Amendments to the Health of Animals Regulations (Humane Transportation)

Transcription

1 Amendments to the Health of Animals Regulations (Humane Transportation) A brief to the Standing Committee on Agriculture and Agri-Food presented by the Canadian Coalition for Farm Animals Written by directors Stephanie Brown, Lynn Kavanagh and Claire Prime

2 Standing Committee on Agriculture and Agri-Food Sixth Floor, 131 Queen Street House of Commons Ottawa, Ont. K1A 0A6 Canadian Coalition for Farm Animals 131 Bloor Street West Suite 200/140 Toronto, Ont. M5S 1R8 Dear Committee Members, The Canadian Coalition for Farm Animals is pleased to submit comments on the Health of Animals Regulations (Humane Transportation) for the Standing Committee on Agriculture and Agri-Food. Below you will find 12 areas of which we are particularly concerned for the welfare of animals during transportation. We would also like to bring to the attention of the committee the findings of several Access to Information requests we filed recently. Through the obtained documents, we discovered that the Canadian Food Inspection Agency (CFIA) bowed to industry pressure, and against the recommendations of scientists, when amending these regulations. Of note in our findings: The maximum allowable time without food, water and rest during transport was increased from the scientific recommendations for nearly every mentioned species after consultation with industry. The recommended 12-hour maximum for spent hens was increased to 24 hours, despite acknowledgement that these birds are compromised because of their weakened state from egg-laying. Food, water and rest deprivation averages 7.75 hours prior to transport, 5.54 hours during loading, 2.96 hours in transport, and 9.72 hours for spent hens waiting for slaughter. Research findings cited in the files show that animals suffer long before the maximum food, water and rest times ( spent hens reportedly show signs of suffering at eight hours). Exposure, heat and cold, and inadequate ventilation are the top three types of non-compliance, yet the proposed regulations set no rules for allowable transport temperatures. In 2014, 17.4 percent of shipments of spent hens had dead-on-arrival (DOA) rates of four percent or more anything above four percent is considered non-compliant. On one truckload, percent of the hens arrived dead. From January 2015 to June 2016, across Canada, the CFIA made only 59 roadside inspections of trucks transporting animals. More information about our findings can be found at humanefood.ca/regulations.php as well as in a Globe and Mail article written by Ann Hui and published March 16. We hope you will carefully weigh our concerns when reviewing these regulations, which impact the lives of millions of animals every year. Thank you, Stephanie Brown, Lynn Kavanagh and Claire Prime Canadian Coalition for Farm Animals directors 2

3 1) The proposed transport time for chickens is too long. CFIA s proposed transport times are an improvement over current standards, but allowable times are still too long. The Regulatory Impact Analysis Statement compares the proposed transport times with New Zealand, the European Union (EU), Australia, and the United States. The EU has the shortest allowable times without rest or access to food and water. New Zealand is second. Canada and the United States, meanwhile, are at the other end of the spectrum. People today are concerned about the care and protection of farmed animals, demanding improvements for animals in areas such as transport. Governments have an obligation to respond. CHICKENS: THE MOST TRANSPORTED ANIMAL IN CANADA About 650 million chickens are transported in Canada each year. Their transport is complicated. These birds are vulnerable to extreme temperatures as well as rain and snow. Current transport vehicles rudimentary flatbed trailers covered by tarps offer little protection from the weather, and no way to feed and water the birds. Spent hens Canadian spent hens are typically shipped to slaughter after a year of lay. Many suffer osteoporosis from calcium deficiency, and many are featherless from life in battery cages. They may suffer broken legs and wings from being quickly pulled from cages and forced into plastic crates. The new draft regulations will subject these birds to 24 hours of transport with no access to food, water or rest. That s far too long. CFIA originally intended to set their transport time at 12 hours the same as the allowable time in New Zealand. 1 However, due to industry pressure, the time was increased to 24 hours. 2 CCFA recommends the maximum time for transporting spent laying hens and broilers be 12 hours, not 24 hours as the draft regulations allow. Spent hens should be transported to the nearest slaughter plant or killed on the farm. From the OIE: Section observing animals during the journey: If the animals are in crates or on multi-tiered vehicles, which do not allow free access for observation, for example where the roof of the tier is too low, animals cannot be inspected adequately, and serious injury or disease could go undetected. In these circumstances, a shorter journey duration should be allowed, and the maximum duration will vary in accordance with the rate at which problems arise in the species and under the conditions of transport. Section space allowance birds should have adequate head room to allow head cooling in transport during hot temps Chickens raided for meat ( broilers ) Transport times for broiler chickens could be shortened to 12 hours by requiring birds to be transported to the closest slaughter plant. Instead, producers often negotiate contracts with kill plants hundreds of kilometers away. For example, chickens transported from Thunder Bay, Ontario, to the Toronto area (a distance of 1,399 kilometers) would travel a minimum 15 hours, 36 minutes. 3 Meanwhile, the Thunder Bay producer could instead contract with a local facility 2 or 3 hours away. This shorter trip would reduce the birds travel time and suffering. CCFA requests transport times for chickens raised for meat not exceed 12 hours unless food and water and temperature-controlled vehicles are used. 2) Transport vehicles in Canada should be equipped with up-to-date transport vehicle technologies, including heating, cooling, ventilation, hydraulics and alarms, dependent on species 3

4 being transported. These amenities should be required when replacement vehicles are put in place on Canada s highways. Canada has extreme weather. We all know that. Vehicles in the European Union require features such as watering equipment, heating and cooling for animals transported more than 8 hours. Norway, Sweden, and Finland transport chickens using fully enclosed transport vehicles that are mechanically ventilated, and sometimes fully air conditioned. 4 While a few companies in Canada use similar technologically-advanced trucks, these vehicles are not mandatory despite Canada s weather extremes. Features such as hydraulic lifts also help improve transport for animals. By raising floors on multi-level pig transport vehicles, these lifts save the pigs from climbing steep inclines, which they find difficult and frightening. A few Canadian trucking companies recognize the advantages of such features, and use these vehicles with success. 5 Canadian animal welfare scientists also advocate these types of vehicle amenities. 6 Despite the benefits of these amenities, there is no mention of them in the draft transport regulations. CCFA requests that, as existing transport vehicles in Canada are replaced, CFIA requires the phase-in of technologically-advanced vehicles with features such as hydraulic lifts, heating and cooling, ventilation, feeding and watering equipment, and temperature monitors to alert drivers when trucks are too hot or cold. 3) The regulations need to address the issue of temperature. Animals are transported every day of the year in this country, in every type of weather. For example, in 2010, approximately 8.5 million chickens died en route to slaughter, or were condemned due to illness and injuries as a result of transport conditions in Canada. 7 There is nothing in the draft regulations to address this issue no guidance around maximum temperatures, no requirements to monitor temperatures in transport vehicles. The Canadian chicken industry document, Should this bird be loaded?, 2010, states that temperatures of degrees Celsius are appropriate for transporting spent hens, and 5 30 degrees Celsius is appropriate for transporting broiler chickens. 8 However, without temperature-controlled vehicles, the only way this standard can be met is to stop transporting chickens on very cold or hot days. CCFA requests the regulations specify allowable temperatures for all farmed species during transport, and then enforce the regulations. 4) The regulations should address density. Animals should be able to stand and lie comfortably during transportation. Density standards are necessary to help ensure comfort and safety. Throughout CFIA s Regulatory Impact Analysis Statement, there are indicators that various standards will be established including clear parameters around overcrowding. However there are no such parameters included in the draft regulations. The Canadian transport code of practice includes tables for density, but this content is not regulated under law. 9 CCFA requests standardized animal transport densities be developed be included in the Health of Animals Regulations (HAR). 4

5 5) Training programs, with certification, should be required for drivers and animal handlers. [Section 138 (1-3)]. Third-party training such as the Canadian Livestock Transport (CLT) certification program are important tools for animal transport drivers and animal handlers. The CLT program provides increased accountability and improved handling practices in livestock transport and poultry handing... The course (also) presents the current regulations in animal transport in Canada. 10 CFIA s Regulatory Impact Analysis Statement addresses the value of training programs for drivers who operate under a commercial carrier. In the draft regulations, Section 138 (1-3) outlines the requirements for training. CCFA supports CFIA s plan to make training mandatory for people who operate commercial transport trucks; however, the program should be extended to all animal transport drivers and all other persons who handle animals. 6) Electric prods and whips should not be allowed when moving animals [Section 144(1) [a-h]. Electric prods are crude tools that frighten and confuse animals. Trained, certified drivers and handlers do not need prods or whips to handle animals it s the untrained handlers who tend to rely on them. Currently, the draft regulations allow for their use. See Statement b, c and d from Section 144 (1)(a-h). CCFA emphasizes use of electric prods and whips on animal should not be allowed under the HAR. See here: 7) Compromised animals should not be transported unless it s for the animal s health care. [Section 142(1-6)] The draft regulations allow compromised (sick or injured) animals to be transported 12 hours (Section 142 (1-6). While the regulations include provisions such as loading these animals last and unloading them first, or ensuring that measures that are necessary to prevent the animal s suffering, injury or death during loading...are taken, these provisions do not address the key issue, which is that these animals shouldn t be transported at all. CCFA believes the allowable transport time is too long given that suffering of compromised animals is often severe and thus should be reduced to six hours. Transport should only be permitted if an animal can receive veterinary treatment or humanely killed or euthanized during that time, otherwise, the animal should be humanely euthanized on the spot. 8) Transport of Unfit Animals CCFA believes unfit animals should be humanely euthanized on the truck rather than being transported for veterinary care or to be killed at a slaughter plant. It is inhumane to cause further suffering to these animals that are unlikely to receive costly veterinary care. Moreover, under the definition of unfit, section 136 (1), transporting animals with some of the conditions listed begin on the farm and transport should NOT OCCUR AT ALL. If they do, farmers should be fined for transport unfit animals. These include: Animals that are extremely thin (often cull dairy cows they should be euthanized on farm) Animals that have given birth in the preceding 48 hours or that are in the last 10 percent of their gestation period Lame Other conditions listed may often occur at the farm level and again farmers should be held accountable for transporting animals in poor health and suffering from acute or chronic pain. 5

6 Similarly, under the definition for compromised animals, those animals in the heavy stages of lactation should be dried out gradually prior to transport. 9) Cull animals (animals intended for slaughter) may be sick or injured, and need to be individually assessed prior to transport especially poultry. As the most transported and least regulated farm animal in Canada, chickens are especially vulnerable to suffering during transport. When barns of spent hens are emptied, for example, the birds are quickly pulled from their battery cages and crated. Catchers pay little attention to the condition of individual animals. Birds in poor condition should not be transported, but killed on the farm. Other cull animals, such as sows, boars, dairy cows, bulls, does, ducks, geese, ewes, rams and turkeys, often must endure extra-long transport because fewer slaughter plants take these animals. Animals should be individually assessed for condition and not transported if unfit. These fragile cull animals are typically subject to extra-long transport because fewer slaughter plants take them. Certain animals such as boars undergo painful procedures such as having their teeth cut without pain relief prior to transport. This is done to stop aggressive animals from injuring one another on long-distance trips. Teeth-cutting should not be allowed instead, boars should be separated by partitions on the trucks to prevent fighting. All cull animals should be carefully assessed before transport especially poultry and should not travel if they are sick or injured. Instead, they should be killed on the farm. 1 10) Section 145 (2) (c) allows a 25-degree ramp for pig transport. This is too high. The maximum allowable slope for pig vehicles should be not exceed 20 degrees. The Canadian Pig Code of Practice has a Recommended Practice, which limit(s) the angle of loading ramps to 20 degrees or less. 11 Better yet, pig transport vehicles with slopes should be replaced with vehicles with hydraulically raised and lowered floors. Guelph s Centre for the Study of Animal Welfare reported, When pigs climb ramps they took longer to load, experienced more slips and falls, their heart rates stayed elevated for longer, their body temperatures were higher and the physical exertion of getting up from the top or the very bottom of the truck showed up in poorer meat quality. 12 At this year s Banff Pork Seminar, Luigi Faucitano reported a comparison study between a pot-belly trailer and truck and trailer with hydraulic features, noting more death losses in the pot-belly trailer compared to the other one. We observed...more losses in the top deck (than) in the bottom deck because of the ramp. The pigs were more fatigued at loading so they couldn t recover from the stress of loading from negotiating the ramp and they eventually died during travel. The ramp inside the trailer within loading systems is something that should be avoided or corrected... Replacing ramps with hydraulic devices is a solution. 13 The CCFA recommends 1) pig transport vehicles with hydraulic floor features, or 2) a slope no higher than 20 degrees for pig transport vehicles without hydraulic lift features. Section 159 Transport times These must be lower to be considered humane and progressive. Canada should match the EU and NZ regulations. We suggest these which we believe are a compromise with animal welfare and industry: Compromised animals 6 hours, and only if going directly to a vet for treatment or to be humanely killed Young ruminants 8 hours Broiler chickens, spent hens and rabbits 12 hours (in keeping with CFIA`s own research) Beef and dairy cattle and other adult ruminants 24 hours 6

7 Other adult monogastrics 24 hours Equines and pigs 18 hours Unfit animals humanely euthanized immediately or ASAP, no transport 11) 1Re: Coming Into Force, unnumbered section, following Section 159(4) (4): Once the revised transport regulations are published in Canada Gazette II, CFIA is proposing a one-year delay to implementation, to accommodate business interests. Already, delay is inevitable, given time needed by CFIA to review comments about the draft regulations, following the February 15, 2017, deadline. To delay implementation of the regulations an extra year for $71 the anticipated savings for the one year delay for businesses by delaying implementation, is not justified. This small amount would not be a hardship for any viable animal transport business. CCFA recommends against a year s delay to implement the transport regulations. 12) Enforcement of animal transport regulations ranks lows among CFIA priorities This section is not based on a particular draft regulation, but rather enforcement of the regulations which are CFIA responsibilities. Animal welfare enforcement does not rate highly among CFIA priorities. CCFA believes CFIA does not allocate sufficient (or any) resources to highway animal transport enforcement. The result is unnecessary animal suffering. Other priorities, such as food safety, receive sufficient CFIA resources. Of course this is an important issue, yet it is not an excuse to short-change animal-transport enforcement, which affects hundreds of millions of farmed animals every year. For example, we question how many random on-highway inspections took place in 2016 across Canada that resulted in the statistic that 98% of current regulatory requirements (which themselves are weak to begin with). How many inspectors across Canada were assigned to animal transport enforcement on Canada s highways on a continuing basis? The Canadian Federation of Humane Societies notes, CFIA funding for animal welfare enforcement must be substantially increased to ensure effective monitoring of federal regulations. 14 This issue is of particular concern because the (draft) transport regulations are partly outcome-based. Outcome-based regulations can only be enforced after a problem occurs. A random highway presence is needed, but that does not happen. Trained highway inspectors would help ensure transport regulations are followed. When an enforcement presence is seen, compliance with HAR will improve. CFIA should institute roadside check points with authority to relieve animals in distress, and employ AMPs at slaughter house auctions and roadside check points. CCFA believes improved inspections and enforcement of animal transport regulations are required to improve animal transport outcomes, to include lower DOAs. Summary of Recommendations to the Standing Committee on Agriculture and Agri-Food CCFA recommends the maximum time for transporting spent laying hens and broilers be 12 hours, not 24 hours as the draft regulations allow. Spent hens should be transported to the nearest slaughter plant or killed on the farm. CCFA requests transport times for chickens raised for meat not exceed 12 hours unless food and water and temperature-controlled vehicles are used. 7

8 CCFA requests that, as existing transport vehicles in Canada are replaced, CFIA requires the phase-in of technologically advanced vehicles with features such as hydraulic lifts, heating and cooling, ventilation, feeding and watering equipment, and temperature monitors to alert drivers when trucks are too hot or cold. CCFA requests the regulations specify allowable temperatures for all farmed species during transport, and then enforce the regulations. CCFA requests standardized animal transport densities be developed be included in the Health of Animals Regulations (HAR). CCFA supports CFIA s plan to make training mandatory for people who operate commercial transport trucks; however, the program should be extended to all animal transport drivers and all other persons who handle animals. CCFA emphasizes use of electric prods and whips on animal should not be allowed under the HAR. CCFA believes the allowable transport time is too long given that suffering of compromised animals is often severe and thus should be reduced to six hours. Transport should only be permitted if an animal can receive veterinary treatment or humanely killed or euthanized during that time, otherwise, the animal should be humanely euthanized on the spot. All cull animals should be carefully assessed before transport especially poultry and should not travel if they are sick or injured. Instead, they should be killed on the farm. 1 The CCFA recommends 1) pig transport vehicles with hydraulic floor features, or 2) a slope no higher than 20 degrees for pig transport vehicles without hydraulic lift features. CCFA recommends against a year s delay to implement the transport regulations. CCFA believes improved inspections and enforcement of animal transport regulations are required to improve animal transport outcomes, to include lower DOAs. 8

9 The Canadian Coalition for Farm Animals (CCFA) is dedicated to promoting the welfare of animals raised for food in Canada through public education, legislative change and consumer choice. CCFA supporters are animal protection organizations across Canada representing over 120,000 Canadians. The goals of the Canadian Coalition for Farm Animals (CCFA) are to educate Canadians about the realities of factory farming and its impact on animals; to promote more humane consumer choices; and to achieve a legislated ban on battery cages and sow stalls in Canada, and revised transport regulations in keeping with more humane standards. 9

10 1 The EU s transport time for birds is 8 hours unless vehicles provide water, are insulated, and have special partitions and mechanical insulation. New Zealand s allowable time is 12 hours. 2 Canada Gazette, vol. 150, No. 49 December 3, 2016, Regulations Amending the Health of Animals Regulations, Regulatory Impact Analysis Statement, p Google.ca, information accessed January 19, Personal from Wouter Keerkamp, Meyn Company, to Lesley Moffat, Eyes on Animals, Amsterdam, January 15, Warren Rix, Advantages and disadvantages of the 3-tiered truck for market hogs, Pork Production 2013: Staying afloat in the troubled waters ahead, 2012 Shakespeare (Ontario) Seminar, September 19, Dr. Luigi Faucitano, Agriculture and Agri-Food Canada, commenting in Diplomat and International Canada Magazine, 2013, p Mitchell and Kettlewell, Should this bird be loaded? Ibid. Mitchell and Kettlewell note 8.5 million birds died during transport or were condemned in Canada, Recommended code of practice for the care and handling of farm animals, Transportation, Canadian Agri-Food Research Council, 2001, pages accessed January 18, Code of Practice for the Care and Handling of Pigs, National Farm Animal Care Council, 2014, p CCSAW News, The Transport Truck: A Pig s-eye View, University of Guelph, pp. 9-10, May 11, Luigi Faucitano, Swine Transportation: Science-based solutions to current issues, Banff Pork Seminar, January 11-12, Realities of farming in Canada, CFHS