificity resides in the fact that the opening of the trachea sits in the middle of the tongue. Thanks to the collapsing action of tongue muscles since this anatomical feature allows ducks to eat and absorb water under the water without drowning. This specificity explains why, as long as the procedure is carried under proper conditions, ducks do not have the upper respiratory tract blocked by the force fed meal, a criticism which is often raised by opponents.
Some criticisms of foie gras relate to the occurrence of bumblefoot as a consequence of inappropriate rearing conditions. The problem of bumblefoot is not specific to animals 3 kept in cages, but also to those kept in floor pens. The condition appears more prevalent when birds have access to outside free-range and is generally associated with poor litter quality, especially humidity.
Panting in ducks, which frequency is increased by the end of force-feeding period (Guémené et al., 2006), strikes many visitors of a force-feeding operation and is often misinterpreted as an indicator of discomfort. Panting originates from a thermo-regulatory reflex. Birds have no sudoriferous glands and their capacity to eliminate extra heat through contact with the air is limited by the insulating properties of their plumage. Thus, they open their beaks and pant to eliminate the latent heat associated with water losses. Panting constitutes an effective way “to burn” excessive calories. It is neither a voluntary nor deliberate action but a reflex controlled by the respiratory bulbous centers.
Globally, in absence of wound or pathology, force-feeding does not appear to induce pain and is not a major source of nociceptive information integrated by the nervous system.
C. Are Ducks and Geese Frightened by the Force-Feeder and/or Force-Feeding?
Aversion to force-feeding and force-feeders has been left too often to anecdote rather than scientific measure. Breeders like to recall the anecdote in which free waterfowl spontaneously run up to receive their ration by force-feeding, while detractors that birds present an aversion to the force feeder and\or to force-feeding.
To test this possibility of aversion, behavioral tests were conducted using the accepted hypothesis that an avoidance response should be observed only if stimuli associated with the situation, are aversive. The behavioral responses of geese and ducks, which were previously trained to move from their rearing pen to a feeding pen in order to have access to their food, have been studied. After a training period, half of the birds were force-fed, and the amount of food ingested was adjusted to equal the amount spontaneously ingested by the non-force-fed control birds. During the experimental period, force-fed geese continued to move spontaneously and at the same speed as the control group (Guémené et al., 1998; 1999; Faure et al., 2001). In mule ducks, the response was more ambiguous. Generally, mule ducks are fearful, social and very sensitive to any environmental factors (e.g., change of the experimenter or in the timetable) that will affect behavioral responses. Additional experimentation, however, demonstrated that the flight distance of ducks was higher in front of an unknown person than with the caretaker who performed force-feeding daily (Faure et al., 2001). Empirical observations with geese delivered similar results. Furthermore, there was no development of aversion to the operator throughout the force-feeding period. In fact, the flight distance lessened with time. Moreover, familiarization limited the amplitude of the physiological responses to physical stress (Guémené et al., 2002; Servière et al., 2003), as well as behavioral reactions of fear in specific experimental tests (Guémené et al., 2002; 2006).
In conclusion, force-fed ducks or geese do not develop any avoidance behavior towards the force-feeder and the force-feeding context. Additionally, familiarization with the feeder appears to have beneficial smoothing effects, both on behavioral and physiological responses.
II. Claims that Foie Gras is Diseased Liver Are Unsupported by Research
Opponents of foie gras production have often claimed that hepatic steatosis, also referred as lipidosis, is a pathological condition. While this statement is true in mammals, 4 including humans, it is not the case in birds. To equate a human pathology with that of certain migratory waterfowl disregards obvious physiological differences between the species.
A. Human Steatosis Is Different than Steatosis in Mule Ducks and Other Waterfowl
In humans, hepatic steatosis occurs as a response to various forms of inherited or acquired metabolic disorders (Alpers et al., 1993). Human steatosis is most frequently secondary to alcoholic intoxication (cirrhoses) and is not reversible over a certain stage. Another type of steatosis, which is increasing among Western human populations, occurs in patients exhibiting metabolic syndromes such as overeating, obesity, dys-lipidemia and insulin resistance. In some patients, this fatty liver remains isolated, has no clinical consequences and does not cause any pain. In others it may evolve into Non-Alcoholic Steatohepatitis (NASH) after several years (Day & James, 1998).
There are some species, however, in which the metabolic adaptations naturally result in hepatic steatosis. These include wild migrating birds and fish (e.g., cod), in which moderate hepatic steatosis occurs spontaneously as a consequence of energy storage before migration (Pilo and George, 1983). The process of hepatic steatosis is facilitated in these oviparous species, because the liver is the major site of de novo lipogenesis, which is not the case in mammals. In chicken, 90% of the de novo lipogenesis synthesis is insured by the liver. This number reaches has high as 96% in pigeons. Humans, by contrast, reach a maximum of 30% after eating (Timlin and Parks, 2005).
In domestic waterfowls, this specific capacity of large liver fat storage is exploited for foie gras production in a proportion not observed under natural conditions. In the goose, the liver weight can increase 10 fold in two weeks and account for 10% of the body (Hermier et al., 1994). In mule ducks, the average liver weight at the end of force-feeding was around 550g in 2002 in France (Chalimbaud, 2004). Their genetic potential, however, would allow the liver to reach a weight of over 800g.
Examination of foie gras demonstrates the absence of disease. Foie gras represents a quasi-pure form of acquired hepatic steatosis of nutritional origin. The tissue is not diseased, as degenerative events such as necrosis or cirrhosis never occur. The hepatic cells preserve their integrity and continue to perform their function. Were this not the case, the animals would not survive force-feeding, even over a time as short as the two weeks (Benard and Labie, 1998). Unlike human fatty liver, foie gras does not exhibit any macroscopic lesions.
Additional indicia also prove an absence of pathological conditions in foie gras. Lipids, for example, store differently in steatosis that is of pathological rather than nutritional origin. In pathological steatosis, one would expect to see centrolobular lipid accumulation, which is not observed in foie gras production (Benard et al., 2005). Furthermore, although the conjunctive hepatic substrate of cells is bloated in foie gras producing ducks, the capsule around the liver remains uninjured.
B. Reversibility of Steatosis and Impact on Liver Function in Foie Gras Production
Very important, is the fact that the steatosis in foie gras is fully reversible. After leaving the animal free to feed, there is a three to four day spontaneous fasting, and the liver 5 returns to its initial composition within two weeks when over feeding is interrupted. This process has been demonstrated to be true both in geese and ducks, and it is true even after repeated periods of force-feeding and fasting (Babile et al., 1998; Benard et al., 1998). This method was originally used for selection purposes and had no negative consequence on the future reproducers.
In addition to the data related to liver function, several studies demonstrate that the whole regulatory system of glucose and insulin remains in working physiological condition, despite the force-feeding. This is a new set of data that can be interpreted to demonstrate the preservation of the functional status of hepatic cells during the period of force-feeding. It has been established that blood glucose concentration is regulated within a narrow range by pancreatic hormones, in particular by insulin. Insulin exerts a stabilizing action upon glycemia and allows the entrance of glucose into target tissues (liver, adipose cells, muscles) to be stored as glycogen or fatty acids. In mammals, lasting excessive food intake, with large amounts of carbohydrates, can unbalance this equilibrium and lead to obesity and diabetes (James and Day, 1998). In mule ducks, recent scientific studies (Berradi et al., 2003; Davail et al., 2003) do not demonstrate any rise in insulin level nor any progressive increase of blood glucose level throughout the force-feeding period. As neither insulin function nor glucose/insulin equilibrium are altered, it implies that physiological regulatory mechanisms remain functional in force-fed birds.
C. Mortality Rates of Birds In Foie Gras Production Indicate an Absence of “Disease”
Opponents of foie gras have often alleged that force-feeding practices result in high mortality rates. Data from experimental approaches do not support this conclusion, and field data provides only an overall culling index below 3% in recent years (Chalimbaud, 2004). Culling causes include not only mortality but also other conditions such as wounds, weakness, injuries at transfer, etc. The recently observed decrease in the culling index has been associated with changes in rearing conditions and feeding techniques.
III. A Review of the Scientific Studies Regarding Whether Foie Gras is “Natural”
At first blush, some may not consider foie gras production to be “natural.” Upon further consideration, however, the conclusion is much less obvious. If by “natural” one intends to an agricultural process in which humans do not interfere with the production process, then the whole process of plant and animal agriculture can be called into question as “unnatural.” Agriculture has always been about selective breeding to produce plants and animals not previously known in nature. Additionally, for millennia, farmers have sought farming techniques to increase both crop and animal agriculture yields.
A. Is it “Natural” for Migratory Waterfowl to Over-Feed?
For some, this question of what is “natural” centers around the notion that wild species do not over-feed themselves nor do they produce livers similar to foie gras. In fact, many migrating species do express a spontaneous capacity to over-feed and accumulate fat deposits in muscles, adipose tissues and, to some extent, in liver at distinctive periods along the seasonal cycles. This is particularly the case in periods requiring a great deal of energy consumption, such as the migration. Some opponents of foie gras contend that, despite this natural tendency of migratory waterfowl to over-feed, force-feeding in foie gras production 6 involves the ingestion of amounts of food that are greatly in excess of the birds’ ability to spontaneously absorb. Critical to a scientific examination of this charge is a factual understanding of the quantities of food ingested and a clear understanding of the inappropriateness of a comparison between human and duck ingestion capacity
Through our scientific studies, we have observed that a single mule duck can ingest, without any physical constraint, up to 500g (over 1 pound) in a single meal and over 750g of food during a day (Guy et al., 1998). Similarly, “Landaise” Grey geese have been reported to spontaneously graze 1kg of pasture daily, while also being fed a regular diet (Leprettre et al., 2000). These geese can also eat as much as 3kg of carrots daily.
The quantity of food fed to mule ducks and geese fits well within this range of spontaneous ingestion capacity. Force-feeding techniques used by farmers involve gradually increasing the amount of feed given to the birds over the course of two to four weeks. The maximum quantities of food are provided toward the end of the force-feeding period and never exceed 1000g daily, or 500g per meal.
B. Impact of Modern Breeding Methods on Foie Gras Production
Claims that foie gras is not “natural” may also be based on the fact that the species generally used in modern foie gras production, the mule duck, is an “artificial” cross between a female Pekin and a male Muscovy duck, obtained by artificial insemination, to create a genotype not present in the wild. The process of genotype selection and intercrossed species is as old as the history of domestication itself. Horses have been bred with donkeys to produce mules, for example. In the present situation, the producers have taken advantage of the capacity of some genotypes to optimally respond to force-feeding by a large and rapid increase in lipid synthesis and storage in the liver without signs of pathology or morbidity. It is worth noting that neither the Polish geese nor the Pekin ducks respond as the Landaise geese and the mule duck do to force feeding. Modern hybrids used for foie gras production are thus specifically adapted for this type of production.
Conclusion
Our objective has been to provide objective experimental data to a debate that has, heretofore, been dominated by emotion. Our data have been published in both national and international peer-reviewed scientific journals. Our years of study have led us to conclude that the scientific data do not support the statement written in the report from the European Veterinary Scientific Committee (1998) that ” [t]he scientific committee on animal health and animal welfare concludes that force feeding, as currently practiced, is detrimental to the welfare of the birds.” That statement, while clearly taken for granted by opponents of foie gras, was based on the very limited amount of scientific literature available at the time and is not supported by the extensive scientific experimentation done in the intervening years.
The references quoted in the text are available on request.
]]>Two Recent Foie Gras Polls and What’s Behind Their Significantly Different Findings
This year, two separate surveys were conducted to gauge the public’s feelings about foie gras production and a proposed ban of the products in New York City.
Surprisingly, the surveys come back with very conflicting results.
Most notably, a poll conducted by Mason-Dixon Polling and Strategy, who specializes in advocacy group and political polling, suggests 81% of New Yorkers support a citywide ban on the sale of foie gras products.
By way of contrast, a poll conducted by Change Research, founded as a public-benefit corporation to promote legitimate polling methods, actually found a majority of New Yorkers, 54%, opposed to the proposed NYC foie gras ban.
How did two polls, surveying a similar pool of NYC voters, come up with such varying results?
Often times, differences can be exposed with a closer look at a poll and its methodology – who was polled, how were the questions phrased, etc.. So we did exactly that, we compared the two polls side-to-side and noticed some tell-tale differences.
The Marked Differences Between the Two Polls:
Survey Question Integrity
The Mason-Dixon survey worded its questions using the same inaccurate and misleading phrases that special interest groups have been using as triggers for years. Specifically, the poll refers to the duck livers used to produce foie gras as “diseased”, a term the USDA has repeatedly said is not accurate and should not be used to describe the product. A Federal District Court in California has upheld the USDA’s position on that front.
In another question, the Mason-Dixon poll depicts the gavage process – how the ducks are fattened – graphically describing a foot-long feeding tube being employed. This is not the case at New York duck farms, where an innovative, shorter, less intrusive, plastic tube is employed for feeding. (This picture shows the difference in the two types of feeding tubes)
On the left, the feeding tube often cited as an example by animal rights activists. On the right, what is actually used. A soft flexible plastic tube that is considerably smaller and able to assist feeding without stress to the duck.
In stark contrast, the Change Research poll actually educates its survey takers, asking them about their familiarity with foie gras and showing them various statements, from proponents both for and against the ban, soliciting their opinions on all. Arguments from both sides of the issue are laid out before ultimately asking people how they feel about the proposed ban. It refrained from using incendiary and accurate terms like “diseased” liver.
Number of Questions
One interesting aspect of the Mason-Dixon poll is its brevity. Aside from basic demographic information, it only asked respondents 3 questions.
The Change Research poll appears to be a little more thorough, asking respondents 17 questions, and narrowing down people’s responses based on the information they already possessed (accurate or not) on foie gras production in New York.
The Survey Pool
Another huge factor in methodology is the survey pool itself.
The Mason-Dixon poll solicited only 625 respondents. Did you know most legitimate newspapers and media outlets won’t even consider citing a survey that polls under 1,000 people? Why? Because below a thousand respondents are considered too small a polling pool to be significant. This is probably why only blogs and smaller niche media outlets gave this poll attention.
The Change Research poll, by contrast, was completed by almost twice that many respondents, 1,173. While not every respondent answered every question, more than 1,000 answered questions related to the proposed band, and it’s considered a legitimate, reportable survey.
Conclusion
Take a look at the polls themselves and see if you don’t think the Change Research came back with a more realistic look at how New Yorkers feel – based on their more thorough polling, presentation of both sides of the issue and qualified questioning of respondents.
]]>Industry Expertise from
United States Department Of Agriculture Response on Foie Gras Farming Practices
Text From Letter
This letter is in response to the petition you submitted in September 2011 on behalf of the Animal Legal Defense Fund (ALDF) requesting that the Food Safety and Inspection Service (FSIS) withhold the official mark of inspection from foie gras products unless the products are labeled as derived from diseased birds. The petition argues that because consumers expect that FSIS will only permit products from disease-free animals to bear the official mark of inspection, allowing foie gras products to bear the official inspection legend without disclosing that the products are derived from diseased birds misleads consumers, contravening the Poultry Products Inspection Act (PPIA) (21 U.S.C. 452 et seq.). The petition asks USDA to take regulatory action to withhold use of the official mark of inspection on foie gras products unless such products are accompanied by the following label: “NOTICE: Foie gras products are derived from diseased birds” in type determined by FSIS to be of uniform size and prominence.
We have completed our review of your petition and have concluded that it should be denied. First, we cannot concur in the premise underlying the petition, which is that foie gras products derive from diseased birds. As you are aware, FSIS previously denied a petition from you, dated November 2007, which was based on the same underlying premise, and your 2011 petition provides no reason to reach a different conclusion here. Second, the action you are requesting in the 2011 petition is not authorized under the PPIA, as the PPIA and implementing regulations require that diseased poultry carcasses and parts be condemned. Therefore, the plain language of the PPIA makes it impossible to grant your request.
To our first point, we disagree with your assertion that foie gras is a diseased product derived from diseased birds. As you are aware, on August 27, 2009, we denied a petition submitted by ALDF and other animal welfare advocacy organizations in 2007 requesting that FSIS prohibit for use as human food foie gras made from the livers of force-fed poultry. Similar to your 2011 petition, the 2007 petition argued that the animal raising practices associated with the production of foie gras induce disease in the birds. Specifically, both petitions assert that force-feeding birds for the production of foie gras results in a fatty liver condition, referred to as hepatic lipidosis or steatosis, which, according to the petitions, alters the ability of the liver to function normally resulting in impaired animal health. To support this assertion, both petitions reference a European Commission report1 and include statements from licensed veterinarians. We denied the 2007 petition, in part because we disagreed with your characterization of the foie gras liver as “diseased.” In our denial, we acknowledged that the appearance of livers of force-fed ducks and geese would be characterized as affected with hepatic lipidosis. However, we determined that the condition of the foie gras liver is due to the altered physiologic state of the bird rather than the result of a disease process.
In addition to arguing that force-fed foie gras is derived from diseased birds, both the 2007 petition and the 2011 petition assert that foie gras products may also induce disease in humans. To support this assertion, both petitions reference an article published in the Proceedings of the National Academy of Sciences that, according to the petitions, suggest that the consumption of foie gras may trigger the onset of Secondary Amyloidosis in certain people. 2 In our response to the 2007 petition, we noted that the study did not include data to establish a link between the presence of amyloid in foie gras and the development of human disease. We also concluded that more study is required to establish any link between the two conditions or the potential effect of consuming amyloid on human health.
Because the 2011 petition raises substantially the same arguments and rests on largely the same sources as the 2007 petition, the 2011 petition does not include any new information that would lead us to change our position on either of the issues raised in the 2007 petition.3
Second, even if we were to accept your argument that foie gras is a product of a diseased bird, the labeling statement requested in your 2011 petition would not be the appropriate course of action because, as discussed below, the PPIA and implementing regulations require that diseased and other adulterated poultry carcasses and parts be condemned and disposed of as inedible.
Poultry carcasses and parts from diseased birds are adulterated under the PPIA because they are “unsound, unhealthful, unwholesome, or otherwise unfit for human food” (21 U.S.C. 453(g)(3)). Under the PPIA, all poultry carcasses and parts thereof and other poultry products that are found to be adulterated must be condemned and destroyed for human food purposes, except that carcasses or parts that may be made unadulterated by reprocessing need not be condemned if they are reprocessed under the supervision of an inspector and thereafter found to be not adulterated (21 U.S.C. 455 (c)). The PPIA’s implementing regulations require the condemnation of poultry carcasses or parts exhibiting signs of certain diseases and conditions (9 CFR 381.81-381.94). As noted in your 2011 petition, these conditions include septicemic or toxemic disease or evidence of an abnormal physiologic state (9 CFR 381.83); evidence of disease characterized by the presence of toxins dangerous to the consumer (9 CFR 381.85); and inflammatory processes or evidence of general systemic disturbance (9 CFR 381.86). The 2011 petition asserts that all of these conditions are common in ducks and geese force-fed to produce foie gras.
Many of the conditions that you state are common in force-fed poultry, such as septicemia/toxemia, disease characterized by presence of toxins, and generalized inflammatory process, require condemnation of the entire carcass. A carcass is defined as “all parts, including viscera, of any slaughtered poultry” (9 CFR 3 81.1 ). Thus, if a carcass from force-fed poultry were required to be condemned for exhibiting signs of these conditions, the viscera, including the liver, would also be condemned. Condemned poultry carcasses and parts are prohibited for human food and must be disposed of as inedible by one of the prescribed methods in 9 CFR 381.95.
In addition, as stated in your 2011 petition, unwholesome parts of carcasses may be removed and condemned, and the remaining wholesome parts of the carcass passed for human food if found to be not adulterated by an PSIS inspector (9 CFR 381.72). Thus, even if force-fed poultry carcasses did not exhibit signs of a disease that would require condemnation of the entire carcass, if force-feeding were to induce liver disease as you contend, the livers of force-fed poultry would be unwholesome diseased carcass parts that must be condemned. In fact, based on this reasoning, your 2011 petition continues to assert that “no authority permits the passing of foie gras” for human food. If, as you assert, there is no authority to permit foie gras for use as human food, there would be no additional authority to permit its use for human food so long as it is labeled as “derived from diseased birds.”
As discussed above, we continue to disagree that foie gras from force-fed ducks and geese is a diseased product derived from diseased birds. In addition, even if we did agree, we could not take the action you are requesting in your 2011 petition. If foie gras were a diseased product derived from diseased birds, we would be required to grant the 2007 petition and prohibit its use for human food. The legal action challenging our denial of your 2007 petition on that issue is ongoing.
Therefore, for the reasons discussed above, we are denying your petition. In accordance with our petition regulations, we have posted your petition on the FSIS website (9 CFR 392.6). We intend to post this response as well.
Daniel Engeljohn,
Assistant Administrator
Office of Policy and Program Development
Industry Expertise from
BY: SUSAN C. KAHLER
READ ORIGINAL ARTICLEDelegates decide issue on science, current practices
Science versus emotion was the guiding principle invoked by several delegates presenting their views on foie gras production July 16 to the House of Delegates.
In this case, evidence was to be found not in a research setting but on the farm.
Foie gras is a delicacy made from the livers of ducks and geese. The term is French for “fatty liver.” Birds are force-fed mostly corn to create lipidosis, which expands their livers to several times their normal size.
Two resolutions were before the HOD opposing the practice of force-feeding ducks and geese to produce foie gras. One of them was a compromise version that had garnered some bilateral support from the AVMA leadership and animal rights advocates. It became obvious as delegates began their discourse, however, that a groundswell of support was building to refrain from adopting an AVMA opposition statement.
Delegates disapproved both resolutions.
Deliberations in the HOD centered not around which resolution was preferable, but whether to adopt a position on the practice at all. Two lines of reasoning ensued—determining what science says about the health and welfare effects of this practice, and whether it is advisable for the AVMA to take positions on specific production practices.
Limited peer-reviewed, scientific information is available dealing with the animal welfare concerns associated with foie gras production, but the observations and practical experience shared by HOD members indicate a minimum of adverse effects on the birds involved. Therefore, delegates decided it is not necessary for the AVMA to take a position on foie gras production at this time.
The issue emerged in the 2004 HOD, which referred a resolution opposing this practice to the Animal Welfare Committee for study. Subsequently, the AWC reviewed the scientific and ethical aspects of the practice and, in response, developed a different recommendation for Executive Board consideration.
This past April, the Executive Board forwarded the AWC’s recommendation to the HOD as a resolution—Resolution 3—so that delegates could decide the issue that originated in their chamber. It states: “Resolved, that the AVMA opposes the practice of mechanical force feeding of ducks and geese to produce foie gras because of the adverse effects on the birds’ health and welfare associated with this practice.”
The board recommended that the 2005 HOD approve Resolution 3 and disapprove the 2004 resolution—this year’s Resolution 1—which states: “Resolved, that the American Veterinary Medical Association hereby opposes the practice of force feeding ducks and geese to produce foie gras.”
The House Advisory Committee’s recommendations mirrored the board’s.
One of the key differences between the two resolutions was inclusion of the word mechanical in Resolution 3. By including it, the submitters sought to eliminate the animal’s stress in having a tube forced down its esophagus but did not rule out the feeding of a high-energy ration.
Some of the makers of Resolution 1 wanted to withdraw it in favor of Resolution 3, but parliamentary procedure would not allow that, since it was submitted by petition and had been referred to the AWC.
Prohibiting production of foie gras in the United States would have a minimal impact on agricultural markets, but several delegates expressed concern that efforts to oppose foie gras production were just “baby steps” by groups with much more ambitious goals. Many of the 13 delegates who spoke to the resolutions were food supply veterinarians who foresaw adoption of a position statement opposing foie gras production as having the potential for a domino effect on other agricultural practices.
The delegation from New York, where two of the country’s three foie gras farms are located, took a strong stand against the resolutions. The HOD deliberations began with New York alternate delegate, Dr. Walter K. McCarthy, saying that the New York VMS board unanimously voted to direct their delegate to cast a vote against them.
Dr. McCarthy said that if the New York Veterinary Medical Society were to oppose foie gras production, its veterinarians would fully expect opposition to methods used to produce veal calves and other livestock to follow. Referring to the positions proposed by the resolutions, he said that opponents of production agriculture could easily propose modifications to those positions that would make them applicable to other stock.
“We cannot condemn an accepted agricultural practice on … emotion,” Dr. McCarthy said. He presented what he considered facts about foie gras production to correct what he said are misperceptions. In contrast with what some critics claim, he said that the esophagus of the birds used for foie gras is lined with a cornified epithelium, “a very tough esophagus that can accept a great deal of abuse.”
He said it is very elastic and pliable, so the birds can swallow a huge amount of fish or grain. The birds don’t appear to be anxious around the persons feeding them, he said, and mortality is much less than at most agricultural facilities.
“The people who have actually seen these facilities are the ones you should listen to,” he added.
Two of those people are New Jersey and Vermont delegates, Drs. Robert P. Gordon and Thomas L. Munschauer.
Dr. Gordon did so because, he said, the AVMA “is claiming” to be a science-based organization. “We’ve all seen the pictures. Seeing with your own eyes and penetrating the issue is worth a thousand pictures.”
On July 5, he visited a farm in New York. “After being on the premises, my position changed dramatically,” Dr. Gordon said. “I did not see animals I would consider distressed, and I didn’t see pain and suffering.” He said it is more distressing to take a rectal temperature in a cat. He cautioned against anthropomorphism, which is different from the human-animal bond.
Instead of the term force-feeding, Dr. Gordon advocated tube feeding, a term he noted is used in veterinary medicine. Dr. Susan L. Clubb, alternate delegate for the Association of Avian Veterinarians, said that some owners feed psittacines via tube. Their esophagus easily accepts a tube without stress, she said, and it would seem logical that the same would be true in birds used to produce foie gras. AAAV delegate Dr. James M. Harris agreed with Dr. Gordon that the use of “emotionally laden terms” is inappropriate. “We are a science-based, factual-based professional organization. … Whatever decision we make today has implications for agriculture.” He appealed to his colleagues not to “give the squeaky wheel the grease.”
Dr. Munschauer visited a New York farm at the request of “both sides” and was conflicted by what he saw. “I didn’t see exploding esophaguses … and it didn’t seem like the birds were distressed,” he said. He judged the facility to be better than most places where broilers are raised. The birds were obese toward the end of the three weeks but still able to walk. They didn’t swim or preen, and they were dirty but not more than other birds. “For the most part, they appear to be well-cared-for,” he said. “That’s what I saw.
“Now, let me say what I think—it is not a good use of these animals,” Dr. Munschauer said. Even if they are treated in a reasonable way from a factory-farming standpoint, he said, the production of foie gras induces disease. Veterinarians may condone the induction of disease in animals for research to learn how tumors are formed, for example, because that benefits society. Inducing disease to produce a food delicacy does not benefit society, he said.
Delegates had differing views, however, on whether a disease process is induced. Dr. McCarthy, for example, insisted that the practice isn’t part of a pathologic process, and Dr. Harris said it is a physiologic not a pathologic process. Nebraska delegate, Dr. Theodore Evans Jr., pointed out that feeding enriched diets in cattle is an existing practice that also induces diseases such as laminitis, acidosis, and fatty liver.
Dr. Y.M. Saif, delegate from the American Association of Avian Pathologists, contacted a scientist who is a foie gras expert in France, where he said 85 percent of the livers are produced, and was assured that mortality is down and the feeding personnel are highly trained.
A prevailing sentiment was that “this is an issue above and beyond the (two) resolutions,” as Dr. Gordon said. A recurrent comment was the need for the AVMA to develop broader policies on animal welfare. North Dakota delegate Dr. Charles L. Stoltenow said, “The AVMA must be a champion for discovery of the facts and keep (actions) on a national level.”
Similarly, from the AAAP, alternate delegate Dr. Greg J. Cutler said, “We need to be looking at animal welfare from a broad policy position … that can then be applied to all animal operations.”
As dialogue drew to a close, a few delegates posed questions of a more pragmatic nature. Dr. Cutler wondered whether blocking production of a product such as foie would result in a Prohibition-type situation. Travis D. McDermott, Student AVMA delegate, asked whether it might be more appropriate for the AVMA to have a position about oversight of the production process than to condemn it. Alabama delegate, Dr. William E. DeWitt, asked delegates, “Do we want (foie gras) produced in our country, where we have control and guidelines, or (to be) importing it?”
]]>