In order to pay for expensive hog and poultry facilities, CAFO operators keep labor to a bare minimum, automate feeding and watering, and concentrate as many animals in a building as possible. If it looks like a factory, and works exactly like a factory, then it probably should be regulated like a factory.

Myth: CAFOs are Farms, Not Factories


Among many assertions put forth by industrial animal producers is that CAFOs are farming enterprises rather than industries. In terms of scale, levels of pollution emitted, and production characteristics, it’s not too difficult to assert that CAFOs are in fact industrial entities and, as such, should be subject to industrial regulation of their air and water emissions and solid waste.

Despite countless exposés and well-publicized CAFO-related meat recalls, many people still associate animal production with nostalgic images of family farming. It’s no wonder. The industry invests considerable resources convincing the consuming public that all is wholesome and healthy down on the factory farm. Advertisements and brand imagery from meat, dairy, and egg industries show dairy cows grazing in pastures instead of mired knee-deep in mud and feces. Chickens appear in barnyard scenes diametrically opposed to the grim realities of 30,000 birds crammed in a broiler shed, or 130,000 hens in an egg-laying facility.

Lobbying Against Regulation The CAFO industry lobbies mightily to have this agricultural qualification codified into laws and regulations. If granted status as agricultural enterprises, CAFOs in the United States can obtain certain immunities from Clean Air Act, Clean Water Act, and Superfund regulations. If considered industrial enterprises, however, they are subject to industrial regulation of their pollution and required to pay the cleanup costs of their operations. For decades, the CAFO industry has worked to receive exemptions from noxious odors, greenhouse gas emissions, and solid waste discharges. They have also strategically favored placement and concentration of operations in states and counties where economic development is desperately needed and environmental regulations are easily manipulated.

Industrial-Scale Production In reality, CAFOs bear no resemblance to farms. By definition, a CAFO is a facility with 1,000 or more “animal units.”1 The scale of these massive factories makes them “production facilities” rather than farms. Smithfield’s subsidiary Murphy-Brown, currently the largest hog producer in the United States and the world, brings 17 million hogs to market each year and employs 6,000 people to run its operation. Pilgrim’s Pride, one of the biggest chicken producers, employs 48,000 people to process 45 million birds per week. Cal-Maine, the largest egg producer in the United States, sold 685 million dozen eggs in 2007 and keeps a flock of 23 million layers. Its empire includes 2 breeding facilities, 2 hatcheries, 16 feed mills, 29 shell egg production facilities, 19 pullet-growing facilities, and 28 processing/packing facilities. CAFO operators call their buildings “production facilities” and their animals “production units.” Gone are the days of pastures, barns, field crops, and farm animals.

Assembly Line Production The livestock sector is dominated by “vertically integrated” conglomerates that specialize tasks into distinct segments that are often spread out across different parts of the country: feed production in one factory; breeding in another; “finishing,” or fattening, in a separate facility; and processing or slaughtering in yet another. Hatcheries ship eggs and chicks across the continent; feed is shipped across the world. Farmers have become low-wage employees or “contract growers” that don’t even own their animals. Hogs, turkeys, and dairy cows are products of artificial insemination—a highly controlled process by which a human operator goes down the line to arouse and/or inseminate female animals. Much of the industry functions on this assembly line model—whether it’s female hogs being injected with semen, cows being milked by computerized machines, or cattle being systematically disassembled at the slaughterhouse. Instead of caring for sick or weak animals, CAFOs simply cull their vulnerable production units. The typical cull rate for dairy cattle in the United States is over 20 percent per year.2 As in any other industry, if a machine or production material is substandard, it is simply replaced.

Toxic Emissions Rather than operating on a closed-system model—in which farms grow their own feed, recycle their animals’ waste back into fertilizer, and act as responsible stewards of the land—CAFOs operate on an industrial model. Inputs come from off-site, and wastes are trucked back off-site. Livestock operations generate 75 percent of the ammonia emissions reported in the United States. Confined dairy cows, however, have been shown to generate five to ten times more ammonia than pasture-raised animals.3

Since the 1980s, U.S. farms have been required to report large emissions of ammonia and hydrogen sulfide from animal manure to the Environmental Protection Agency, and findings by the agency’s scientists confirm that the gases pose a genuine health threat. But the EPA does not impose limits on releases; it merely requires that farms disclose emissions over a certain level. In the final days of the Bush administration, the EPA further relaxed regulations on air emissions and reporting. If not overturned, these rule changes would exclude big animal-feeding operations from reporting ammonia emissions.

In 2008, Minnesota attorney general Lori Swanson filed a still unsettled suit against Excel Dairy, a CAFO with 1,500 dairy cattle in Thief River Falls, Minnesota, for air emission violations.4 Residents living nearby were evacuated from their homes because of extremely high hydrogen sulfide readings. Symptoms from such releases can include headache, nausea, vomiting, dizziness, diarrhea, coughing, and shortness of breath.

Does this sound like a healthy family farm or an industry with a toxic emission problem?

1. 1,000 “animal units” is the equivalent of 1,000 beef cattle, or 700 dairy cattle, or 2,500 hogs, or 10,000 sheep, or 55,000 turkeys, or 100,000 broilers or laying hens.
2. Susan S. Schiffman and C. M. Williams, “Science of Odor as a Potential Health Issue,” Journal of Environmental Quality 34 (2005): 129–138.
3. Doug Gurian-Sherman, CAFOs Uncovered: The Untold Costs of Confined Animal Feeding Operations (Cambridge, MA: Union of Concerned Scientists, April 2008), 54; C. B. Roller, A. Kosterev, and F. K. Tittel, “Low Cost, High Performance Spectroscopic Ammonia Sensor for Livestock Emissions Monitoring,” USDA Research, Education, and Economics Information System.
4. “Attorney General Lori Swanson and Minnesota Pollution Control Agency Jointly Sue Feedlot to Abate Public Nuisance and for Violations of Minnesota’s Environmental Protection Laws,” Office of Minnesota Attorney General Lori Swanson, press release, June 20, 2008.

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