Mar 22, 2017


CHICK-CITE has repeatedly commented on the dubious value of monographs issued by the International Agency for Research on Cancer, a body administered by the World Health Organization.  In recent months, IARC has created conflicts over classifying glyphosate as a potentially carcinogenic compound.  This claim was subsequently retracted based on strenuous opposition from reputable universities, toxicologists and specialists in mutagenicity.


Cal Dooley President and CEO of the American Chemistry Council (ACC) stated, “ The IARC monographs program has been responsible for countless misleading headlines about the safety of the food we eat, the jobs we do and the products we use in our daily lives”.  She added, “IARC work suffers from persistent scientific and processed deficiencies that result in public confusion and misinformed policy making”.  The American Chemistry Council is urging the World Health Organization to reform the IARC. The ACC considers the IARC to be lax in transparency and considerations such as weighing scientific evidence, thereby distorting public policy.

The U.S. Congress has requested documents relating to the preparation of IARC monographs since the Agency is partly funded by an allocation from the U.S. National Institutes of Health.


Visas for Foreign Agriculture Workers?

Mar 15, 2017


The Economist on January 28th reported on a program to import indentured workers from Haiti for a farm in Alabama.  Jon Hegeman who operates a small nursery found difficulty in finding laborers to pot plants and work in greenhouses. 

He was introduced to a program operated by Protect the People which focuses on alleviation of poverty in nations subjected to climatic extremes and earthquakes.  By using the leverage provided by the charity, visas were issued to eight workers from Haiti.


A study conducted by the Centre for Global Development documented the financial advantage of migrating to the U.S. to undertake manual labor compared to fellow citizens of Haiti who had no alternative but to remain in their native country. The monthly income of the migrants was approximately 1,400 percent higher than those that remained and most of the U.S. earnings were remitted back to families in Haiti. Apparently, a similar scheme offers temporary agriculture work in New Zealand to islanders of Tonga and Vanuatu and is regarded as an effective development policy by the World Bank.

The real issue is why is Jon Hegeman was forced to import temporary workers to carry out unskilled work paying close to $11.00 per hour. Were there no abled-bodied recipients of welfare in rural Alabama who would otherwise be available to work?  Should the Federal and state governments develop incentive schemes for farmers and employers to build acceptable housing to allow current welfare recipients to move from urban blighted areas to where employment is available. After all, there was a migration ten years ago to the oil fields of North Dakota in response to a demand for skilled and semi-skilled workers, many of whom were displaced from offshore oil installations in the Gulf and expatriate positions in the Gulf.

Erection of poultry processing plants in rural areas attracts applicants from among residents within commuting distance.  This is evidenced by the wide ratio of applicants compared to available jobs offered by Sanderson Farms in their new Saint Pauls NC. plant.  Is the difference between the Alabama farm of Jon Hegeman and the Saint Pauls plant established by Sanderson Farms a function of available workers living in the vicinity of a job opportunity?  If this is the case, programs to facilitate relocation and housing may reduce the need for foreign agricultural workers and at the same time shrink the welfare rolls.

During the Great Depression, displaced sharecroppers and disposed farmers migrated west to California and Oregon to work in orchards, vineyards and vegetable farms since there was little or no welfare available other than the WPA.  Perhaps both our politicians and welfare recipients should read John Steinbeck.


Lawsuit by Contractors Alleges Collusion by Integrators

Mar 8, 2017


As an anticipated offshoot of the now suspended GIPSA Rule, some contractors have initiated a class action lawsuit (Haff Poultry Inc. et al v. Tyson Foods Inc. et al. Case No. 17-CV-00033) in the U.S. District Court for the Eastern District of Oklahoma. Defendants include Tyson Foods, Pilgrim’s Pride, Sanderson Farms, Koch Foods and other integrators.

Allegations are that large broiler producers represent a cartel which has colluded to exchange information on grower remuneration and also to adopt policies disfavoring competition among integrators for contractors. It is acknowledged that through the monthly Agristats® reports integrators can determine historical levels of grower remuneration. The data is anonymous with respect to complexes listed but serves as a benchmark to establish a range of costs extending from breeding through processing. This does not constitute “collusion” as alleged.


The National Chicken Council estimates that there are 25,000 farmers with contracts to rear pullets, house parent breeder flocks or to grow broilers.  It is a reality that most integrators have waiting lists for new contractors and those wishing to erect new houses.  It is also an established fact that contractors stay with their integrators over many years, frequently exceeding the 15-year duration of their mortgage repayments and they enjoy excellent relationships with their servicepersons and their companies.

As frequently observed in postings on CHICK-CITE, the growth of the U.S. broiler industry is based on long-term satisfaction of mutual requirements of contractors and integrators.  Contractors have a regular income from raising broilers or housing breeders which smooths cash flow from their other farming activities which usually generate semi-annual payments for crops and livestock. The contract system allows available family members to participate in a collective farming enterprise.  Integrators are reliant on contractors to provide housing, utilities and labor to raise flocks. This allows them to concentrate investment and resources on capital intensive industrial components of production including feed milling, hatching and processing.  Integrators assume the risk of catastrophic disease, market fluctuations and increases in the cost of ingredients which represent up to 70 percent of live cost.

From experience and contact with the industry, there is little justification for claims that contractors are exploited or that integrators generate excessive profits at their expense.  If anyone profits unjustly from claims alleging exploitation, it is the legal profession and politicians.

Since the late 1940’s, the broiler industry has functioned with efficiency in a competitive environment, providing opportunities for contractors and their families and supplying our domestic and export markets with affordable protein.

It is hoped that the companies defending the spurious lawsuit will be successful in their efforts and the claims by the disaffected growers and their legal advisors will be regarded as without merit.


Kuwait Import Ban Rolled Back to January 5, 2017

Mar 1, 2017


According to a report in the February 27th edition of the USAPEEC Monday Line, Kuwait has set back the date of the import ban attributed to “avian influenza” to January 5th from February 9th. The USAPEEC estimates that shipments in transit affected by the January 5th date amount to $1.5 million.  According to the report authorities have detained one shipment on arrival.


The entirely unjustified ban is apparently based on a single isolation of avian influenza virus from a hunter-killed mallard in Montana during early January. The action taken by the Government of Kuwait is contrary to the policy of the World Organization for Animal Health which makes a distinction in significance between isolates of avian influenza from free-living birds and commercial farms.  In addition Kuwait should recognize the OIE principle of regionalization.  Broiler-exporting states are far removed from Montana and are not even on a common flyway.

Actions such as those taken by Kuwait although difficult to understand, occur frequently.  It is a personal recollection that in the late 1980’s this commentator was in the invidious position of requesting importation of infectious bursal disease vaccine into Kuwait based on high mortality attributed to the disease in non-vaccinated flocks.  An official in the Ministry of Agriculture refused to accept that IBD was in fact present in Kuwait despite the worldwide distribution of the infection including in neighboring states.  He was however willing to reconsider the situation when a bottle of grossly enlarged and hemorrhagic bursas, obtained a few hours previously, was placed on his desk for inspection.

The USDA-FAS, the APHIS and USAPEEC will have difficulty in reversing the decision by authorities in Kuwait by advancing science and OIE recommendations. Simply applying logic and geographic realities will be questionable given the byzantine and complicated interaction among government agencies in Middle East nations. Essentially a combination of institutional ignorance and stubbornness will mitigate against reversal of any decision irrespective of how fallacious the basis may have been. I am glad I am not a diplomat and only a diplomate.



Feb 22, 2017


It came as no surprise that during the first full working day of the Administration of President Donald J. Trump that an Executive Order was issued, formerly withdrawing from the Trans-Pacific Partnership (TPP).  It was anticipated that the TPP would have provided considerable advantage to agriculture although the potential downsides were highlighted by both Presidential candidates.


Formal withdrawal from the TPP has created a vacuum which will inevitably be filled by China which is promoting a competing Regional Comprehensive Economic Partnership.  Trade with Malaysia, Philippines and Thailand will be impaired in the absence of the proposed 12-Nation TPP.  Japan and specifically Prime Minister Abe will be the most embarrassed by failure of the TPP which was a cornerstone of his economic recovery strategy.

The World recently witnessed Xi Jinping extolling the virtues of free-trade at the Davos Gathering of economist and business leaders.  The reality is that China may talk free-trade but the reality is quite different. China effectively imposes barriers against importation, ignores intellectual property rights and promotes national enterprises many of which are government- owned, to the detriment of foreign competitors.

In an incisive editorial in the January 24th Wall Street Journal it was noted that the President might have had a stronger bargaining hand with China had the TPP been ratified, which was the hope of outgoing President Barack Obama.

To maintain exports, especially in the agricultural sector, the U.S. will now have to negotiate a series of bilateral trade agreements with Japan as the priority.

There will be no immediate economic impact from failure of the TPP. Going forward it will be necessary to balance self-interest with the realities of globalization in order to avert a decline in the export of agricultural commodities and poultry to Asian nations who comprise our accessible and qualified markets.


North Carolina to be the Battleground between EPA and State over Animal Waste

Feb 15, 2017


The U.S. Environmental Protection Agency (EPA) has addressed a letter to the North Carolina Department of Environmental Quality concerning continued health problem among minority communities living in the vicinity of large-scale hog operations.

There are more than nine million hogs on 2,000 farms in Duplin and Sampson Counties.  Following environmental complaints dating back to 1980, a moratorium was placed on expanding hog farms by the North Carolina General Assembly in 1997.


Craig Jarvis writing in the Durham News and Observer on January 20th noted the involvement of the North Carolina Environmental Justice Network, the Rural Empowerment Association for Community Health and the Waterkeeper Alliance.  These activist organizations claim that hog operations discriminate against minorities exposing them to “stench, flies, and other problems resulting in asthma and other health concerns”.

The news report suggest that harassment of activists has occurred including threats of physical violence.

North Carolina now has a Governor from the Democratic Party who narrowly defeated the Republican incumbent.  The Legislature of North Carolina is majority Republican, rural oriented and conservative.

As noted previously in both CHICK-CITE and EGG-CITE, environmental, welfare and disease-related issues affecting the hog industry have a commonality with the egg and broiler industries and regulatory action imposed on hog farms by both Federal and state agencies should be monitored.

Whether the Civil Rights Office of the Environmental Protection Agency will be allowed to pursue action against the state of North Carolina is questionable given the probable confirmation of Oklahoma Attorney General, Scott Pruitt as the future Head of the EPA. Despite tough partisan questioning at the nomination hearing, Pruitt will be confirmed resulting in a change of policy at the EPA.



Feb 8, 2017


A JBS plant in Louisville was the recent recipient of USDA sanctions as a result of improper handling, and stunning of hogs before slaughter.  The plant uses a captive bolt procedure which depends on adequate training of operators, restraint, supervision and suitable plant conditions to achieve optimum efficiency and welfare. 

The UDSA inspectors observed three incidents involving improper stunning during a two month period.  Although no fines were imposed, inspectors withdrew from the plant for a number of hours resulting in interruption of processing.  This is an expensive action costing as much as $40,000 per hour.


The USDA warned the management of the plant that they should be cognizant of repeated “egregious human handling violations”. Following release of intrusion videos by animal rights and activist groups, the USDA is especially sensitive to allegations of improper handling and welfare.

Only a few U.S. broiler plants have installed modified atmosphere stunning.  The industry standard is low voltage DC to render birds insensate followed by AC to and position stunned birds for optimal pre-slaughter treatment.  Since birds are not handled from the point of shackling onwards, the human factor relating to stunning and slaughtering of broilers requires appropriate adjustment and maintenance of stunners and rotary blade equipment.

The significant point of concern with regard to welfare activists is the exceptionally rare passage of birds with incompletely severed cervical blood vessels into the scald tank.  Accordingly agents representing animal rights groups usually attempt to function as a backup slaughterer. In this position they are able to generate “blue birds” (incompletely exsanguinated broilers) through deliberate negligence while they contrive to obtain clandestine videos to document alleged deviations from acceptable operation.

Adverse publicity whether justified or not, resulting from a claimed welfare incident in the kill- room can result in the loss of brand image and customer disaffection.

It should be expected that USDA will exercise more concern over monitoring regulations relating to humane handling and slaughter in both red and white-meat plants.


Wal-Mart Stores to Redefine Relationship with Suppliers

Feb 1, 2017


A January 24th article by Jon Springer in Supermarket News confirms that Wal-Mart Stores intends to establish a closer relationship with suppliers including cost negotiations and business interaction.

Walmart has embarked on a cost-cutting exercise. The Company has announced layoffs of administrative personnel at their headquarters. The Company will incur higher costs for wages and training. The need for economy in operations lies in the reality that the Company must invest in E-commerce in which it lags and to rationalize store size in numerous areas of the U.S.  The company is also extremely vulnerable to proposed import duties given the high proportion of its products come from China which is disfavored by the incoming Administration.  Imposition of import duties would raise prices and would further reduce store traffic and margins.


A memo address to suppliers as reported in industry press noted “Our objective is to simplify the way we work and to allow Merchants, Sourcing Managers and Replenishment Associates more time to do what they do best – support our customers’ needs. As such we are adding Merchants and Merchandise Support Teams in Bentonville.”  The memo continued “your Merchants will be more involved in managing supplier relationships including supply of business assignments, cost negotiations and longer-term strategic initiatives.”  Sourcing Managers will be more involved in collecting and evaluating agro-intelligence and will spend more time at farms and facilities and engaging key players in your organization.” 

If the intent is to “help” producers to do what they do best, Wal-Mart Stores will be wasting time and resources.  If the objective is to use knowledge gained through becoming “more involved” to ascertain producers’ margins in order to engage in tougher price negotiations they will create antagonism reminiscent of the situation in 2007-2010 managed by John Fleming, Chief Merchant.

Egg producers who are heavily committed to Wal-Mart Stores should be most concerned over the initiative.  If Wal-Mart Stores sincerely wishes to reduce the cost of acquiring eggs they might look carefully at the advantage and costs involved in interposing an intermediate between suppliers and their Company.  The purpose of the “middle man” appears superfluous and the rationality and financial justification of the arrangement is questioned. Currently the egg production industry operates with a high level of competition and price transparency, universal compliance with health and safety regulations, welfare certification and computerized records with repetitive third-party audits.


Cobb-Vantress Awarded “Compartment” Status in Brazil

Feb 1, 2017


In 2004 the World Organization for Animal Health (OIE) introduced the concept of a compartment to designate the disease-free status of breeding companies which operate with a high degree of biosecurity and freedom from specified infections.

These companies are considered eligible to export chicks and breeding stock subject to the conditions of the importing nation and compliance with OIE directives pertaining to “compartments”, irrespective of the disease status of the nation in which they are located.  In 2009 the government of the UK introduced a variation of compartmentalization to conform to EU regulations, including high levels of biosecurity and serologic surveillance.


Cobb Brazil is the first breeder in that Nation to receive certification as a Compartment by the Federal Ministry of Agriculture Livestock and Food Supply.  In accordance with Normative Ruling 21, Compartments must incorporate biosecurity, traceability and surveillance with specific emphasis on avian influenza and Newcastle disease.

Jairo Arenazio Executive Director of Cobb-Vantress for Latin America noted that “Brazil currently exports breeding stock to over twenty nations on four continents.”  He commented “compartmentalization has become a point of no return for the poultry industry, we are raising the health bar in the Brazilian poultry industry and showing once more it is leading the World in innovation and establishing a worldwide benchmark.

Dr. Monique Eliot Director General of the World Organization for Animal Health regards the certification as an international trend.  She stated “I want to be back in Brazil in a few years and verify that the country remains free of diseases such as avian influenza.”

With the outbreak of highly pathogenic avian influenza in the Midwest during 2015 breeding companies which were totally outside the affected states and were operated with a high degree of biosecurity were subject to embargos by various nations. This created problems for exports and impacted customers reliant on periodic importation of stock. Simultaneous outbreaks of diseases such as avian influenza in both EU and North America could impose serious restraints on production in many countries reliant on primary breeders for grandparent and parent level stock.

The OIE recognizes both Regionalization and Compartmentalization.  Regrettably some nations either through ignorance or to protect domestic production ignore both principles. China imposed a blanket ban on importation of breeding stock from the U.S. which has yet to be lifted despite assurances by the USDA and serologic evidence of freedom from avian influenza.  Restrictions on importation of breeding stock have seriously restrained production and expansion in the broiler industry in China to the detriment of commercial-level producers, QSRs and consumers.


Slow-Growing Broilers are Subject to the Law of Unintended Consequences

Jan 25, 2017


For diverse reasons welfare activists, vegans, agricultural Luddites and those opposed to all forms of intensive livestock production are promoting “slow-growing” broiler strains.  This is an extreme example of anthropomorphism in which rapid growth and favorable conformation achieved through genetic selection is regarded as antipodal to welfare. 


It is an inescapable fact that broilers commence life as ballerinas and at the time of harvest, six to eight weeks later resemble sumo wrestlers.  Optimal weight gain and feed conversion efficiency inherent to genotype can be achieved without detracting from welfare as denoted by low mortality and excellent integumentary quality displayed by high-yield flocks at the time of processing.

The National Chicken Council recently released a report on the environmental and economic impact of converting to slow-growing strains. Converting only one-third of U.S. broiler production, estimated to attain 41,550 million pounds of ready-to-cook chicken in 2017, to slow-growing strains would require an additional 1.5 billion birds annually to produce the same quantity currently produced with highly selected broiler strains.  The environmental impacts of the additional birds with inferior genetic potential for growth and feed conversion include:-

  • An additional 13.4 million tons of feed to be consumed
  • An area approaching 7 million acres will be required to grow the additional feed
  • Production of an additional 28.5 billion pounds of manure annually
  • Consumption of an extra 5.1 billion additional gallons of water annually to rear the slow-growing strains.

With respect to the economic implications, the cost to the industry and accordingly, to be passed on to consumers, could exceed $9 billion annually.  It is estimated that without adding 1.5 billion additional birds to meet demand, there will be a reduction of 27.5 billion center-of-the-plate chicken meals annually.

The exercise in promoting “slow-growing” broilers is a typical example of an effete, ill-informed, arrogant, high-income demographic imposing their unscientific views on the population at large. Their collective actions invariably result in degradation of the quality of nutrition leading to deprivation especially among our less-fortunate fellow citizens.

Many consumers even receiving Supplementary Nutritional Assistance need to divert income from food to rent, utilities and other essentials.  Adoption of “slow-growing” broilers may be fine for the boutique stores of this world with an affluent clientele.  The one in seven U.S. consumers using food stamps would obviously have a different view.

Slow-growing broilers should be available at a price and in quantities corresponding to demand.  This is after all what constitutes a free market.  Both consumer organizations and the broiler industry should however guard against imposition of unnecessary restraints or regulations which have a negative impact on sustainability, the environment, public wellbeing and the economy.



Jan 18, 2017


A research team at the University of Minnesota (UM), College of Veterinary Medicine recently published on studies conducted to determine the extent of dissemination of avian influenza virus from infected flocks. *

In a December 13th University of Minnesota release, the research team led by Dr. Montserrat Torremorell, described studies on the distribution and spread of swine influenza virus applying similar techniques as used in the poultry studies to ascertain the presence of the pathogen in the air within hog barns, in exhaust streams and in the vicinity of farms.


During the spring 2015 HPAI outbreaks, H5N2 avian influenza virus was isolated from the environment of infected flocks and in exhaust air streams within 300 feet from houses.  In addition, virus could be recovered from the ground in the vicinity of farms suggesting that intra-farm dissemination of virus occurs. 

The presence of viable avian influenza virus on surfaces in the vicinity of barns holding infected flocks creates the potential to pass infection between farms unless appropriate biosecurity precautions are followed.  What would be interesting is to confirm the presumption that virus remains viable at relatively low temperature on surfaces such as earth especially in the presence of moisture and biological material. Survival of virus should be compared to impervious surfaces such as concrete or blacktop with and without exposure to sunlight and effective disinfectants.

The studies on hogs detailed in the UM press release demonstrated the presence of swine influenza virus on particles suspended in air within houses, corresponding to the excretion of virus from animals in the herd.  The virus could also be isolated from soil up to a mile from infected farms raising the question as to whether exhaust streams or wind can disseminate virus from a concentration of infected hogs or poultry.

Studies conducted by the University of Minnesota established the following principles:-

  • Virus shed by migratory waterfowl in the vicinity of houses can remain viable for some time and theoretically can be tracked into houses in the absence of appropriate biosecurity precautions.  At a minimum, Operational Biosecurity should involve a complete change of outer clothing and footwear at the entrance to the farm and a change of footwear on entry to each house.
  • The persistence of influenza virus can be influenced by surface characteristics.  Roads and aprons in the vicinity of houses which are constructed with a layer of blacktop or concrete will probably not support viability of virus for more than a few hours. Prolonged infectivity can be expected on soil mixed with biological material.
  • Although it would seem epidemiologically beneficial to filter air entering houses the complexity of installations and their cost raises questions of feasibility and practicality unless there is a high probability of introducing infection.
  • Investment in Structural Biosecurity is a function of :-
  • The risk of infection,
  • The financial consequences of introducing a disease,
  • The effectiveness of the modality such as filtration or ultraviolet radiation.

In studies on the epidemiology of avian influenza among turkey farms in Minnesota it was concluded that migratory waterfowl in all probability introduced the H5N2 virus although there was negligible evidence of persistence among free-living birds during post-outbreak surveillance. Dissemination of virus and the high incidence rate of infection in affected counties was attributed to defects in both Structural and Operational biosecurity as determined by surveys which identified risk factors for introduction of infection.

In contradistinction geospatial evaluation failed to correlate wind direction with the temporal and spatial sequence of outbreaks. Notwithstanding this general conclusion anecdotal evidence was highly suggestive of individual cases of aerogenous spread of virus among closely located farms in Minnesota and one case in Wisconsin.

Multiplication of virus occurs in a large flock following infection. Dissemination is possible over short distances in exhaust streams which entrain virus-laden dust particles which are deposited on roads and soil surfaces. The possibility of subsequent spread by mechanical transport on tires and footwear is self-evident. It is for this reason that current control procedures mandate deactivation of ventilation systems followed by and rapid depopulation of a flock.

This is accomplished using carbon dioxide foam for floor houses or VSD for high-density cage units. Control of an outbreak is impeded by delays in depopulating flocks and herds as evidenced by the early stage of the mid-West epornitic and current events in South Korea. In contrast prompt and appropriate action in the Indiana “pop-up” outbreak in January 2016 confined spread and restricted the infection to nine houses despite the high density of poultry in the counties surrounding the index farm.

It is evident that both Structural and Operational biosecurity should be complementary since the two components of the system are mutually dependent.  With neglect of aspects of either Structural or Operational biosecurity, the entire system of protection fails with disastrous economic consequences when flocks are exposed to a catastrophic disease such as highly pathogenic avian influenza.

*Torremorell, M et al. (2016) Investigation into the Airborne Dissemination of H5N2 Highly Pathogenic Avian Influenza Virus During the 2015 Spring Outbreak in the mid-Western U.S. Avian Diseases 60:637-643.


Sanderson Farms and Others Oppose Mississippi HB 1523

Jan 11, 2017


Large companies with many employees and shareholders, irrespective of their product market scope, have a responsibility to speak out on legislation and social issues especially when earnings or the prospects for growth are impacted. 

During the past week, Sanderson Farms joined with other parties and companies in Mississippi to oppose House Bill 1523, enacted as a “religious liberties” law.  Implementation of the Bill is currently blocked by a decision of a U.S. District Judge but the status of HB 1523 has been referred to the 5th Circuit Court of Appeals in New Orleans. This legislation is regarded as discriminatory and unconstitutional addressing a situation perceived as a problem by a minority of the citizens of the State and region.


Setting aside the moral component, HB 1523 has proven to be damaging to the economy of Mississippi and the enterprises based within its borders. The State will lose investment and will suffer cancellation of conventions and sports events which bring money into the financially hard-pressed state.  At the very least, the Bill will not enhance the image of Mississippi, which is hardly regarded as a progressive and liberal enclave. Clearly the Bill will discourage migration to the state by professionals and entrepreneurs, who by their presence will increase productivity and wellbeing.

Michael Cockrell, Chief Financial Officer of Sanderson Farms is highly critical of HB1523 stating “It stigmatizes the entire state and will cause lasting harm to the Mississippi economy, driving down the GDP, deterring business development and expansion and costing the state jobs.”  He added “In economic development we do as well as our state and communities do, so we want them to do well-- because as they do well we do well.” 

Cockrell noted that Sanderson Farms has 13,000 employees in five states.  He noted “we don’t know how many of them were impacted by this Bill, but even if it was one, it’s important for us to protect their constitutional rights where we can”. Cockrell added “our vision states that we treat each person with dignity and if someone is impeded from exercising their rights that’s not respectful and it is important for us to make sure that our voice was heard”

North Carolina recently enacted HB2 which discriminates against specific demographics among its citizens.  It is generally accepted that through his action in signing the Bill, the previous Governor Pat McCrory narrowly lost his election to a Democratic opponent, Attorney General, Roy Cooper in the November 2016 election which demonstrated overwhelming support for Republican candidates.

Sanderson Farms is to be complimented on their stand supporting constitutional rights and advocating for rationality based on the financial and moral implications of unnecessary and discriminatory legislation.


Coordinated Publicity for Proposed GIPSA Rules?

Jan 4, 2017


Outgoing Secretary of Agriculture, Tom Vilsack is determined to place his stamp on the structure of U.S. food production by promoting the proposed Farmer Fair Practices Rules through application of the Grain Inspection, Packers and Stockyards Administration (GIPSA) mandates.

The proposed rules announced on December 14th www.gipsa.usda.gov, were published in the Federal Register during the last week of December 2016 despite avowed opposition from Congress which has consistently deflected any previous implementation over the past six years.

As reported in CHICK-CITE, in 2010 the Department of Agriculture conducted a series of regional hearings in conjunction with the Department of Justice.  At issue was the inherent perception among the then incoming Democratic Administration that contractors in the livestock and poultry industries were exploited by integrators.


Tom Vilsack

Why if conditions are so bad for growers do most companies have waiting lists for farmers wishing to erect houses and enter into grower contracts?  Why is it that the broiler industry over half a century has expanded to a current production of approximately 160 million broilers per week with over 95 percent of birds produced in grower-owned housing?

It is no accident that a news report promoting the Rules appeared in the December 20th edition of the Omaha World Herald. The article deprecated the present contract system and lauded the Department of Agriculture for its concern over reducing “market power willed over growers by processors, sometimes treating them unfairly, suppressing how much they are paid or pitting them against each other.”  The article accused integrators of retaliating against growers attempting to organize to bargain for increased remuneration or to complain over contract conditions.  The question of enhancements and improvements in facilities was also raised, using the false assertion that processors “require growers to make investments that are not economically justifiable for the grower and that processors can terminate contracts with little notice.”

The Omaha World Herald article which has appeared in various forms in other media suggests a campaign by proponents of the Farmer Fair Practices Rules, if not actually originated by the USDA. It is significant that the article highlighted the invidious position of contractors supplying a single plant in a region with no other alternative producers to supply contracts. This clearly alludes to the fact that Lincoln Premium Poultry intends to establish a complex near Fremont, NE. which fails within the circulation area of the Omaha World Herald.

The USDA maintain that following a review of comments on the proposed 2010 Rules, some issues were deleted or modified with the new Rule “focusing on the most damaging unfair practices that family farms face.” The tenor of the Omaha World Herald article is that avaricious integrators exploit small family farms.  Nothing is said about the risks the integrators take placing chicks on contractor’s farms and supplying feed and undertaking the inherent uncertainties of disease, escalation in ingredient costs, export embargos and competition in the domestic marketplace.

The contract system has functioned to the mutual benefit of integrators and contractors for seven decades.  The system works well if the relationship between integrator and contractor is based on mutual respect and fair remuneration.  Upgrades are required due to both age and technical obsolescence and benefit both parties.  Integrators need diligent and industrious growers just as contractors require regular deliveries of chicks and feed, technical assistance, removal of the flock and payment within a short period thereafter.

The free market and existing laws and regulations are adequate to ensure a level playing field. If unacceptable practices occur, there are avenues to obtain resolution through existing GISPA rules and the legal system.

The proposed Farmer Fair Practices Rules are a manifestation of the socialistic views of the current President and his Secretary of Agriculture. The message which Tom Vilsack did not glean from the regional hearings and comments was “if it ain’t broken don’t try and fix it.”


USDA Attempts End Run on GIPSA Rule

Dec 28, 2016


In the waning days of the current USDA administration, the Department has announced an intention to publish a set of rules which could seriously impact the relationship between integrators and contractors.  The rules were developed after a series of staged regional meetings organized jointly by the USDA and the Department of Justice in the early years of the Obama Administration.  


Congress then specifically enjoined the USDA from promoting and enacting the proposed regulations.  The most recent announcement by the USDA is regarded as an attempt to alter the Packers and Stockyards Act without Congressional approval. Three specific rules are at issue. These comprise the “Clarification of Scope”, “Tournament System” and the “Fair Practices” provisions.

The Clarification of Scope rule allows agreements between producers and packers relating to specialty products such as USDA Certified Organic and “hormone” and antibiotic- free products which are an especially important consideration in the beef industry. The Farmers Fair Practices rule if implemented would make the poultry industry vulnerable to specious claims and represents a blatant concession to trial lawyers. The “Tournament System” functions equitably if contractors understand the rules and method of calculating payment and if the integrator is fair and unbiased in implementing the procedures with regard to recording production parameters.

In commenting on the action by the Department of Agriculture, Mike Brown, president of the National Chicken Council released a statement on December 15th incorporating the following comments:

  • “These rules could lead rigid, one-size-fits-all requirement on chicken growing contracts that would stifle innovation, lead to higher costs for consumers and cost jobs by forcing the best farmers out of the chicken business.”
  • “Some of the provisions could also have a detrimental impact on the welfare of flocks by eliminating competition and the incentive to provide the best care possible on the farm.  The performance-based contract structure of modern poultry production was designed to put the well-being of birds as the top priority, as incentives are given to farmers who raise the healthiest birds and work hard.  It incentivizes farmers to do their best, to compete, just like every other business in America or any other free market.”
  • “Business under the current contract structure has given thousands and thousands of farm families an opportunity to live in rural American and operate profitable businesses that allowed them to build homes, expand other aspects of their farm enterprises and to put their children through college.”

The Meat Institute also condemned the proposal stating “Although GIPSA provided an opportunity for affected stakeholders to comment on the Proposed Rule, more than six years have passed since its publication. If the Agency relies only on the administrative record as it existed when the comment period closed in November 2010, it is affirmatively choosing to ignore the many changes in and evolution of the livestock, meat, and poultry industry during the past six years and would publish a rule on a record that can only be described as “stale” and not developed in a ‘timely fashion’."

CHICK-CITE strongly condemns a cynical attempt to impose standards reflecting the views of a few political appointees in the USDA on the entire protein-production segment of U.S. agriculture. The intended rules are merely an attempt to endow a liberal legacy, in defiance of determinations by our Congress and will be contrary to the productivity and profitability of food producing companies.


Americans Divided Over GMO and Organic Foods

Dec 21, 2016


The Pew Research Center, noted for its antagonism towards intensive livestock and crop production, conducted a survey on 1,480 adults to determine attitudes towards conventional, GM-free and organic foods.  The survey noted that 55 percent of the respondents considered that organically-grown produce was healthier than conventional counterparts, while 41 percent did not consider that there was a difference. 

Forty percent of respondents considered that GM foods were “worst for health than other foods” while half said there was no difference.  The remaining ten percent of respondents felt that GM foods were healthier.


Only six percent of the respondents said that most of the food they eat is USDA Certified Organic. A negative perception of GM foods was held by young adults who are obviously more susceptible to misinformation disseminated by social media.  Not surprisingly, the survey disclosed that respondents had a lack of trust in scientists. A high proportion of this demographic either are unaware of, or discount data and reports from scientific organizations that there is no difference between conventional and GM foods.

As with all surveys, results and interpretation depend on how the sample of respondents was selected and how questions were phrased.  The bias demonstrated by Pew in previous surveys* and their activities suggests that the results may not be generally applicable to U.S. consumers.

 Notwithstanding any overt bias, it is evident that promoters of GM foods must concentrate their publicity towards users of social media and should develop appropriate messages to dispel inaccurate and false assertions by the opponents of GM foods.  The current approach of using scientists or leveraging affiliation with Land Grant Universities and scientific associations is obviously ineffective.  Perhaps companies and institutions benefiting from GM ingredients and foods should consider using spokespersons in the sports and entertainment arenas to project messages that appeal to the target demographic of millennials, homemakers and the “worried well”.

*See Posting March 11th 2016


Antibiotic Resistance Demonstrated on U.S. Swine Farm

Dec 14, 2016


Carbapenem resistance among potential pathogens was detected on U.S. swine farms by researchers at the Ohio State University.  Eighteen isolates of Enterobacteria have been shown to express imp-27, a gene coding for beta-lactamase production which confers resistance to carbapenem antibiotics. 

This plasmid gene is readily transmissible to other bacteria.  The isolates were obtained in the environment of a barn housing sows on a thorough-to-finish farm during 2015.  The resistance gene was identified in two isolates of E. coli and one of Proteus mirabilis a ubiquitous but nonpathogenic bacteria in a nursery room and from farrowing rooms. 


Stock ready to harvest did not yield any bacteria carrying the imp-27 plasmid transmitted gene.  Subsequent to the survey on the 1,500-sow operation, the OSU investigators recovered the gene from organisms in feces suggesting that some animals on the farm have been colonized with enterobacters carrying imp-27.  Dr. Thomas Wittum Chair of the Department of Veterinary Preventive Medicine at the OSU College of Veterinary Medicine speculates that “there is a clear relationship between carbepenem resistance and the use of ceftiofur antibiotic which is common to human therapy.  There is at this time no relationship between administration of cephalosporin antibiotic and the emergence of carbapenem resistance.”

Dr. Tim Johnson of the College of Veterinary Medicine at the University of Minnesota noted that the Ohio State University study “revealed the real and long thought inevitable threat of carbapenemase-producing Enterobacteriaceae making the way into animal production facilities with subsequent risks to the human food supply.”

While the finding is not a “smoking gun” the investigation together with a previous demonstration of the presence of mcr-1 plasmid mediated gene imparting resistance to colistin in Asia, the EU and most recently the U.S. justifies action taken by the FDA to restrict antibiotic use to veterinary supervision applying Prudent Use Principles.

Carbapenem resistance Enterobacteriaceae are taken seriously by the Centers for Disease Control and Prevention since it is estimated that there are 9,300 nosocomial (hospital-related) infections resulting in 600 deaths annually in the U.S.  Immunosuppressed patients and those on life support systems or receiving long-term intravenous therapy are especially at risk.

The National Pork Board placed a positive spin on the report noting that the antibiotic resistance gene was isolated in the environment of sows and weanlings and was not present in stock destined for slaughter and accordingly was not of any threat with respect to food safety.  This avoiding the issue.  The problem relates to transmissible drug resistance and not foodborne infection.

It is a matter of record that hog farmers participate in the Ohio State University Public Health Preparedness for Infectious Diseases Program.  Producers cooperate with research to understand the epidemiology of antibiotic resistance in foodborne disease.  The National Pork Board accepts that additional studies are necessary (to validate and attempt to replicate the findings).

Additional revelations will support contention of organizations opposed to intensive livestock production and will also result in congressional action with pressure on regulatory agencies including the FDA and the FSIS.

Any attempt to belittle the significance of the epidemiologic studies or to deprecate the activities of individuals at Ohio State University will boomerang to the detriment of the pork industry and indirectly all livestock production.



Dec 7, 2016


A recent press release from the Birsa Agriculture University at Ranchi, Jharkhand State, India describes development of the Jharsim broiler strain. The release was reproduced without comment by a poultry periodical, ignoring the implications of this “non-event”.  What is evident from the exercise in breeding and reinforced by personal observation of similar indigenous “make-work” programs, is the degree of self-delusion demonstrated by academics in India involved in the development of “new and local” strains for meat and egg production.


The claimed performance for the Jharsim chicken is a live weight of 450 grams at six weeks.  This may be compared to the Cobb 500 broiler used commercially worldwide which attains

2,700 g at the same age with a feed conversion of 1.75 to 1.85 depending on housing and nutrition.  The Birsa Agriculture University claim a weight at maturity of 1,700 grams without specifying either age or feed conversion.  Although the strain was developed for small-scale production as a dual-purpose chicken it has the claimed genetic potential to lay 140 eggs over a 72 week period. This is under controlled experimental-farm conditions. When subjected to suboptimal nutrition, predator- loss, disease and natural day length, performance probably will be no better than the 50 to 60 eggs laid per hen placed, corresponding to native varieties of backyard chickens.

Money spent on development of indigenous strains in India is not only a waste of money but also runs counter to the imperative of sustainability which should be derived from efficiency.  The Nation is short of all commodities, possibly with the exception of wheat. In practicality all domestic monogastric livestock is in competition for available nutrients with the burgeoning population. It is calculated that the effective feed conversion based on carcass weight would be 3.2:1 for the Jharsim strain assuming a live weight of 1,75 kg, live feed conversion of 2.4 and a 75 percent yield. In contrast the Cobb 500 strain under commercial conditions in India would produce a 2.7 kg broiler with a feed conversion of 1.8 and a yield of 80 percent with giblets. The effective feed conversion would be 2.2:1. For every 1 million live birds produced, the Cobb 500 would produce 2,160 tons of saleable product compared with 1,312 tons from the indigenous strain. Restated, to produce 2,160 kg of processed whole bird with the Jharsim strain would require 6,914 tons of feed compared to 4,860 tons for the Cobb 500 strain. This would necessitate consumption of an additional 1,438 tons of grain and 410 tons of vegetable protein in a nation hard-pressed to feed its human population.  

The developers of the strain refer to the immense production of eggs and chicken by China Reading into the article it may be inferred that there is an apparent preoccupation among academics and administrators in India with the size and success of their Asian counterpart. Trying to achieve the output attained by China by promoting backyard production is a futile exercise.  Backyard chickens will neither provide food nor employment at the levels corresponding to intensive commercial production in both Nations.

Claims for “resistance to disease” inherent to the Jharsim strain may well be justified since erosive infections may not be quantified in a low-performing strain. Exposure to catastrophic pathogens such as HPAI which are endemic in the Nation would reveal the fallacy of attempting to breed for “resistance”.

Implementing a retrograde genetic program has profound implications in terms of sustainability and for the economic realities of producing food.

A pair of Jharsim birds at BAU in Ranchi. (Courtesy Telegraph of India)


Activists Group Urges McDonald’s to Eliminate All Antibiotics in Meat

Nov 30, 2016


The Congregation of Benedictine Sisters of Boene, TX., a nominal shareholder in McDonald’s Corporation has resumed the call for the Company to ban all antibiotics used to produce meat and poultry for their supply chain. 

In 2015, twenty percent of shareholders voted in favor of a similar proposal.


McDonald’s has already announced that antibiotics of human health significance will not be allowed to produce foods for their supply chain but has yet to issue a timeline for complete elimination of antibiotics. The Company noted that “we continue to engage with key experts including some who serve as advisors to the World Health Organization to advance progress across the industry.” One of the problems facing McDonald’s is that in many nations, suppliers do not have systems to verify compliance.

According to Reuters, the Congregation of Benedictine Sisters is part of an Interfaith Center on Corporate Responsibility which has links to activists and pro-vegan organizations.  Two of these groups, As You Sow and Farm Animal Investment Risk and Return are targeting a number of quick service chains and protein producers.

The Food and Drug Administration has taken appropriate action based on available science to eliminate routine sub-therapeutic administration of antibiotics for the purpose of growth promotion.  By classifying antibiotics according to criticality and importance in human therapy, restrictions have been imposed on administration to livestock.  The regulations governing veterinary feed directives and prescriptions will take effect in January 2017 and should regulate the use of antibiotics for preventive and therapeutic purposes. 

This action which represents a science-based and responsible move towards reducing and ultimately eliminating antibiotics will prove more effective than web-postings and corporate resolutions which are effectively coercion.  Generation of hysteria implicating food animal production in the emergence of multi-drug resistant pathogens in human medicine is superficially effective at the interface of our FMI, NCRR and NRA customers and their consumers.

Unfortunately the statistics on drug resistant infections which are deliberately distorted and frequently misquoted appear convincing but should be questioned.   The most significant drug-resistant diseases responsible for hospitalization and fatalities include tuberculosis, Clostridium difficile enterotoxemia, and gonorrhea, none of which have any connection to livestock production or administration of specific human-designated drugs. The main genera of pathogens involved in emerging drug resistance in the U.S. and the EU are included in the acronym “ESKAPE” (Enterococcus, Staphylococcus, Klebsiella, Acinetobacter, Pseudomonas, and Enterobacter)

Notwithstanding available scientific information, the public perception that administering antibiotics to livestock is deleterious to human health persists. It is inevitable that market pressures will demand production of antibiotic-free protein by the poultry and meat industries. Many of our leading producers are progressing towards antibiotic-free production or are marketing brands with a USDA Verified, “No Antibiotics Ever” claim.


Controversy over the Georgia Dock Benchmark Price

Nov 23, 2016


On February 10th 2016, CHICK-CITE posted an article refuting a January 19th article in The Wall Street Journal which implied that an inflated Georgia Dock price could increase retail prices.

The reliability of the Georgia Dock price index has simmered for a number of months culminating in an extensive posting on Seeking Alpha by an anonymous analyst ManBearChicken, an acknowledged short on the three public traded broiler stocks.


Subsequent negative publicity arising from the Thursday November 10th New York Times report resulted in an approximately five percent decline in the share price of Sanderson Farms (SAFM); Pilgrim’s Pride Corporation (PPC) and Tyson Foods (TSN).  Given that the three companies have a collective market capitalization of $31 billion, publicity relating to the Georgia Dock price has cost shareholders $1.5 billion. By Friday 18th November, observers considered that the reaction was overblown.

The recent news reports and postings suggest that the composition of the Georgia Dock price and its compilation have resulted in overpayment by customers who have used the index as a basis for payment.  Data shows that there was close correspondence between the USDA Composite Index, the Urner Barry Index and the Express Markets Index through 2011. Price deviation between the Georgia Dock price when compared to the other three indexes was evident from 2012 onwards.  Despite seasonal fluctuations in the price of chicken, the Georgia Dock price demonstrated both consistency and a higher level with exception of mid-2012 when feed prices were exceptionally high and then again during mid-2014.

The Georgia Dock price is derived from the voluntary submissions by ten companies producing broilers in the state of Georgia, weighted by their relative production. The effective weighting of two of the ten participants amounts to 47 percent of the total and the top three represent 61 percent of the weighting. In addition, the Georgia Department of Agriculture introduces “smoothing” by eliminating outliers from the calculation. Any responses that are either one cent per pound above or below the weighted average are removed from the index.  The Georgia Dock price is based on ex-plant values and does not include transport which may amount to as much as five cents per pound.

 The issue raised by opponents of the Georgia Dock price is that buyers incorporating this index in their contracts may well have been overpaying relative to customers purchasing on the basis of the alternative Urner Barry, USDA Composite or Express Markets indexes.  As of October 31st 2016, the Georgia Dock price was $1.10 per pound; Urner Barry, $0.72 per pound and the USDA Composite $0.71 per pound. This data confirms close correspondence between the Urner Barry and USDA prices which were approximately 30 percent below the Georgia Dock Index.

Based on questions concerning the validity of the Georgia Dock index price, the USDA removed the quotation from their website in early August 2016 and introduced a national whole broiler/fryer quotation based on a 2.5 to 3.5 pound Grade A whole-bird and incorporating a provision for freight. 

The controversy over the derivation of the Georgia Dock price and discrepancies between the index and three other benchmarks will surface in the September 2nd class-action lawsuit filed a by a food service distributor alleging price fixing in the chicken industry. As noted in CHICK-CITE the plaintiffs alleged collusion by virtue of subscribing to and using cost data circulated to subscribers to the AgriStats® program.  At the time, CHICK-CITE noted that this was a spurious claim with no relevance to marketing, given the historical nature of AgriStats® data which is restricted to production cost with the intention of enhancing efficiency and productivity.  Revelations concerning the Georgia Dock price  will now be raised to buttress what is generally regarded as an attempt to shakedown producers.

The effect of the exposure in press reports and web-postings of the differentials among the benchmarking indexes and implications of collusion among the companies providing price data to the Georgia Department of Agriculture has already resulted in financial damage in addition to reputational concerns.  ManBearChicken extended the analysis by adjusting the future earnings of the three public-quoted companies noting that if revenue were to conform to the Urner Barry price they would effectively have generated losses in past quarters.  This is a somewhat spurious approach since the companies concerned have a wide range of customers for diverse products other than whole birds and use different selling strategies. Accordingly revenue represents a mosaic of products and prices.  ManBearChicken considered he was justified in prejudging the issue and projecting fines and penalties which may or may not be valid in terms of the Sherman Antitrust Act. The extreme case presented incorporates punitive damages to be awarded to customers, and has a profound effect on predicted share price under a worse-case scenario.

In a Friday 18th November statement the National Chicken Council (NCC) rebutted articles which have appeared on the websites of The New York Times, Investor’s Business Daily and Seeking Alpha. The clarification included, “Chicken companies use a variety of methods and price reporting programs to sell their products.  The Georgia Dock is a long-standing publicly available index and is only one of several indexes used by chicken buyers and sellers including USDA, Urner Barry, EMI and Informa”.  Justifiably the National Chicken Council maintains that customers can select from among the Georgia Dock price or any other index as a rational business decision.  There is no obligation to use the Georgia Dock but according to the NCC it has been found to be “effective to start negotiating the price for chicken.”

 The fallacy in the New York Times and other articles is that the Georgia Dock price “is blindly accepted without any adjustment” according to the NCC.  The ManBearChicken posting specially states “we have spoken to dozens of buyers at grocery stores across the country and we have yet to find a single customer of Tyson Foods who doesn’t use the Georgia Dock contract”.  This is an unsubstantiated statement which belies the business acumen of buyers in diverse segments of the food industry involved in food service, retail and manufacturing.

The NCC statement noted “most if not all large volume poultry buyers retain outside consultants to continually advise them on price discovery and timing for purchases.  In the very competitive marketplace it is difficult for sellers to gain an arbitrary price premium when the buyers have the clear and easy option to take their business to another chicken supplier”.

The price of chicken is determined by supply and demand and is not predicated by any single index irrespective of how it is calculated. Since broiler integrators function in an environment characterized by mild and occasionally significant overproduction, the reality of competition, irrespective of contracts, contributes to fair pricing.


Research on Blackhead disease in turkeys

Nov 16, 2016


Dr. Robert Beckstead has been appointed to an endowed Chair in the Prestage Department of Poultry Science at North Carolina State University. His specific mission is to develop practical and efficient methods to prevent and possibly treat Blackhead (histomoniasis) in turkeys.

Following the introduction of the disease to the U.S. by asymptomatic pheasant carriers in 1890,  domestic wild and commercial turkey populations have been severely impacted by the protozoal pathogen Histomonas meleagridis.

The economic significance of the disease declined after introduction of nitrasone in 1950 which was an effective preventive compound when added to feed and by the nitroimidazoles for treatment. Accordingly research on the pathogen and the epidemiology of blackhead waned through the 1970s but resumed following withdrawal of both compounds during the first half of the present decade.


Robert Beckstead

Recent studies by Dr. Larry McDougald of the University of Georgia have demonstrated the effect of intra-flock transmission of Histomonas by “cloacal drinking”.  It is significant that Histomonas will not remain viable outside the host in litter for more than three hours.  This is due to the fact that the protozoan pathogen lacks mitochondria and is reliant on anaerobic metabolism using hydrogenosomes.  The role of the cecal roundworm Heterakis gallinarum in the transmission of Histomonas has been well documented. 

The protozoan parasite is carried within the ova of the cecal roundworm.  The voided Heterakis ova require 14 days for embryonation.  When the roundworm ova is ingested by a turkey host, the larva is released. In the process of maturation, the larvae molts dispersing the Histomonas organisms which infect the enterocytes lining the cecum initiating the infection.

Following the withdrawal of both nitarsone as a preventive agent or the nitroimidazoles for treatment, producers are currently evaluating combinations of probiotics, prebiotics, botanicals, and minerals including zinc and copper to prevent the disease.  Unfortunately field trials do not incorporate controls and since the disease is sporadic, a specific modality which appears to control the disease in the absence of challenge may be erroneously regarded as effective.

Dr. Beckstead has developed a challenge model to evaluate the preventive action of various compounds. His studies have failed to show any benefit from a range of feed additives with mortality ranging from 85 to 90 percent when infected at 28 days of age with viable Histomonas.  Applying a lateral transfer model, where twenty turkeys are penned together, with five infected and fifteen exposed, neither zinc nor copper feed supplements prevented infection. 

Dr. Beckstead also noted that deworming flocks after onset of a blackhead outbreak is futile.  Currently strict biosecurity is the only effective method of preventing introduction of Histomonas into flocks.  Under experimental conditions simple fencing within a common area will prevent transmission of Histomonas from an affected group of turkeys to susceptible non-contact birds.  Future studies will be directed against agents which will disrupt the outer coat of the ova of the Heterakis intermediate host during the stage of embryonation. 

Neither salt nor lime added to litter is effective although temperatures under 50 F will delay development of Heterakis ova but a temperature of 150 F is necessary to destroy viability.  Various compounds which have been proven effective against malaria are under evaluation as potential therapeutic agents and work is currently in progress on developing a vaccine in the EU.  Attenuated strains of Histomonas have been prepared but have generally provided inadequate protection even when administered by the intra-cloacal route.


Copyright 2017 Simon M. Shane