Issue Brief

For millions of Costco shoppers, a $4.99 rotisserie chicken is more than dinner—it’s a cultural icon.

The Costco chicken is convenient and notoriously cheap, an automatic purchase for millions of Americans every time they visit the store. It’s also a key part of Costco’s brand identity: a symbol of quality, consistency, and member value. But few consumers know that Costco’s chicken brings high rates of salmonella contamination into its stores.

Costco’s Lincoln Premium Poultry (LPP) plant in Fremont, Nebraska, slaughters over 100 million chickens annually for two of Costco’s most popular products—rotisserie chicken and raw chicken breasts sold under the Kirkland Signature brand. But the plant consistently fails USDA salmonella safety standards year after year, sending contaminated chicken to Costco stores nationwide. The high level of salmonella contamination in Costco’s chickens is closely tied to overcrowded, poorly ventilated barns; birds bred to grow unnaturally fast, causing their legs to buckle under their own weight; and stressful transport and handling. This chronically poor animal welfare both weakens birds’ immune systems and provides a breeding ground for pathogens, increasing the spread of disease.

Farm Forward analyzed USDA salmonella regulations, inspection records, and humane handling reports to investigate the extent of salmonella contamination in the poultry industry, and any overlap between inhumane handling and higher rates of contamination. We found clear indicators of irresponsibility and disregard for consumer well-being, adding to a broader pattern of neglect across Costco’s poultry supply chain:

• Salmonella contamination: Costco repeatedly exceeds federal limits, sending unsafe chickens to stores nationwide—more than 1 in 10 whole birds and 1 in 6 packages of chicken breasts are contaminated.
• Humane handling violations: Genetically modified birds live in ammonia-filled, overcrowded barns, often collapse under their own weight, struggle to reach food and water, and are routinely deprived of both during transport, weakening their immune systems and underscoring the link between cruelty and disease spread.
• Established labor and environmental abuses: Workers endure unsafe conditions, contract growers face crushing debt and production pressure, and poultry waste pollutes local waterways, compounding risks to both human and animal health.

Costco’s persistent salmonella failures are not just a food safety problem—they reflect systemic failures in animal welfare, labor practices, and environmental stewardship. Until the company addresses how it raises animals for food, the true costs of those $4.99 rotisserie chickens will extend far beyond the checkout.

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Issue Brief

Top poultry brands are routinely violating salmonella standards, and USDA is letting them do it. USDA has found that companies like Perdue, Foster Farms, Cargill, Butterball, and Costco’s supplier (Lincoln Premium Poultry) have persistently high rates of salmonella contamination in products destined for grocery stores across the country, but USDA does nothing to prevent these contaminated products from reaching consumers. At the same time, certain companies with high rates of salmonella contamination have also violated humane handling guidelines—standards for treating animals with care during slaughter, including proper stunning and minimizing stress and suffering—exacerbating the risk of contamination even further.

With little explanation, the Trump administration shelved a recent proposal to strengthen USDA authority to stop the sale of contaminated poultry products. Meanwhile, contaminated poultry remains the leading cause of foodborne-illness-related deaths in America, with the CDC estimating that salmonella alone infects an estimated 1.28 million people per year, a full one-quarter of whom are infected by poultry. Farm Forward analyzed USDA salmonella regulations, inspection records, and humane handling reports to investigate the role of regulatory failures, industry practices, and lack of enforcement in enabling dangerous levels of salmonella contamination in the poultry supply chain. Our research led to three key findings:

1. USDA permits dangerous levels of salmonella and lacks the authority to enforce standards. The agency sets lenient contamination standards and cannot suspend slaughter or processing plants that consistently exceed them, nor can it recall or stop the sale of contaminated products, leading to contaminated chicken routinely reaching grocery store shelves. Over the past five years, the USDA has issued no criminal penalties, civil penalties, administrative penalties, or product withholdings due to excessive salmonella levels despite its own testing revealing the chronic failure of many plants to meet standards.
2. Top poultry brands have repeatedly failed salmonella contamination standards. Companies like Perdue, Foster Farms, Cargill, Butterball, and Costco’s supplier (Lincoln Premium Poultry) have repeatedly received the USDA’s worst rating (Category 3) for excessive salmonella contamination in certain products across multiple years. Despite this consistent noncompliance, these companies have faced no meaningful consequences.
3. Inhumane treatment of birds fuels higher rates of salmonella contamination. Many of the same companies that fail salmonella standards have also failed standards for humane handling of animals. Industry practices such as overcrowding, poor handling, and high-speed slaughter increase stress and illness in birds, directly contributing to the spread of foodborne illness.

Despite known risks and widespread contamination, USDA continues to allow contaminated poultry into the marketplace, failing to protect both public health and animal welfare.

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Salmonella bacteria are a leading cause of foodborne illness in the United States, resulting in 1.28 million illnesses and 238 deaths each year. At the heart of this ongoing public health crisis is the poultry industry, which accounts for at least a quarter of all salmonella infections. A recent investigation by Farm Forward sheds light on how this problem persists. By analyzing USDA salmonella regulations and inspection records, federal purchasing data for nutrition assistance programs, and humane handling reports, our findings reveal how regulatory failures, industry practices, and government procurement policies together undermine food safety.

Key Findings:

• USDA permits significant salmonella contamination levels in poultry: USDA’s Food Safety and Inspection Service (FSIS) sets standards for salmonella in poultry, allowing for high percentages of salmonella contamination in meat.
• FSIS lacks authority to enforce its salmonella standards: The agency cannot shut down plants for repeated contamination, stop contaminated products from entering the food supply, or issue recalls—even when plants repeatedly fail its standards for contamination.
• Major poultry companies sell contaminated products: Companies like Perdue, Foster Farms, Cargill, Butterball, and Costco’s supplier (Lincoln Premium Poultry) have repeatedly received the USDA’s worst rating (Category 3) for excessive salmonella contamination in certain products across multiple years without consequences.
• Meat from contaminated plants has likely been purchased for federal nutrition assistance programs like school lunches: USDA’s Agricultural Marketing Service’s (AMS) commodity procurement program has knowingly supplied poultry products from plants that have repeatedly failed salmonella standards to federal nutrition assistance programs, like the National School Lunch Program and the Emergency Food Assistance Program.
• Inhumane treatment of birds may contribute to higher salmonella risk: Birds raised in crowded, stressful conditions are more likely to shed bacteria. Some facilities with frequent humane handling violations also have Category 3 salmonella records.
• Regulatory reform efforts have stalled: FSIS proposed a rule in August 2024 to limit salmonella in raw poultry, but withdrew the proposal in May 2025.
• Inspection records lack transparency: Although inspection reports are public, the data is difficult to access and incorporate into purchasing decisions.

Despite clear risks to health and mortality, current regulations fail to protect the public. The federal government’s inability to enforce the standards it sets underscores a systemic failure to align food policy with public health and animal welfare standards. Against this backdrop, it’s no wonder that the poultry industry has consistently failed to adopt responsible practices to control salmonella.

To reverse this trend, the USDA must be empowered to enforce stronger standards, eliminate contaminated meat from public programs, ensure humane handling, hold poultry producers accountable, and improve transparency so the public can make informed choices about what they eat. Until these reforms are enacted, the poultry industry will continue to operate with minimal accountability—putting millions of Americans at unnecessary risk of illness from a preventable and dangerous pathogen.

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Farm Forward reported the results of its investigation into the welfare abuses of Alexandre Family Farm, a prominent California-based organic dairy operation that holds multiple certifications, including USDA Organic and Certified Humane® – just over a year ago. With extensive documentation, the investigation revealed widespread patterns of animal abuse, neglect, and consumer deception at what was publicly regarded as one of the nation’s leading “ethical” dairy producers. These abuses were not isolated incidents but represented systematic failures affecting more than a thousand animals over multiple years.

Farm Forward’s investigation’s impact was substantial and swift. Following publication, USDA’s National Organic Program finally launched an investigation that substantiated numerous allegations of abuse. The company faced multiple lawsuits, law enforcement investigated, and retailers terminated marketing campaigns, reduced product placements, or cancelled orders entirely. Although Alexandre had publicly maintained that many of Farm Forward’s accusations of wrongdoing were “totally false or fabricated half-truths,” we obtained through a Freedom of Information Act request the results of USDA’s investigation, in which Alexandre admitted to many of the allegations privately to regulators.

Our work exposing the abuses at Alexandre illuminates the legal and regulatory exceptionalism at work in animal agriculture, where actors at every level—federal and state organic agencies, local law enforcement, the state veterinarian, the commercial entities that sourced its products, and nonprofit welfare certifiers—privilege industry interests, fail to protect animals, and disempower the public from making more informed, humane purchasing decisions. The net effect of this exceptionalism is an extraordinary level of unchecked humanewashing, where consumers purchase products thinking they represent far better conditions for animals than they actually do. Beyond exposing conditions at a single operation, our investigation’s aftermath illuminates broader systemic failures across multiple oversight mechanisms designed to protect both animals and consumers. This case study demonstrates that animal agriculture operations can and do operate with an impunity that most consumers would find shocking, and a far cry from the level of accountability they would expect for any producer, let alone a USDA Organic, Certified Humane dairy.

This report documents how government regulators, independent certifiers, and “ethical” retailers all failed to monitor, prevent, or adequately respond to documented abuses. These findings reveal how current systems that consumers would expect to hold producers accountable to high standards instead function primarily for the marketing benefit of producers, humanewashing their practices—that is, providing false assurances of ethical treatment to consumers while masking widespread farmed animal suffering.

The report concludes by identifying critical reforms needed to prevent ongoing failures in animal welfare oversight, focusing on three key areas: reforms in government (establishing and enforcing clear, science-based standards, and separating regulatory and promotional mandates); independent certifiers (enforcing standards, eliminating conflicts of interest, and developing alternative models of certification); and retailers (increasing their responsibility for the accuracy of their marketing claims about the ethical standards of their suppliers through a combination of legal, regulatory, and consumer pressure). The conclusion also highlights the need to address perverse incentives in current organic standards and to prioritize transparency and consumer education. These proposed systemic changes are designed to move the industry toward greater accountability and better protection for animals, and to empower consumers with the information they need to make informed choices. While these reforms are actionable and practical, they will also require sustained, cross-sector collaboration.

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ISSUE BRIEF

Since the beginning of the current H5N1 outbreak in early 2022, the federal government has been bailing out meat and dairy companies for losses related to the virus. These bailouts come in the form of so-called “indemnity payments”—federal funds designed to compensate producers for the value of animals or animal products (e.g., milk) lost due to the epidemic. However, these payments aren’t just acts of emergency relief; they can function as subsidies that prop up a system of industrial animal agriculture, whose core practices are driving the same bird flu crisis these payments are intended to address.

Earlier this year, Farm Forward reported that USDA had made $1.25 billion in indemnity payments to the poultry industry to compensate producers for economic losses from bird deaths, including funds allocated for the “depopulation” (that is, culling) of infected birds (see Farm Forward’s report for an analysis of poultry indemnities). Now, Farm Forward presents new data, gathered through the Freedom of Information Act, that shows a similar pattern of harmful indemnities to farms raising dairy cows affected by bird flu. The extension of indemnity payments to dairy producers reveals how the federal government continues to fail in its bird flu response and prop up the industry’s reckless practices that threaten public health. The FOIA data1 obtained by Farm Forward reveals four key findings:

1. The large-scale dairies most responsible for endangering public health reap the most benefit from taxpayer bailouts.
2. USDA repeatedly bails out the same producers for ongoing outbreaks, with over forty percent of payments going to recipients who received multiple disbursements.
3. By making losses the financial responsibility of the taxpayer and requiring no changes in behavior from operators, the USDA payments incentivize producers to continue their risky practices that exacerbate the outbreak.
4. Federal agencies are neglecting the threat of bird flu and deliberately sidestepping common-sense solutions because of industry pressure.

In July 2024, USDA began to compensate dairy producers for losses associated with the virus.2 The Emergency Assistance for Livestock, Honey Bees, and Farm-Raised Fish Program (ELAP) is a federal program administered by USDA to compensate producers for losses in response to a range of events (e.g., disease outbreaks, adverse weather, or feed shortages) that impact livestock, honeybee colonies, and farm-raised fish. In response to the growing impact of bird flu on U.S. dairy herds, USDA expanded ELAP eligibility to include dairy producers affected by the virus. This move allowed dairies to access federal compensation for losses linked to infection, such as decreased milk production and the costs of testing and containment.3 The original intention of the ELAP program is a good one; it is reasonable to protect farmers from extreme weather and disasters outside of their control.

Bird flu, however, is not an act of God—it is often the direct result of routine practices in industrial animal farming operations, whose crowded, filthy, cramped conditions create and exacerbate disease outbreaks.4 Unlike a corn or soybean farmer, who can’t meaningfully change their farming practices in ways that would reduce the risk of future extreme weather events, animal farming operations can and should make changes to reduce future risk of pandemic diseases. Common sense policy for animal operations indemnity payments should be to a) encourage producers to test and report outbreaks, and b) create incentives for producers to change practices in ways that will reduce the spread of the disease (e.g., lowering animal density).

As of January 2025, USDA has distributed over $80 million through ELAP to assist dairy producers, including large-scale producers, in covering losses from H5N1-related milk production declines.5 Despite tens of millions in taxpayer bailouts for these dairy companies, there’s little sign that such operations or the animal farming industry as a whole are making progress to improve their farming practices in ways that would reduce the risk of the virus spreading.6

The bailouts from the ELAP program are just one part of the ongoing failure of both the Democratic and Republican parties to respond to the bird flu outbreak robustly. In April 2025, the FDA suspended its testing program for milk, which would improve bird flu testing and milk safety. The Trump administration also made sweeping cuts to an already limited staff responsible for testing, tracking, and controlling the virus;7 canceled plans for an H5N1 poultry vaccine;8 and cut funding for the development of a human H5N1 vaccine.9 Taken together, our findings highlight the repeated failures of the federal government to contain the H5N1 outbreak and protect public health.

1. The large-scale dairies most responsible for endangering public health reap the most benefit from taxpayer bailouts.

Our review of FOIA payment data indicated that large-scale dairies in major dairy-industry areas like Tulare County and Kings County in California (as well as Weld County in Colorado) received some of the largest payments, with many receiving nearly $1 million. While operations with more animals will have greater losses than a smaller operation with fewer, and therefore will have more losses and receive higher payments, this approach reflects the business-as-usual approach of subsidizing large-scale farms for externalities they themselves create and exacerbate. Many of these operations use large freestall barns, typified by high-confinement conditions with limited outdoor access, all of which require massive cesspools of manure, creating the perfect breeding grounds for disease.10

The top three individual payment recipients are all large-scale industrial dairies, confirmed through analyzing satellite imagery (see Appendix):

• Prado Dairy LLC (CO) – $1,545,189
• Williams Family Dairy LLC (CA) – $998,864
• Meadowvale Dairy LLC (IA) – $914,849

The size of these payments is notable not only because they represent large expenditures of taxpayer dollars to industrial producers but also because ELAP eligibility for milk losses states that “a person or legal entity with an AGI (as defined in 7 CFR Part 1400) that exceeds $900,000 will not be eligible to receive ELAP payments.”11 The payments that these companies received for milk losses exceed the maximum adjusted gross income allowed, suggesting that if, in fact, producers like these operate below the $900,000 threshold, they may have been compensated in total for more than they make in a given year.12

In California specifically, our analysis of FOIA records indicates that roughly three-fourths of payments went to large-scale dairy operations.13 This is reflective of the broader trend of federal subsidies, tax credits, and incentive programs primarily benefiting large-scale animal operations over smaller and more sustainable ones.14 It is precisely trends like these that compelled former representative Earl Blumenauer (D-OR) to propose the federal Food and Farm Act, which “would redirect billions of dollars away from subsidies for commodity farms towards programs that support small farmers, climate-friendly agriculture and increasing healthy food access [emphasis added].”15 And yet, despite efforts at reforms like this one, the federal government instead doubles down on subsidizing and incentivizing those industrial producers that do the most harm.

2. USDA repeatedly bails out the same producers for ongoing outbreaks, with over forty percent of payments going to recipients who received multiple disbursements. USDA has required no change in behavior and issued no penalties on dairies despite the repeated problems.

As is the case with payments to poultry companies that have had bird flu outbreaks and bailouts, many large-scale dairies have received multiple payments, which suggests they have received taxpayer dollars for repeat or ongoing outbreaks. Per our analysis of outlays to dairy companies, 43 percent of payments went to recipients who received multiple disbursements,16 some of which received as many as five separate payments from USDA in a six-month period. This included, but was not limited to, Meadowvale Dairy LLC, Wolf Creek Dairy LLC, Sierra View Dairy, 4K Dairy Family Partnership, and Parreira-Gaspar Dairy, which collectively received nearly $6 million in payments. This suggests a pattern: industrial dairies that received payments (that were very likely related to bird flu17) engage in practices that make losses either predictable or more probable and are the very operations that reap the most economic benefit from taxpayer dollars.18 We expect that these trends have continued into 2025.19

3. By making losses the financial responsibility of the taxpayer and requiring no changes in behavior from operators, the USDA payments continue to incentivize producers to continue their risky practices that exacerbate the outbreak.

Federal regulators have failed on multiple fronts to control the spread of bird flu, and the current system of USDA indemnities entrenches these failures.20 USDA compensation programs pay producers for disease losses, but fail to require the changes to farming practices that could reduce future disease risks.21 This allows these producers to privatize their profits but make their losses a public taxpayer responsibility, enabling the moral hazard associated with managing their herds irresponsibly in a way that encourages the risk of outbreaks. USDA indemnity allocation does not address the fundamental risks associated with disease spread, such as high-density housing of animals, unsanitary conditions, and speed of production that compromises the implementation of proper safety protocols.22 Although the CDC recommends that dairy and poultry workers wear personal protective equipment (PPE) when in contact with poultry and dairy cows,23 there is no mandate to do so in order to receive federal funds. Without meaningful biosecurity requirements attached to indemnity payments, producers are disincentivized to implement more responsible farming practices, increasing risk and endangering public health.

4. Federal agencies are neglecting the threat of bird flu and deliberately sidestepping common-sense solutions because of industry pressure.

Along with propping up a risky system with bailouts, the government is hampering the efforts that would effectively track and contain the virus. Since January 2025, crucial federal programs related to detecting and containing bird flu have seen major budget and staff cuts. Mass layoffs affected the already small staff responsible for responding to animal disease outbreaks at the USDA’s National Animal Health Laboratory Network,24 and top veterinarians in the FDA’s Center for Veterinary Medicine were fired.25 Testing of animals and humans is a cornerstone of effective disease response. However, federal policy related to testing and tracking means that the scale of the outbreak is unknown. In April 2025, the FDA suspended a major bird flu testing initiative for milk and cheese, severely limiting the ability of farmers, public health officials, and the public to know even basic details about the ongoing spread of the disease.26 Critically important testing for farmworkers in dairy and poultry operations has been severely limited, and farmworkers (who typically lack health insurance or paid sick leave) are disinclined to seek testing when they are ill, especially with the severe risks posed to many workers in the Trump Administration’s aggressive crackdown on immigration.27 Without adequate testing, tracking, and government resources allocated to disease management, the virus has been allowed to spread unchecked.

The federal government has put public health at further risk by hampering the development of vaccines for animals and humans that would be essential in containing the outbreak. Most recently, the Department of Human Services (HHS) terminated a more than $700 million grant to Moderna for the development of a human bird flu vaccine.28 After a refusal to pursue a poultry vaccine due to the potential impacts on the export market, USDA finally announced in June 2025 that it will consider a plan to explore the viability of such a vaccine; however, applications for federal grants dedicated to H5N1 poultry vaccines will not be awarded until fall of 2025, delaying their development and pushing out their distribution indefinitely.29  Similarly, early research on a vaccine for dairy cows has shown some promise, but “political headwinds” at the federal and state levels threaten their viability.30 Without vaccines, we lack essential weapons in the battle against the next human pandemic.

Conclusion

The combined failures of the federal government in responding to the H5N1 outbreak are only exacerbated by the current indemnification system. Ultimately, compensating losses due to disasters or illness is not intrinsically bad policy. However, continuing to subsidize a model of agriculture (i.e., industrial, high-confinement) that creates the conditions for disease outbreak, refusing to require meaningful disease containment measures (e.g., biosecurity, testing, vaccines), or leveraging taxpayer funds to incentivize safer, healthier farming practices amounts to reckless endangerment of public health paid for with taxpayer funds.

The dynamic that has emerged across the government’s response to bird flu is a troubling, though largely unsurprising, pattern: the industrial animal sector drives disease risk through intensive production, yet it also secures public funding to shield itself from the financial consequences of such production methods. There’s no silver bullet that will eliminate pandemic risk, but rethinking the way the current methods of farming intensify disease outbreaks—such as by attaching biosecurity requirements and better farming practices to bailouts, and leveraging risk-based insurance programs for indemnity payments—is essential for preventing the growing risk of a human H5N1 pandemic.

Methods

A spreadsheet was received from USDA detailing all payments made through the ELAP program in 2024. There were nearly 20,000 entries, most of which were records that were likely not related to bird flu. The dataset was limited in its specificity and clarity, so the entries were filtered to only payment recipients with “dairy” in the name and, therefore, were very likely to represent dairy companies. However, this means that there were almost certainly some payments that went to dairy companies that were not captured by our analysis. Further, per USDA, the dataset “may or may not be for reduced milk production as the data is not available in that format.” Although the nature of the available data makes it impossible to verify precisely which payments went to H5N1 indemnities, we do know that after USDA opened ELAP to bird flu compensations, payouts to dairy companies spiked by approximately 900 percent, indicating that substantial taxpayer funds have gone to bailouts for bird flu.

Appendix

Satellite Image of Prado Dairy LLC in Weld County, Colorado, the operation that received the most in a single payment: over $1,500,000 per the dataset received from USDA. Image courtesy of Google Maps.

Satellite Image of Williams Family Dairy LLC in Tulare County, California, an operation with many thousands of animals that received a nearly $1,000,000 in payment per the dataset received from USDA.

Satellite Image of Meadowvale Dairy LLC in Sioux County, Iowa, the recipient that received the most: over $1,800,000 in payments per the dataset received from USDA. Image courtesy of Google Maps.

According to the Centers for Disease Control and Prevention (CDC), antibiotic resistance is “one of the greatest global public health challenges of our time.”1 Globally, the number of deaths associated with antibiotic resistance is 4.95 million annually, with 1.27 million deaths directly attributed to resistant bacterial infections.2 By 2050, more than 10 million people could die worldwide each year from resistant infections.3

That the industrial animal sector is a primary cause of antibiotic resistance in both animals and humans is well-established.4 The industrial animal sector administers antibiotics not only to treat acute diseases, but also in low doses as prophylactics, which enable animals to survive unsanitary, high-density farming practices that breed disease.

This is not only a story of industry deception, false labeling, and USDA failures to substantiate labeling claims. It is also a story about the existential threat of antibiotic resistance driven by the overuse and misuse of antibiotics in animal agriculture and government-wide failure to respond to this issue.

Consumer demand for meat raised without antibiotics has steadily increased for decades and is projected to continue this rapid growth. In 2023, the global RWA meat market was valued at $18.75 billion; it is expected to grow into a $35.6 billion industry by 2032, with North America projected to continue holding the largest market share.5

Consumer surveys show that concern about antibiotic resistance and the unhealthy conditions under which animals are raised drives increasing demand for antibiotic-free meat,6 and consumers are willing to pay more for products that carry this label.7 Meat companies and grocery retailers profit from this demand. On average, RWA meat costs at least 20 percent more than conventional meat.8 The profits from charging a premium for RWA meat incentivize use of the RWA label regardless of whether meat is actually antibiotic-free.

So it should be no surprise that meat sold with RWA labels is not always antibiotic-free. Testing of RWA beef samples revealed that major beef companies and retail grocers are deceiving consumers by selling products under RWA labels that do, in fact, contain antibiotics.

Testing of RWA beef by Farm Forward, a research team from George Washington University, and eventually the USDA, found antibiotic residues in RWA beef. In 2020, Farm Forward commissioned testing of RWA beef sold at Whole Foods under their No Antibiotics Ever promise and found an antibiotic as well as other pharmaceutical drugs.9 In 2023, USDA conducted its own exploratory testing and detected antibiotics in 1 out of 5 samples tested (20 percent). The USDA testing revealed that the beef from Tyson, Cargill, and JBS, as well as more than a dozen beef companies supplying retailers like Whole Foods, contained antibiotics while consumers paid a premium for these products.

This testing revealed negligence not only by industry but by the government agencies responsible for truthful labeling and antibiotic oversight. The USDA—the agency tasked with verifying that food labels are truthful and accurate—has failed in its mandate to protect consumers, allowing beef producers to sell meat with antibiotics under RWA labels. More broadly, there is a government-wide failure to regulate antibiotics use by the Food and Drug Administration (FDA) and other agencies, which choose not to track and report on antibiotics use, or to institute enforceable guidelines for responsible antibiotics stewardship.

The good news is that the science is well-established and non-controversial, so the regulations that could dramatically reduce animal agriculture’s contributions to the antibiotic resistance crisis are clear. The question is whether the public will exert enough pressure to force corporations and government to adopt practices less perilous to human health.

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Tomorrow, May 13th, the Bureau of Labor Statistics will release an update on the Consumer Price Index for April. The data is expected to include an announcement about the retail price of eggs, which has been a focal point of national discussion about inflation, food, and tariffs. Even before the April figures were released, President Trump has claimed victory, saying that the price of eggs is falling and  “availability is fantastic.” 

But while retail prices are expected to fall in April compared to March, there are many reasons to believe that this trend represents only a seasonal cyclical decline — and that higher egg prices are here to stay unless federal agriculture regulators finally start getting serious about reforming our broken and unhealthy food systems.

This issue brief has two main findings:

1. Despite a recent dip, egg prices will likely remain high as long as federal regulators fail to respond to the ongoing bird flu pandemic; and

2. Evidence from Canada suggests that farm size and intensification contributes to pandemic risk.

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Trusted beef brands have been deceiving consumers by selling meat products under Raised Without Antibiotics (RWA) labels that are not antibiotic-free. Using documents obtained under the U.S. Freedom of Information Act, a Farm Forward investigation revealed that government regulators detected antibiotics in supposedly antibiotic-free beef, including meat sold by three of the four largest meatpacking firms that dominate the American beef market. With deceptive labeling, these three companies—Tyson, Cargill, and JBS—sold RWA products containing antibiotics at a higher cost to consumers than conventionally raised beef, while government regulators have taken no public or punitive actions to stop them.

Simply put, consumers are being scammed by Big Beef, and the United States Department of Agriculture (USDA) is knowingly letting them get away with it.

USDA testing revealed that antibiotic residue was widespread in RWA beef, but USDA did not release the names of offending companies. This investigation uncovered how the meat industry’s largest and most trusted brands drove this deception of consumers and how USDA’s failure to regulate RWA labeling has made it impossible even now for consumers to make conscientious purchasing decisions.

This brief outlines two key findings:

1. Three of the beef industry’s four largest companies deceived the public about claims that their beef is free of antibiotics, and some have continued to mark products RWA even after receiving USDA’s notice that their products contained antibiotics.

2. USDA has deliberately maintained labeling policies that allow meat companies to mislead consumers.

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The rapid spread of highly pathogenic avian flu (HPAI) H5N1 through our agriculture system presents a deep threat to our food supply and a growing risk that the virus will mutate to become the next dangerous human pandemic. Sadly, the U.S. federal government response has not only been insufficient, but has actually worked to encourage the dangerous corporate practices driving this risk. Longtime close ties between federal agricultural regulators and the industry they are supposed to regulate has resulted in taxpayers actually footing the bill for programs that profit the industrial animal sector while making a human H5N1 pandemic more likely.

As of February 27, 2025, there have been 70 confirmed cases of the virus in humans in the U.S., causing one human death. While the virus has not yet been documented to spread between humans, researchers found that the H5N1 variant in dairy herds required only one mutation to spread more easily in humans. Given that H5N1 mutates rapidly, like other forms of influenza, scientists and public health officials are particularly concerned to know that we are just one mutation away from a potentially deadly human pandemic. The World Health Organization reports that, since 2003, 48.6 percent of global H5N1 cases in humans have been fatal.

Farm Forward’s review of current policies and data reveal six essential flaws with USDA’s response to the pandemic at poultry farms:

• USDA compensation payments to poultry farms with infected birds increase pandemic risk.
• USDA compensates repeat offenders.
• Current audits of safety measures are meaningless.
• Huge loopholes in safety requirements allow many farms to take no measures at all.
• Information blackout from the new administration leaves public health officials in the dark.
• Vaccine requirements lag far behind many other countries.

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Executive Summary

One of the most sophisticated greenwashing and corporate welfare schemes ever designed, “manure biogas,” is providing Big Ag cover to use public dollars to fund an expansion of factory farms in the Midwest. The first thing to know about “biogas” is that the term itself is misleading. “Biogas,” also sometimes called “renewable natural gas” or “RNG,” refers to the use of methane digesters (also known as anaerobic digesters) to capture gas emanating from the cesspools of waste that concentrate on factory farms. These digesters process some portion of the waste from factory-farmed animals into fuel while also producing a polluting byproduct called digestate. “Manure biogas” is more accurately described as factory farm gas, or FFG for short.

Industry has touted its use of FFG as a climate solution, but an investigation by Farm Forward released in parallel with this one documents that FFG functions as a net negative by incentivizing the expansion of factory farming and entrenching current factory farms and their worst practices. This Farm Forward report demonstrates how Big Ag is effectively bringing its waste problem to the Midwest by confusing legislators and the public with lofty talk of “biogas” or, as it is alternatively branded, “renewable natural gas” or “RNG.”

With industrial dairy at the helm, a coalition of utility and fossil fuel companies are making plans to entrench and expand factory farming’s most destructive practices: mass confinement of animals and manure cesspools. At the center of this plan is FFG, which industry plans to promote by a combination of deregulating digesters and manipulating clean fuel standards. Industry has already introduced legislation in Michigan to deregulate anaerobic digesters and their waste byproducts, and to establish a new “clean fuels standard,” a credit trading scheme for polluters.

Michiganders are increasingly waking up to the industry’s plans, and concerned citizens are resisting and opposing the growth of CAFOs in their states.1 However, industry misinformation has led to considerable confusion about FFG, even among policymakers and some environmentalists. This report demonstrates that FFG is a clear case of egregious greenwashing. FFG threatens a massive misappropriation of public funds to expand a polluting industry deeper into America’s heartland.

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Executive Summary

“Manure Biogas” (also known as factory-farmed gas, or FFG) is rapidly expanding, and industry has structured it to produce a reverse Robin Hood effect: the increasing subsidies for FFG are supposed to incentivize green practices but instead fund greenwashing that promotes the growth and entrenchment of the largest factory farms at the expense of the surrounding communities, the climate, and public health.

“Biogas” is how Big Ag refers to the use of methane digesters—large sealed tanks with no oxygen—to capture gas emanating from the cesspools of waste that concentrate on factory farms. These costly and inefficient digesters process some portion of the waste from factory-farmed animals into fuel while also producing a polluting byproduct called digestate. “Biogas” is more accurately described as factory farm gas or FFG for short.

FFG functions to pump billions of dollars into propping up industrial animal production. In places where data is available like Wisconsin and Iowa, FFG growth has meant the growth of factory farms. In 2023, federal subsidies for biogas began rapidly expanding and exceeded $150 million. In one federal grant program alone, there was an over 2,600 percent year-over-year increase in federal grants for biogas. These public funds have attracted private investments that further exacerbate the problem.

Farm Forward’s analysis reveals that these subsidies flow almost exclusively to factory farm interests and disproportionately to the biggest, most destructive farms—rewarding the ones that do the most environmental damage. In addition to grants, low-interest loans, tax deductions, and other free monies from public coffers, the justification of FFG involves a blatant overvaluation of environmental credits. Despite these obvious problems being flagged by 15 members of the U.S. Senate and House,1 the federal government has doubled down on support for FFG.

Greenwashing gas from factory farms is not a climate solution. It’s climate gaslighting. The real solutions to the problems of factory farming are well known: reducing our overall dependence on animal products and raising the remaining animals on farms that combine the best of traditional and modern models to reduce the many public health and environmental costs of large-scale animal agriculture.

Read the full report

See our parallel report, “The ‘Biogas’ Plot: Fueling Factory Farms in the Midwest.”

Executive Summary

This report details the results of a consumer fraud investigation conducted by Farm Forward, with the help of rancher whistleblowers, that uncovered systemic deception, cruelty, and animal abuse by arguably the leading higher welfare, Organic, Certified Humane, and “regenerative” dairy operation: Alexandre Family Farm, LLC. Our own eyewitness experiences in investigating this report, coupled with extensive documentation—including video footage, photographic evidence, ownership documents, a veterinary evaluation from a large animal veterinarian who works in the dairy industry, and a review by leading animal welfare scientist Gail Hanson, DVM—together provide damning evidence that Alexandre, in contrast to their public claims and certifications, practices a business model that ensures that cows routinely suffer egregiously and that diseased animals are sold into the human food supply chain. Given Alexandre’s leading reputation in the industry, Alexandre’s failures suggest that decades of industrialization make it nearly impossible for modern dairies to produce their products in line with public expectations.

The enormous scale of preventable animal disease and suffering documented at Alexandre reveal loopholes in its certifications that function to deceive consumers, so-called humanewashing. Perversely, Organic certifications frequently function to incentivize farmers to withhold needed medical treatment from diseased animals and, polling shows,1 aid in humanewashing by giving the public the false sense that these certification standards align with their values. Many manufacturers that incorporate Alexandre’s dairy into their own products—including toddler formula—highlight Alexandre’s welfare claims to increase their own sales, expanding the humanewashing (and such products may not identify Alexandre by name and so are hard for consumers to avoid).

One of the most dramatic findings of our investigation is that in more than a hundred videos and photos Farm Forward has documented dozens of cases of serious violations of even the relatively weak Organic, Certified Humane, and other certifications that Alexandre touts in its advertising, yet Alexandre retains those certifications.

Structural conditions in the dairy industry, and particularly in Organic certification programs, may make socially unacceptable forms of animal suffering— like failure to adequately treat obvious injuries and illnesses—the rule rather than the exception. Given that these welfare problems are occurring in “best of the best” operations that, as of the release of this report, remain in good standing with their certifications, it is our recommendation that for the foreseeable future, consumers who wish to avoid animal cruelty steer clear of products made from cows’ milk.

Introduction

The Historical Moment

When the country’s most diverse, lactose-intolerant, and environmentally conscious generation, Gen Z, turned its back on cows’ milk, it put industrial dairy’s back up against a wall. Americans’ annual cow milk consumption had already fallen by two-thirds between 1945 and 2022, from 45 gallons per person to 15.2 Members of Gen Z drink even less than the rest of the public, in 2022 buying 20 percent less cows’ milk than the national average.3 “We lost almost an entire generation of milk drinkers,” noted U.S. Representative Glenn Thompson (R-PA), leader of the House Committee on Agriculture.4 Meanwhile, in 2022 just over 40 percent of U.S. households purchased plant milks5 like oat, soy, and almond, which occupy ever-increasing footage of grocery store shelves: their global revenue of $15 billion in 2015 is expected to grow to more than $35 billion by the end of 2028.6

The Labels

As the dairy industry tries to convince Gen Z that it offers a humane, desirable, relevant, and climate-friendly product, dairies apply appealing labels to milk cartons: “pasture-raised,” “grass-fed,” “eco-friendly,” even “carbon neutral,” and the recently introduced “regenerative.” Most of these labels are meant to convey in part—as phrased by Alexandre Family Farms, LLC (Alexandre)—“These are some happy grass grazed cows,”7 “I am one happy cow,”8 and “Life on our pastures is a happy one!”9 But how can consumers know that these marketing labels and statements fairly represent the actual conditions on the farm, and aren’t simply more humanewashing?10

The Certifications

Enter third-party certifications like “Certified Humane by Humane Farm Animal Care,” to persuade consumers that on-farm conditions are as humane and environmentally sound as the labels purport. And it’s working, at least for the dairies. Alexandre’s customers likely believe that they are supporting “happy cows.”11 Well-intentioned consumers buy into both the label claims and certifications, paying a hefty premium for cows’ milk from the dairies that sell to “ethical” retailers like Whole Foods Market, which markets their partnership with Alexandre as “Restarting Dairy.”12 Alexandre boasts a number of premium animal welfare certifications and was named a Whole Foods Market Supplier of the Year in 2021.13 But given the evidence that we uncovered, Alexandre’s welfare claims appear designed to deceive.

The Animal Welfare Violations

In more than 15 years of advocacy Farm Forward has seen the worst of the worst on factory farms. Yet our own eyewitness experiences combined with the videos, photographs, and research the rancher whistleblowers provided to us documenting Alexandre’s practices shocked even us.

Dozens of videos and photos depict Alexandre’s numerous indefensible animal welfare violations. Far from indicating isolated incidents, or physical abuse of a few cows by “a few bad apples” among Alexandre staff, the footage points to routine management practices, driven from the top, that lead to systemic, egregious suffering. In addition to what the videos depict, whistleblowers working with and around Alexandre provided photographic evidence of more than a dozen calves who were kept isolated from their mothers and died; whistleblowers also described serious lapses in management that resulted in, for example, the extreme suffering of hundreds of cows and the violent deaths of dozens of cows.

The Report

The report’s first section, “Animal Abuse at Alexandre,” documents the condition of cattle videoed, photographed and/or witnessed by the whistleblowers or by Farm Forward staff, as well an assessment of video evidence from a large farmed animal veterinarian specializing in dairy. Their evaluations, along with an independent evaluation by farmed animal welfare expert Gail Hansen, DVM, all point to dismal welfare conditions at Alexandre.

The report’s second section, “Animal Welfare Certifications Failed to Prevent Suffering,” demonstrates that the certifications supposedly verifying Alexandre’s welfare practices—USDA Organic, Certified Humane by Humane Farm Animal Care, and Regenerative Organic Certified—did not prevent, or apparently even detect, the abuses at Alexandre. In fact, documentary evidence indicates that the Organic program and Organic certifiers were notified of abuses and potential violations of Organic standards and yet the issues persisted. Sadly, when combined with the market pressures in the dairy industry, a requirement of the Organic program—the prohibition of the use of antibiotic treatment of animals marketed with the label—may have perpetuated and even worsened systemic animal suffering at Alexandre.

Third, in “Ripples of Humanewashing,” this report shows that Alexandre’s claims of ethical production expand through the market through food manufacturers who purchase its dairy products, including a company producing toddler formula. These “ethical dairy” companies spread Alexandre’s deception far beyond the products that Alexandre sells directly to consumers.

When the certifications with the highest animal welfare standards don’t prevent appalling animal suffering even at the leading higher welfare regenerative dairy, we are left to wonder what is happening at other big dairies, and whether higher welfare dairy is possible for today’s grocery markets. Given current market dynamics, big dairy may be a welfare problem that cannot be solved.

Widening the focus from just Alexandre, the appendix “Structural Suffering” explores how the organizational structure of large scale organic and conventional dairies depresses animal welfare and leads to the staggeringly high annual death rate for cows used for dairy, and suggests directions for future research.

Read the report

Introduction

This report provides an analysis of the opportunities for alignment between the Regenerative Agriculture (RA) movement and the Farmed Animal Protection movement (FAPM). Farm Forward was commissioned to create this report by a client in the funding community. It has been condensed and edited for a larger, but still targeted, audience: funders and advocates who work, or who are interested in working, at the intersection of farmed animal protection and regenerative agriculture. In particular, our imagined reader is someone who already shares certain values with the FAPM—a concern for the suffering of farmed animals, for example—but is unfamiliar with the history, politics, structures, and ideologies that have driven farmed animal protection work in certain directions. We hope this report will facilitate greater investment and participation in farmed animal protection work— and in strategies that involve the RA movement—by helping interested parties identify entry-points for engagement with advocacy groups.

This project was conducted over several months and was motivated by our client’s interest in understanding:

• The broad landscape of the RA movement.
• How RA actors incorporate farmed animal welfare into their models or understand farmed animal welfare as central to their missions.
• Barriers to scaling RA.
• Opportunities for scaling RA.

We limited the scope of our research to activities taking place in the US. Our methodology included conducting interviews with people working within the RA space, consulting scientific and expert research, and referring to publicly available 990s and nonprofit websites. We also draw upon the direct experience of our team.

Farm Forward is a mission-driven nonprofit advocacy organization that both conducts direct advocacy campaigns against factory farming and provides strategic consultation to advocacy groups, funders, and businesses around farmed animal protection issues. We do not claim to be disinterested parties— rather, a strength we bring to this project is our team’s deep experience as FAPM insiders, including the relationships, insights and intuitions won over years of direct engagement with farmers, companies, and advocacy groups. We also assume certain values on the part of our reader: that the welfare and well-being of farmed animals matters, and that advocacy work which centers farmed animals merits more robust funding and support.

This report is not meant to provide a comprehensive or definitive description of all RA activities. It has focused, instead, on answering certain questions that are of especial interest to our client, whose central aim is to advance farmed animal welfare. Because we conducted this project with the assumption of certain shared values with our reader, we were able to leave out some more granular analysis and data that would be expected in a report claiming academic objectivity.

We have attempted to be transparent when we are expressing Farm Forward’s informed opinions as well as observations based on our own experience rather than outside research or interviews (usually through footnotes). We have also attempted to provide data that is accurate and included citations so that readers can conduct their own research.

One thing to note is that we conducted most of this research prior to the global outbreak of COVID-19, which has dramatically altered the economic landscape in which regenerative agriculture operates. Economic and political decisions being made now and in the near future will play an important role in determining which models of agriculture grow or shrink in the US, and we may face a different regulatory climate for agriculture in the US than we have in the past. While we have incorporated new data into this report wherever possible, we cannot predict the state of regenerative agriculture in the years to come, and we think it is highly worthwhile to revisit many of the questions in this report again in the future to see how their answers may have changed in post COVID-19 America.