Within the first 72 hours, farmers start depopulating, an industry term for killing contaminated flocks.

Despite the sweltering heat inside the barns, hired workers wear gloves, face masks and other protective equipment and repetitively pick up flailing, sick chickens and place them into a metal container filled with carbon dioxide. In a few minutes, the chickens are dead.

In other cases, workers seal the barn doors and crank up the temperature, causing the birds to die from heat stroke, or flood the barn with a suffocating foam. In a few hours, most of the chickens are dead and workers begin to haul thousands, if not millions, of lifeless caracasses out to dump trucks.

The stench of death seeps into workers’ clothes, sweat and even the water they’re supposed to shower in.

This is the business of killing chickens during the ongoing bird flu epidemic. And business is booming.

As the virus spreads and drives up grocery prices by shrinking the nation’s supply of eggs and meat, bird disposal companies, environmental waste businesses and large poultry producers have received millions of federal dollars to kill flocks, compost their bodies and clean barns across the country.

However, the scale and urgency of these recent depopulation events have left room for worker protections to fall through the cracks, Investigate Midwest has found.

A review of thousands of pages of state depopulation inspection records and conversations with dozens of people who work behind the scenes has revealed:

  • Underage workers, in some cases, have been hired to kill poultry flocks, handle dead carcasses and clean industrial poultry farms.
  • Workers sometimes lack personal protective equipment or receive damaged gear, despite the risk of the virus jumping from animals to people.
  • Dealing with a federal backlog, some farms have used killing methods considered inhumane because it can be quicker and cheaper.

“The biggest factor in agricultural safety is the urgency,” said Bethany Alcauter, director of research and public health for the National Center for Farmworker Health, a Texas-based nonprofit that advocates for worker safety and health. “Everything has to get done in a short amount of time and that really can be problematic because there’s not the same amount of time to adequately train workers.”

The current bird flu outbreak is also the first time in the nation’s history that the U.S. Department of Agriculture has put a single federal contractor in charge of responding to outbreaks when a business or state agriculture department can’t handle a farm’s depopulation request.

In the past, the USDA would train emergency response contractors across the country to deal with outbreaks in their state and region.

This practice changed with the most recent outbreak when the USDA awarded a contract to Patriot Environmental Services to be the single provider of federal depopulation services.

The use of a single federal contractor has caused delays when a farm requests assistance from the federal government to depopulate a flock, according to depopulation consultants, veterinarians and state agriculture agencies interviewed.

An excerpt of an email exchange between reporter John McCracken and CDPHE spokesperson David Ellenberger regarding the results of a CDPHE farmworker survey.

No Interpreters. No PPE. Just Blood Stains and Feathers.

In July 2024, hundreds of workers descended on two poultry farms in rural Colorado, an hour northeast of Denver, to kill over 3 million egg-laying chickens.

Two of the state’s largest egg companies had tested positive for bird flu and their flocks needed to be destroyed.

Officials with the Colorado Department of Public Health and Environment (CDPHE), the USDA and the Centers for Disease Control were onsite at both outbreaks to monitor for symptoms of human exposure to the virus and to spot behavioral health concerns — that is, the psychological impact of performing high-volume animal killings in hazardous, often distressing conditions.

CDPHE forms obtained by Investigate Midwest through public records requests show agency workers interviewing primarily Spanish-speaking workers. A behavioral health worker wrote in a daily report that USDA staff approached farm management and asked if they could meet with full-time farm employees to discuss working conditions, to which management said “absolutely not.”

“They did not have the ability to go to the workers with us and did not have anyone who could be an interpreter for us,” the behavioral health worker wrote in a report, referring to USDA employees onsite.

A separate behavioral health official wrote that they witnessed workers with torn or missing PPE, PPE not being utilized, and saw “animal matter, including blood stains and feathers” on workers’ torn PPE.

The same behavioral health official noted that culling and disposal workers were required to shower at the entrance and exit of the barn, but workers said several people were not showering because the “water has a dead chicken smell” and “the horrible smell stays on the skin.”

One of the July 2024 outbreaks was at an Opal Foods commercial egg facility in Roggen, Colorado, where 1.8 million egg-laying hens were killed. Opal is a private company headquartered in Neosho, Missouri, and partially owned by Indiana-based Rose Acre Farms, the nation’s second-largest egg production company.

Opal Foods has received $24 million in payments from the USDA to cover the cost of the lost flocks since 2022, a federal response known as “indemnity payments.”

The other outbreak occurred at Morning Fresh Farms, half an hour away in Platteville, Colorado, where 1.2 million egg-laying chickens were killed. Morning Fresh is a subsidiary of Versova Holding, the nation’s fifth-largest egg-production company, which employs more than 2,000 people and purchased Morning Fresh in 2023.

Morning Fresh received nearly $7 million in indemnity payments in 2022 and 2023, but federal data does not list them, or their parent company as a recipient of funds in 2024.

Depopulation workers on both farms spent hours each day picking up chickens, putting them in metal rolling carts and filling the carts with carbon dioxide.

This process subdues and kills the birds in a few minutes but poses a danger to workers because of the repeated exposure chicken handlers have to sick birds, according to the American Veterinary Medical Association, a nonprofit that set guidelines for depopulation methods with the USDA in 2019.

chart visualization

Underage Labor Flagged During Bird Flu Response in Colorado

Colorado Department of Public Health and Environment employees surveyed contract workers at both Colorado facilities to monitor for symptoms of bird flu and in a subsequent report, the Centers for Diseases Control showed workers self-identifying as young as 15.

The Colorado Youth Employment Opportunity Act prevents workers under 18 from performing hazardous work such as euthanasia and disposal of animal carcasses unless performed in certain programs, such as student-learning initiatives, agricultural education opportunities like 4-H, and work apprenticeship training, according to a department spokesperson.

The Colorado health agency confirmed with Investigate Midwest that workers under the age of 18 were present based on self-reported answers to survey questions and conversations with farm staff. The department did not provide the specific ages of workers, citing state privacy records laws.

Investigate Midwest also received records through the Freedom of Information Act for Occupational Health and Safety Administration, or OSHA, inspections done at both facilities in July and August 2024.

The records included the names of four contract labor companies interviewed by OSHA, two of which matched company names provided by the Colorado Department of Public Health.

All four contract labor companies denied using employees under the age of 18.

Aaron Garcia, owner of Atlas Labor and Staffing Solutions, which was hired during the Colorado outbreak, said his company and other contractors were working at both egg farms around the same time, given their proximity to each other and similar outbreak timeframes.

Garcia said he has heard of agriculture contract companies hiring underage workers throughout the bird flu epidemic, but his company has not done so.

He said his company, based in Iowa, was paid to provide laborers who cleaned and disinfected barns and provide laundry services for workers’ uniforms. For a few days, his crew picked up dead birds and placed them in disposal trucks. He said all of his workers’ ages were verified through federal E-Verify services.

“It’s illegal, in the first place, and it does affect the reputation of the guys that are actually trying to do it right and follow the laws,” he said.

Brian Mouw, a manager with D&H Poultry Services based in Sibley, Iowa, who was contracted to work at Opal Foods during the July 2024 outbreak, said all of their employees’ ages are verified before being hired.

“The other 200-275 people were with three other contractors hired by Opal, it could’ve been them,” he said in an email to Investigate Midwest. “They didn’t work under us.”

Khali Depardo, chief operating officer at 5280 Staffing, a Colorado-based staffing agency listed on OSHA documents as a contractor for Morning Fresh Farms, said his company “does not hire anyone under the age of 18, at any time.”

A spokesperson for Express Employment Professionals, an Oklahoma-based staffing agency also listed as a contractor in OSHA documents, said its Greeley, Colorado, office does contract work with Morning Fresh Farms but was not contracted to provide labor related to bird flu depopulation.

“Express Employment Professionals of Greeley, CO., has not employed individuals under 18 years old at Morning Fresh Farms,” the staffing agency spokesperson said in an email.

Investigate Midwest provided its findings of potential underage workers and their tasks to the Colorado Department of Labor and Employment. An agency spokesperson said it was unaware of any underage labor working on commercial egg farms.

“Without a full investigation, we are unable to definitively determine whether the work at issue was ‘hazardous’ under Colorado law, and if so was otherwise permissible, and we cannot opine on federal law as that is outside of our authority,” the spokesperson said.

Workers clean a truck at the site of Minnesota poultry depopulation event in 2015. photo provided by Dan Hougentogler

Asked about the Colorado case, a U.S. Department of Labor spokesperson said it “is not clear” whether the specific case violates federal laws.

Federal child labor regulations prohibit workers under the age of 16 from conducting certain hazardous tasks while working on farms, such as working with pesticides and chemicals, but makes no mention of the gases and tactics used to kill poultry during depopulation.

The commercial egg companies behind culling events in July of 2024 denied the use of child labor as well as the hiring of contractors who used child labor.

“Morning Fresh Farms holds the highest standards for ensuring all employees are eligible to work,” a company spokesperson said in a statement provided to Investigate Midwest. “Our company has no awareness of any underage labor issues by contracting companies working on our farm during our response to highly pathogenic avian influenza.”

Versova Holdings, parent company to Morning Fresh Farms, did not respond to repeated requests for comment.

“Opal Foods, LLC is a separate, independent company in which Rose Acre Farms has partial ownership,” said a spokesperson for Rose Acre Farms, parent company of Opal Foods. “We do not know all the details nor can we speak to Opal Foods’ internal operations, but Rose Acre Farms is not aware of any instances of underage hiring at Opal Foods, LLC. You should however direct your questions regarding this issue to Opal Foods.”

Opal Foods did not respond to repeated requests for comment.

The USDA’s One-Contractor System. Efficient or Overloaded?

Over 168 million birds have been depopulated in the U.S. since early 2022, the majority of which have been at commercial operations. When a flock is killed, the USDA can compensate producers for the loss of revenue and the cost to depopulate.

Currently, operators are paid a flat fee for depopulation and disposal fees, regardless of whether the farm handles the killing on their own or hires a contractor. Producers are reimbursed $1.62 per bird for egg-laying chickens, $2.95 per meat chickens, $4.50 for turkeys and just over $5 per duck, as of February 2025, according to USDA documents.

When a farm doesn’t have the resources or money to kill a flock on its own, the state’s agriculture department is contacted. If the state does not have access to equipment or labor, a USDA-approved contract company steps in and kills the birds.

Patriot Environmental Services is the nation’s only federal contractor able to provide depopulation services when requested by the USDA.

The company is a subsidiary of the national environmental cleanup company Crystal-Clean and is headquartered in Los Angeles, California, with 18 locations across the country.

Parent company Crystal-Clean works with oil spills and waste management and is owned by the private equity firm J.F. Lehman & Company. Crystal-Clean was fined $1.1 million in 2023 by the U.S. Department of Justice and the U.S. Environmental Protection Agency for failure to have proper permitting and handling of hazardous waste materials.

chart visualization

Patriot Environmental Services has received more than $18 million in USDA poultry depopulation contracts since the beginning of the most recent outbreak, a figure that accounts for nearly a quarter of all depopulation contracts, technical assistance payments, research and grant funding related to bird flu funded by the federal government.

This money has been paid to private companies, state agencies, universities and research groups related to poultry depopulation.

Federal contracts and grants related to poultry depopulation during the ongoing outbreak have exceeded the total amount spent during the 2014 to 2015 outbreak of bird flu, from $68 million to $73 million and counting.

Workers at a depopulation site in Maryland manage biosecurity by decontaminating incoming and outgoing vehicles and equipment. photo provided by Dan Hougentogler

In some states, poultry producers receive technical training from the state department of agriculture on proper depopulation methods and previously, the USDA would train emergency response companies across the country to handle outbreaks, according to Dan Hougentogler, an emergency response and depopulation consultant with nearly two decades of experience in the animal disease outbreak and research industry.

This practice changed with the most recent outbreak when the USDA awarded a contract to Patriot Environmental Services to be the single provider of federal depopulation services.

Hougentogler said this switch has caused a bottleneck when multiple farms need access to the federal services at the same time.

A common depopulation tactic is to fill barns with suffocating foam and Patriot Environmental Services is the only company that can access the federal foaming equipment, he said.

Workers demonstrate the use of a water-based foam depopulation method at an empty broiler farm in Pennsylvania. photo provided by Dan Hougentoglerr

A state agency located in the same area as the national equipment has to wait for Patriot Environmental Services to deploy a team and use the equipment, even if they have staff trained to operate the equipment, he continued.

“Not having an expansive, trained network to operate this federal equipment, or allowing states to utilize the equipment that’s just sitting here with minimal people to use it, does cause some concern,” Hougentogler said.

The nation’s largest poultry companies do not typically use a third party for depopulation services, according to a spokesperson for the National Chicken Council, an industry advocacy group whose board members include executive leaders of several major poultry processors.

The U.S. Poultry & Egg Association, whose members include leadership at Rose Acre Foods, Versova and Cal-Maine Foods, said its members follow all guidelines set by the American Veterinary Medical Association and referred questions to the USDA.

The USDA, Patriot Environmental Services and Crystal-Clean did not respond to repeated requests for comment.

In some cases, the backlog has caused companies to use more controversial methods of depopulation because they do not have the equipment or labor on hand to complete the killings in the needed time frame.

Hougentogler said he was aware of turkey farms that used “less appropriate methods” when they couldn’t access the federal contracts in time. He noted an example where a turkey farm used ventilation shutdown and heat, referred to in the industry as VSD+, to depopulate a flock of commercial poultry.

VSD+ is a controversial method of killing animals, but is currently accepted by industry standards set by the American Veterinary Medical Association.

The USDA and the AVMA note that VSD+ is to be used only in “constrained circumstances,” but the majority of birds killed during the ongoing outbreak have been killed using ventilation shutdown.

Workers close off the circulation of air and seal entrances to barns with ventilation shutdown, oftentimes adding extra heating units to increase the temperature.

“Ultimately, the goal is to have the production system and the state veterinarian agree on what is best for both the production system and animal welfare,” Hougentogler said. “We are depopulating the animal regardless, but until they are unconscious, we should still take as much care for them as possible.”

Utah state veterinarian Amanda Price told Investigate Midwest that the state was able to receive help from the federal contractor Patriot Environmental Services when requested, but some instances were delayed by a few days. This resulted in farms using ventilation shutdown in an effort to stay within target time frames meant to prevent virus spread.

Crystal Heath, a California-based veterinarian and co-founder of Our Honor, a nonprofit group of veterinarian members that advocate against using ventilation shutdowns in the U.S., said that ventilation shutdown is a cruel method to kill flocks.

The practice is banned in the European Union and has been criticized for its cruelty to animals in both commercial pork and poultry depopulation.

“If (producers) are going to get bailout money, they should put plans in place to depopulate with less cruel methods,” Heath said.

The American Veterinary Medical Association is currently reviewing proposals to update its depopulation guidance and is expected to announce changes later this year. The AVMA did not respond to a request for comment.

McDonald’s Egg Supplier Kills Millions of Birds in Michigan with VSD+

Once a farm has depopulated its flock, the work isn’t over.

Carcasses, feed, eggs, manure, and other organic materials are gathered and composted or disposed of, a process that requires a fleet of equipment and workers.

Michigan, a state with 31 confirmed cases of bird flu in dairy cattle herds, has had 16 commercial poultry farms infected with bird flu since 2022, with more than 7 million birds killed.

Most birds killed in Michigan were at egg-laying commercial farms using the ventilation shutdown method, according to USDA data.

“Michigan Department of Agriculture and Rural Development (MDARD) isn’t going to discuss details about the responses done on individual farms as most of that information is protected by Michigan law,” MDARD Director Tim Boring said in a statement provided to Investigate Midwest in response to questions about the use of ventilation shutdown.

“At every facility, we are balancing multiple priorities; including, but not limited to, stopping the spread of the disease, animal welfare, practicality given the structure, and of course safety of the people involved,” the statement continued.

Documents obtained through records requests from the Michigan Department of Agriculture show Herbruck’s Poultry Ranch, the state’s largest egg-producer and supplier of eggs to McDonald’s, disposing of dozens of dump trucks filled with chickens by the day during a depopulation that occurred in April 2024.

Records referred to Herbruck trucks hauling caracasses to be composted at an outbreak site named “IO 02,” which is a reference to “Ionia 02.” This was the site of an April 2022 depopulation event that killed 2.1 million egg-laying chickens.

Herbrucks used ventilation shutdown to kill the flock, based on USDA depopulation data and references to renting and using “heaters” made in the daily logs filled out by staff on site.

Daily worker logs describe days where 55 loads of dead chickens and other material were hauled off the farms to be composted or sent to a landfill.

Contracted environmental waste companies, composting companies, labor and disinfecting crews hauled dead birds and contaminated materials to nearby landfills as well as composted the dead carcassess.

Composting the bodies of birds infected with bird flu is a common practice in disposal and requires all organic material to reach an internal temperature of at least 130 degrees Fahrenheit for three days in order to kill the virus and other pathogens.

Contaminated feed, manure, bodies, eggs and other waste are stacked into large mounds, monitored for internal temperatures and eventually spread back onto land as fertilization.

Herbruck, which received $89 million in indemnity payments for the flocks killed by VSD+, was part of fast-food giant McDonald’s push for cage-free eggs and the decision to “prioritize the health and welfare of the animals,” according to a 2024 company press release.

Herbruck announced it was laying off hundreds of workers in Michigan a month after its 2024 bird flu outbreak.

Mohamed Mousa, Herbruck vice president, declined to answer questions about the company’s depopulation events and bird flu outbreaks. In an email, Mousa said the company does not have a media contact and is trying to “move on.”

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