SAPA Egg Organisation Response to Animal Law Reform South Africa Report Titled: “Scrambling
for Truth” of September 2024.
We understand that the aforementioned report compiled by Animal Law Reform SA is the
supplementary report to the initial report titled “Laying Down the Facts: Animal Welfare Standards
of the Standards of the Companies Providing Your Favourite Foods” (Published in August 2023).
We wish to inform you that SAPA rejectsthis so-called research done by Animal Law Reform SA about
the South African Egg Industry and the value chain. In our opinion, this is a very misleading literature
review aimed only at forcing the agenda of cage-free egg production systems in South Africa,
attempting to use Environmental Legislation to create panic in the public. Secondly, the attempted
use of the Promotion of Access to Information Act No. 2 of 2000 (“PAIA”) to intimidate, abuse, and
cause vexatiousness to the producers, Retailers, Food manufacturers, animal feed manufacturers,
consumers and the Government State-owned entities. This disruptive strategy employed by Animal
Law Reform is similar to the one that was done in the United States of America by welfare lobbyists
for the push for cage-free systems. This is not to mention the fact that in various attempts by Animal
Law Reform SA to utilise PAIA to gain access to information from SAPA, they have failed to establish
sound legal grounds permitting them to obtain the requested information which is evident of the fact
that there is no sound legal basis for the claims which Animal Law Reform SA has made. This is further
evident by the fact that to date, Animal Law Reform SA has been unsuccessful in all attempts to invoke
the provisions of PAIA against SAPA.
We strongly reject this non-factual literature review in its entirety based on, amongst others, the
following grounds:
- The report is not factual, is based on incorrect information, is written in a sensational manner,
and it aims to create public panic to gather support for the move to cage-free systems in South
Africa, similar to some of the few developed wealthy Western countries that have voluntarily
considered or have been forced to move to cage-free systems based on time commitments
and certain state legislation (such as only 10 states out of 50 in the USA). - The report paints eggs as an unhealthy animal protein source that is related to serious diseases
like cancer (This claim is disturbing and surely if it was factual, the National Department of
Health would have long imposed a ban on the consumption of Eggs in RSA). - The report fails to acknowledge the Global facts that, according to the World Organisation for
Animal Health, the chapter on the welfare of layer hens is not yet concluded. This means cage-free egg production is not Globally mandated. Each country can make its own decision on its
egg production methods. The report conveniently ignores the leading authority, the World
Organisation for Animal Health, on this topic. - The report fails to acknowledge that Highly Pathogenic Avian Influenza is now endemic and is
the most concerning issue that is Globally devastating to the Egg Industry. - South Africa alone in 2023 was hit by two strains of the Avian influenza, the H5 and H7
variants, resulting in about 30% of the National layer Flock size by law being mandatorily
destroyed (culled) with no compensation. - Animal Law Reform SA fails to acknowledge some of the technical aspects that in South Africa
we do not remove “spurs” and or “De-toe” any layer chickens. - Day old female layer chicks are beak treated using laser infra-red which removes only the
sharp point from the end of the beak and prevents cannibalisation and vent pecking. - Layer breed fertile Eggs hatched are approximately 50% male and 50% female. The egg
industry has no use for the male layer breed chicks which are immediately macerated rather
than the old method of disposal by gassing. The practice of using a macerator is the
internationally accepted method of disposing of male day-old layer chicks where it is not
economically viable to raise these layer breed male chicks to 18 weeks slaughter mass versus
a broiler breed chick which reaches slaughter weight at 6 weeks. - The report further fails to acknowledge that more than 60% of the Global Eggs are produced
by the BRICS countries and the stance within this block is that food security is the priority
without compromising the welfare of the chickens. Less than ten percent of eggs produced in
the BRICS countries are cage-free. - South Africa is also a member of the BRICS block, and hence we believe that all the 3 existing
production systems Barn, Free Range, and Caged systems in our approved regulations should
remain in South Africa allowing the consumer to purchase eggs based on their affordability. - Should the demand for cage-free (called “Free Range” and “Barn”) produced eggs increase,
producers are at liberty to start producing these eggs if economically worth their while. - It is scientifically proven that the bio security risks of the spread of diseases of cage-free hens
and eggs produced from these systems are considerably higher than eggs produced by hens
in cages, which are cleaner and less likely to convey salmonella than cage-free produced eggs.
We would like to give comfort to the South African consumer that we are not against cage-free
production systems, however, demand will drive the production of these products. Unfortunately, at
this stage, we do not see that demand due to several factors including our majority populations poor
economic situation. The objective of Animal Law Reform SA to attempt to downplay the need for food
security in South Africa is particularly concerning. The fact that the report by Animal Law Reform SA
fails to address the concerns around food security and the fact that Animal Law Reform SA fails to
factor this in to the one-sided conclusion which the report reaches is evident of the agenda which
Animal Law Reform SA and their funders are seeking to achieve.
We further now also know the risks associated with Avian influenza (Bird flu) and regret have no
vaccines at this stage. Bird flu infection is mainly caused by migratory wild birds as the initial vector,
causing free range hens to be immediately confined in their barns legally for periods up to 24 weeks,
continue to be sold as free range, and thereafter forced by law to change labelling to Barn eggs.
Our independent research lays a solid foundation about the facts of the South African Egg Industry if
we consider a 100% move to cage-free:
i. In 2021 it was revealed that a direct investment of R4,93 billion is necessary to switch South
Africa to a cage-free system. If the cost, (spread over 5 years) can be passed on to the consumer, then it will mean an additional cost above cage produced cost of eggs of between
R5,70 and R6,00 per dozen of eggs for the 5 years. It is estimated that the GDP of the Egg
Industry will decline by 21%, whereas the impact on the use of capital will decline by 27%,
while the impact on employment will be a 12% decline.
ii. The industry will further decline by 36%, now in a country like South Africa with a dual
agricultural sector, one of the most underlying questions is where do you then talk about
transformation if the industry will decline by 36%? Instead of increasing and encouraging the
growth of the industry to allow fair participation of the historically disadvantaged individuals,
welfare NPO’s similar to Animal Law Reform SA disregard historic imbalances of the industry
and the strategic approaches detailed in the Egg Master Plan and the Agriculture and Agroprocessing Master Plan.
We again reiterate that the report compiled by Animal Law Reform SA fails to factor in all of the
abovementioned points. This, unfortunately, results in the report from Animal Law Reform SA
reaching a very one-sided and biased conclusion. One needs to question the authenticity of a report
which fails to consider a matter from all angles. The fact that the report fails to adequately address
and factor in these points speaks louder than words.
In conclusion, we urge Animal Law Reform SA to immediately refrain from portraying the Egg Industry
as a reckless and self-regulatory industry that operates outside the scope of the Laws of the Republic
of South Africa. If there was anything practiced outside the Laws and gazetted Govt. Regulations of
the Republic of South Africa, surely by now the Government would have long ago seized many of our
production units. The fact that all attempts by Animal Law Reform SA to invoke the provisions of PAIA
to date have failed further reiterates this point.
The South African Egg producers wish to assure the consumers that we will continue to adhere to the
laws and regulations of the country and continue to produce quality eggs at affordable prices based
on purchasing power. Regular inspections by a Government appointed assignee occur at farm, at the
egg pack station and at points of sale in the market, ensuring label, weight and quality compliance,
with strict adherence to the Government regulations applicable.
We hope to see the industry fully recover in the second half of 2025 to the previous layer flock
numbers after the devastation of the 2023 HPAI (bird flu), and to be allowed to vaccinate as
expeditiously as possible once the science proves the efficacy and safety of the HPAI Vaccinations to
the State authorities.
For any clarity and comments on the matter please contact:
Dr Abongile Balarane
abo@sapoultry.co.za