Five burning questions on Prop 12 complianceFive burning questions on Prop 12 compliance
Pork producers making significant adjustments to manage space effectively, provide proper care for sows.
Since California’s Proposition 12 went into full effect on Jan. 1, Cloverleaf Animal Welfare Systems has been assisting pork producers in achieving certification. As the first accredited certifying agent by the California Department of Food and Agriculture, Cloverleaf has collaborated with numerous producers and distributors to achieve certification and disseminate information about the certification process.
One area of confusion is whether gilts and sows can be housed at different densities in enclosures due to their relative sizes. “We all know that a gilt is usually smaller than an older parity sow, and so physically, they take up less space than an older sow,” says Jamee Eggers, chief operating officer for Cloverleaf Animal Welfare Systems. “It is important to understand the definitions of production cycle, breeding pig, and production cycle in the regulations. The 24 square feet requirement applies to every female pig that is six months of age and older and confined to be bred or is bred. It doesn’t matter if the gilts are physically smaller; they still need 24 square feet. That calculation is not based on their size but on the size of the enclosure they are in.”
Another area of confusion concerns the amount of time a breeding pig can be in a non-compliant enclosure. The regulations are very clear about when animals can be in a non-compliant enclosure and the documentation required for those times.
There has also been considerable confusion regarding the regulations of other countries and certification programs and their applicability to Prop 12. “The easiest way to understand this is that there are zero, absolutely zero equivalencies to Proposition 12,” Eggers says. “From the EU standards to the Canadian Code of Practice for pigs, which allow for a certain percentage of sows to be in gestation stalls while the other percentage must be in open pen gestation, to any other verification label program that doesn’t allow for gestation stalls—none of these are equivalent. These producers must still be inspected and certified for California Proposition 12.”
The most common non-conformance noted by auditors is a lack of complete documentation. The regulations define the documentation that needs to be kept for the times breeding pigs are in non-compliant enclosures. Farms have had to start recording the date sows are loaded into farrowing stalls to verify compliance, ensuring they aren’t placed in farrowing stalls more than five days before their expected farrowing date, among other documentation for compliance.
Beyond adjusting to the record-keeping requirements for certification, the biggest challenge for Prop 12 compliant farms is utilizing space effectively. “What do you do with returns? What do you do with opens?” Eggers says. “Managing these situations can be challenging for farms. They are really trying to figure out the best ways to handle these issues. Additionally, they are working through the challenge of remixing sows that have fallen out of their group due to an injury or being found open.
"We knew this even before Prop 12, when we started exploring group housing. The challenge is determining the best time to mix sows and how to mix sows post-weaning to minimize aggression and fighting. This is a challenge in open pen gestation farms, regardless of Prop 12.”
Eggers notes pork producers are working hard to find solutions for their farms, providing good care for the sows, and staying compliant with Prop 12 regulations.
In addition to questions from producers about the certification process, Cloverleaf is also receiving inquiries about other areas along the supply chain and the Prop 12 inspection process:
Is there a time limit for how long an animal can be in less than 24 square feet during individual treatment under a veterinary exemption? Eggers says the short answer is no. There is no time limit written into the regulations. “However, there are several considerations for maintaining compliance with a veterinary exemption. For example, is the sow being rechecked periodically? Does the treatment protocol include a timeframe for the conclusion of treatment and the sow’s return to compliant housing? Does she have a space to return to compliant housing? The veterinary exemption cannot be used to place nearly everything in stalls and then backfill that pen with Prop 12 sows.”
What documentation is required for farms to show that breeding sows have not been restricted for more than six hours in 24 hours and no more than 24 hours in a 30-day period? Eggers says this is a lot of time tracking. It comes down to a record-keeping system that works for the farm and clearly and consistently demonstrates compliance.
Are packers audited, or is it only producers? The answer is sometimes. “If you refer to the regulatory framework, you have the farm that’s audited and then the distributor. Packers participate in the audit trail by requiring or providing some of the information between the distributor and the farm,” Eggers says. “Sometimes, packers are distributors, so they go through a distributor inspection. It depends on what kind of activities the packer is doing and how they fit into the regulatory framework.”
How does a packer or processor know if a producer has passed an audit? That’s based on the certificate, Eggers says. That is what is provided to the packer to know that a farm has passed an audit.
Are packers required to verify or check any documentation before animals are unloaded at the facility? “The answer to that question is 100% based on the packers’ policies and procedures for receiving Prop 12 certified pigs,” Eggers says. “Some packers are segregating certain days for harvesting Prop 12 pigs. Some might harvest Prop 12 pigs every day but only assign certain dock times to Prop 12 pigs. A good majority of them are giving a different tattoo code to Prop 12 pigs versus non-Prop 12 pigs. But it’s all completely dependent on the packers’ SOP and their procedures for harvesting Prop 12 product.”
About the Author
You May Also Like