Welcome, everyone, to this 51st meeting. Pursuant to Standing Order 108, we continue our study of amendments to health of animal regulations, regarding humane transportation.
We have a very packed table to give us some information today and to answer some of the questions we will have. With us this morning we have, from the Canadian Pork Council, Gary Stordy, public relations manager, and Frank Novak, vice-president. From Chicken Farmers of Canada, we have Steve Leech, national program manager, food safety and animal welfare; and Mike Dungate, executive director. From the Canadian Cattlemen's Association, we have Matt Bowman, who is a director and the president of Beef Farmers of Ontario, and Brady Stadnicki, policy analyst. Also, from Metzger Veterinary Services, we have Kenneth Metzger, veterinarian.
Welcome, everyone. We will start with the presentations by the groups, for seven minutes each.
Mr. Novak, would you like to start for seven minutes?
Good morning. My name is Frank Novak. I'm a producer from Alberta and first vice-chair of the Canadian Pork Council's board of directors. I'm joined today by Gary Stordy, who is our manager of government public relations. I want to first thank the House of Commons Standing Committee on Agriculture and Agri-Food for the invitation to appear before you this morning and to discuss the amendments to the health of animals regulations.
I'd like to spend a little time this morning outlining some of the CPC's industry activities related to animal care and transportation and why we have concerns with the proposed amendments to the health of animals regulations. First of all, I just want to point out that the CPC represents more than 7,000 pork producers across Canada. We produce, as a group, more than 25 million animals per year and are responsible for over 100,000 jobs across our industry. The industry generates almost $24 billion in economic activity and last year exported 3.8 billion dollars' worth of pork.
Raising livestock is a 24-hour-a-day, 365-day-a-year commitment, and those who do it take the responsibility very seriously and consider it much more than just a job. Hog producers want to ensure that our animals arrive at their destination in the best condition possible. Canadian farmers are dedicated to the highest quality standards. Registered producers demonstrate their commitment to national standards for food safety and animal care through the national Canadian quality assurance program known as CQA. To be a registered CQA producer, a producer has to undergo an annual assessment for compliance to program requirements.
Producers recognize the importance of animal welfare and led the process to update the code of practice for care and handling of pigs on our farms, which was released in 2014. It was developed through a reasoned and scientifically informed debate that goes far beyond minimum requirements and includes provision for further progressive changes in the future.
I'd like to point out also that the livestock transportation industry is also in the process of updating its code of practice for livestock trucking, and pork producers plan to be engaged in the development of that code. Producers raise their animals to the highest standards to ensure health, safety, and high-quality product, and it is in our best interests to maintain this through transportation.
Hog producers and hog transporters take specialized training courses addressing the specific needs of animals in transport. This includes training staff on how to handle pigs, load and unload pigs, account for weather conditions, be prepared for emergency responses, and understand the potential impacts of those actions on the animals' well-being. Education tools like the Canadian livestock training program, or more specifically for swine, the transport quality assurance program, are mandatory training for anyone who wants to handle or transport pigs to Canada's federally inspected plants.
The CPC supports the move to outcome-based regulations and recognizes the need for continuous improvements, including in areas such as preventing undue stress for animals during transport. We believe that the welfare of animals in transit is dependent on a wide variety of conditions including vehicle condition, weather, handling, etc. It's not possible to describe every possible situation that you might incur.
Outcome-based approaches allow transporters and animal handlers the flexibility needed to ensure good animal welfare by identifying best practices to align with the regulatory requirements. This is why we are unsure why the CFIA has chosen to use both prescriptive measures, such as time off feed and water, as well as outcome measures to address the same concern. We feel that this is unnecessary.
The CPC does not agree with the proposal to reduce the maximum interval for restricting access to food and water from 36 to 28 hours. We feel that the prescriptive time limit does nothing to contribute to the goal of improved animal welfare and only serves to take away from progress that could be made by designing and implementing outcome-based regulations that are grounded in unbiased science.
Very little scientific evidence is offered to support the CFIA's claim that the change will improve animal welfare and reduce risk of suffering during transportation. Despite claiming that the position is establishing clear and science-informed requirements, no research has been cited demonstrating the impact of long transportation times for pigs. The small amount of data available on transportation is limited to market hogs, and no data has been presented for early-weaned pigs, feeder pigs, or breeding stock.
Most of the movement with a duration of between 28 and 36 hours in our industry is for isoweans transported to nursery barns in the midwestern United States. These shipments experience extremely low mortality rates and the U.S. nursery barns report exceptional performance from our pigs when they arrive. These newly weaned pigs have very low feed and water intake in the first couple of days at any rate, even without being transported. It is unreasonable to expect them to eat much, if anything, during this time.
Stopping also compromises biosecurity and increases the risk of exposing these animals to disease. The unloading of pigs will create significant stress leading to even more sickness and death losses, and both of these issues do nothing to improve animal welfare.
In 2016, Canadian producers shipped over 20 million market hogs to federally inspected plants. Our numbers, or the CFIA's own public numbers, show that 0.3% of those animals were found to be sick, injured, or dead upon arrival. This, to me, suggests that we don't have a problem that is out of hand. Rather, it shows that we can always improve. Longer hauls often show reduced rather than increased losses.
CPC is supportive of the efforts to improve animal welfare; however, we believe that better progress can be made by designing and implementing outcome-based regulations that are firmly grounded in unbiased science.
I would also like to add that research on newly weaned pigs' ability to withstand long-distance transport is being initiated currently at the University of Saskatchewan. This project will determine the maximum reasonable transport time that does not significantly impact the pig's welfare. Our recommendation would be that these regulations not be amended, or at least that this particular section not be amended, until that research is complete.
In conclusion, I would like to thank the committee for the opportunity to appear before you today.
Thank you, Mr. Chairman.
Good morning committee members. I'm here with my colleague Steve Leech today.
Chicken Farmers of Canada appreciates the opportunity to provide input on the proposed health of animals regulations regarding transport.
Canada’s 2,800 chicken farmers willingly accept that they have a serious responsibility in terms of animal care, and they take that responsibility seriously. CFC takes pride in its long-standing, progressive approach to animal care. We have a third party, audited, mandatory animal care program that has been in place since 2009. Unlike any other programs that may be proposed out there, the CFC animal care program is the only program that establishes one national standard for all chicken production and is verified by annual third party audits. It's also the only program that is capable of ensuring animal standards on all farms in Canada.
Our program has credible foundations. It's been designed based on the code of practice developed by the National Farm Animal Care Council. The National Farm Animal Care Council is a world leader in bringing together stakeholders with different perspectives and a broad spectrum in terms of input to develop robust and sound codes of practice.
We want to take it one step further. That is why we are, as part of the next agriculture policy framework, seeking a recognition protocol for animal care similar to the one that we have in place for food safety. We think that would provide additional assurance as part of a public trust of agriculture component.
In light of our commitment to animal care, CFC believes that transport regulations should be science-based and developed to work in unison with food safety regulations. We can't do them in isolation. They have to be mindful of the operational structure of Canadian production, and developed with a view as to how they'll be interpreted by the courts. CFC's full comments and the proposed regulations are detailed in our submission, which we've provided to the committee. Specific areas of concerns that we'll address today are the definition of suffering; changes to the feed, water, and rest intervals; and the assessment of compromised and unfit animals. Clearly, I'm not going to try to address in seven minutes all the issues here, but I'll point out some highlights.
The first concern is with the definition of suffering. Under the current health of animal regulations, the reference is to “undue suffering” whereas the proposed version has removed all references to the word “undue”. CFC believes that “undue” must be maintained in the regulations.
The Canada Agriculture Review Tribunal and the Federal Court of Appeal have already developed a balance between animal welfare requirements and normal legal practices of agribusiness in transporting animals and chickens. The word “undue” provides the ability for the courts to interpret if the suffering was unwarranted, disproportionate, or unjustified. Without the word “undue”, any suffering would be illegal, and farmers would be constantly at risk of being before the courts. CFC is of the opinion that maintaining the word “undue” in the regulations will ensure that the objectives of the regulations are met without unduly harming the industry.
Moving on to the transport time—and I'm speaking specifically of the interval for chickens—the proposed regulations would reduce the transport time for chickens from 36 hours to 24 hours. That is a one-third reduction in terms of the time that we're allowed to transport animals. However, the impact is far greater, because the proposed regulations would incorporate feed withdrawal, which can be six to eight hours. Effectively, chickens would now have to be loaded, transported, and unloaded in 16 to 18 hours, so we're talking about more than a 50% reduction in the transport time. This is not continuous improvement; this is radical change.
Feed withdrawal is a food safety issue. This is where we think that we have to pay attention. CFIA has both food safety regulations and animal care regulations. It is there as a food safety issue to reduce the pathogen load on carcasses, and thus reduce public health risks. The proposed transport regulations would compromise food safety, making industry decisions a fight between human health and animal welfare. To remove the inconsistency between CFIA's food safety and animal care requirements, the maximum interval time should be modified to begin once water is withdrawn, not feed.
In Canada, water is available right up to the point at which we load the birds for transport. In CFC's view, radically reducing the transport time by 50% could be considered if there were definitive and compelling scientific evidence to do so. While we won't go into specifics, the consultation submission by Dr. Trever Crowe from the University of Saskatchewan raises significant questions about the scientific evidence to support the proposal. It is a detailed piece from a researcher on animal welfare who is globally recognized, and I think it's an important submission that should be considered by the committee.
CFIA's regulatory impact analysis statement indicates that changes are required to better align with the standards of Canada's international trading partners and the OIE animal welfare standards. However, there is no consistency in feed, water, and rest regulations for chickens among international trading partners. In the United States, there are no federal regulations for transport times; there are only industry guidelines.
Australia, one of the jurisdictions in the proposed regulations, commented that time off feed and water must not exceed 24 hours for chickens, while feed must not be withdrawn longer than 12 hours prior to transport. Since 24 hours plus 12 hours is 36 hours, that's exactly where we are today, although it's being claimed that it's 24 hours. They're not seeing, however, that the regulations are not covering just the transport time. They're expanding what is considered transport.
In Europe, the maximum times that chickens cannot have access to feed and water is 12 hours. However, this does not include loading and unloading times. To Mr. Novak's point, it's interesting that loading and unloading times are not included because of animal welfare concerns. They don't want to put pressure on quickly loading or unloading the birds just to meet time requirements. They want to give them the time necessary to do it properly.
Thank you for the invitation to speak with you this morning. My name is Matt Bowman, and my family and I raise cattle in Temiskaming, Ontario.
I'm currently the president of the Beef Farmers of Ontario and a director of the Canadian Cattlemen's Association. The CCA is the national voice of Canada's 68,000 beef farms and feedlots. With me today is Brady Stadnicki, a CCA staff member here in our Ottawa office.
Transportation is a critical element in modern cattle production, marketing, and distribution. All cattle are transported at least once in their lives. Successfully hauling cattle requires particular skills and a strong emphasis on good pre-transportation decision-making and ensuring that the animals are fit for the entire journey, not just fit enough to get on the truck.
Proper animal care and welfare is paramount in the beef industry and producers continue to ensure the best life possible for their livestock. This proactive approach includes maintaining animal health; minimizing stress when handling, treating, or transporting animals; and continually updating and improving our practices.
When it comes to understanding the effects of transportation on cattle, the Canadian beef industry has not taken a backseat in this approach. In collaboration with Agriculture and Agri-Food Canada, academia, animal welfare experts, veterinarians, truckers, and animal care advocacy groups, cattle producers have invested substantial dollars into research to benchmark how the industry has been performing and to seek ways to minimize the stress on the animals.
Canadian research has shown that the outcomes for cattle transported in Canada are very positive. Studies have found that 99.95% of animals on a longer haul of over four hours reach their destination incident free, and 99.98% of the animals on a short haul of less than four hours reach their destination injury free.
We want to ensure that any amended regulations do not inadvertently move this number farther away from 100%. While we believe this is a good news story, it hasn't stopped industry from continually looking at ways to improve these outcomes. Researchers are always looking into more specific aspects of cattle transport and how they affect the well-being of animals. Examples of such areas include comparing the stress of unloading and reloading versus the stress of completing the journey, and the effects of temperature, trailer design, loading densities, and how a trucker drives.
In addition, it is important to understand whether rest stops do in fact relieve stress. For example, rest stops can facilitate the spread of respiratory and other diseases, especially on vulnerable animals.
With respect to the proposed regulatory changes, Canadian beef animal producers and CFIA share the goal of continually improving animal health and welfare outcomes. It is CCA's position that any regulatory change needs to be based on scientific evidence, and wherever possible, uses outcome-based guidelines that focus on the animal. The CCA believes that for a new rule to be meaningful, the supporting research needs to be conducted using commercial cattle, transport trailers, and drivers under typical commercial distances and conditions in Canada.
CCA is supportive of the efforts to modernize the regulations by bringing more clarity to certain definitions and make regulations less prescriptive and more outcome-based. However, we are concerned with some aspects of the regulatory proposal and the effect they could have on our industry.
First, we're concerned with the change in the maximum number of hours that cattle can be transported, which has been reduced to 36 hours from 48 hours. The geography, climate, and infrastructure that the Canadian cattle industry operates in are much different from other cattle jurisdictions, such as the European Union's, which is a jurisdiction that CCA believes has limited applicability to the Canadian context.
There is little existing evidence that suggests a prescriptive change in the number of hours cattle can be in transit will make the small number of negative outcomes in the cattle industry even smaller. Instead, CCA believes that regulations should be consistent with an outcome-based approach, which would allow experienced and competent drivers to use their judgment and get cattle from point A to point B as safely and efficiently as possible.
CCA also recommends that more research on rest stop intervals and durations is required before any regulatory change comes into force to avoid unintended, negative consequences on animal welfare outcomes. Furthermore, CCA recommends that the existing four-hour grace period in transport times be retained as there is need for reasonable flexibility for unforeseen circumstances that occur during long-distance travel.
CCA is also concerned that the regulatory impact and cost-benefit statements included in the proposal do not accurately represent the cattle industry. It also fails to acknowledge that producers will bear the majority of the added costs created by these regulations. CCA is concerned about the capacity for existing rest stations to handle increased volume, as well as the suitability of existing rest station locations across Canada.
I've recommended that CFIA provide a more sector-focused analysis before any new rules come into force.
Finally, there are concerns about the transfer of responsibility requirement and some of the proposed definitions, which we would be happy to elaborate on a little later during questions.
In closing, I would like to say that cattle producers are continually working to make demonstrable improvements in animal health and welfare outcomes with all aspects of our industry. As we move forward, it is critical that any regulatory change also contributes to real welfare improvements rather than unintentionally risking the high prevalence of positive outcomes delivered by industry today.
Thank you for the opportunity to present this morning, and we look forward to your questions.
Thank you, Mr. Chairman.
I know what you're all thinking. Who is this Ken Metzger, and what is he doing in this meeting?
I'm not a national organization and I don't represent thousands of people. I'm just one little vet from Linwood, Ontario, but I am hands-on and my clinic provides the veterinary service for about 10% of Ontario's hog production and about 75% of Ontario's beef production.
When I read the Canada Gazette, I became worried that the government may just be naive enough to believe these fantasies and actually implement the changes, so I wrote to my MP, my MPP, and Dr. Kiley, expressing my concerns, and I guess that's how I ended up here today. Thank you for inviting me.
One of the main proposed changes in the Gazette would reduce the maximum transport time from 52 hours to 36 hours for cattle, and from 36 hours to 28 hours for pigs. This should not be done because it would seriously disrupt our industry in Ontario. Remember that pigs cannot be unloaded and reloaded for biosecurity reasons.
Every week in Ontario, we bring about 8,000 early weans from Nova Scotia and Manitoba. These trucks can't make that journey in 28 hours, so that entire flow would have to be discontinued. In the case of the Nova Scotia producers, many of them would go out of business. Many of the Manitoba farms are owned by Ontario producers to supply their Ontario pig flow, and many of those farms would have to be sold.
In addition, Ontario has a shortage of hook space, and we need the ability to market pigs to Manitoba for slaughter. There are also over 100,000 cattle per year from Manitoba that would have to be unloaded unnecessarily. Currently, they come straight through.
There is no scientific evidence that shorter transport times would enhance animal welfare. In fact, the research shows that loading and unloading is the most stressful part of the journey and where most of the injuries occur.
Another argument you'll hear is that calves become dehydrated during the journey. That's simply not true, because they have a five- to 10-gallon rumen capacity. Just think about it. The driver might consume three litres of water, but the calf already has 30 litres of water in its rumen. Calves don't become hungry, either, again because of the large rumen capacity and because they eat straw while they're on the truck.
It's already been mentioned that the unnecessary unloading of Manitoba cattle at Thunder Bay is a biosecurity risk. In our own vet clinic every year, we do a survey of our producers on cattle health. We consistently find that long-distance western calves have half of the sickness rate that our Ontario and Quebec calves have. The current transport times are working just fine. Western calves arrive in Ontario in excellent health.
If the committee feels the need for reassurance on that, I'd encourage you to simply open your laptop, go on Twitter, type in “Ken Schaus”, and take a minute to watch some of those videos of unloading western calves in Ontario. Those calves tell the real story.
The second main part of the Gazette deals with a series of definition changes. Now let me be clear. The only group I can see that would benefit and cares about these exact definitions is the CFIA, because they use these definitions to assign AMPs. In four and a half years, the CFIA has issued over 1,000 AMPs that have generated $8.5 million in fines. In my opinion, many of the AMPs that my customers have received are unjustified.
Kathy Zurbrigg, who is a Ph.D. student at the University of Guelph and now works at Ontario Pork, has presented her research to the CFIA. I have it here. It is about in-transit losses in hogs, meaning pigs that die on the truck on their way to slaughter. Her findings were that many of these pigs had heart lesions that caused their death, and that there was no way that producers or transporters could know ahead of time which pigs were affected or if or when they would die.
These pigs simply died, and it's no one's fault. The CFIA assumes, however, that it's from overcrowding, even though the scientific research says otherwise. The CFIA does not seem to be influenced by scientific research, and they continue to issue AMPs for this.
I'd like to give you one more example of how disastrous these definition changes would be. In paragraph 136(1)(f), any animal with “slightly imperfect locomotion” would be deemed compromised and could only be transported if it's segregated, loaded last, and unloaded first, etc. There are tens of thousands of animals with slightly imperfect locomotion every year in Ontario. It would be simply impossible for the industry to comply with that regulation.
In summary, I implore this committee to do the right thing. Don't give in to the irrational objectives of the animal activists. Don't make it even easier for the CFIA to issue AMPs when there are already too many unjustified AMPs. We all want improved animal welfare, both the activists and the livestock industries, but what the activists don't understand is that these changes would actually backfire and reduce animal welfare.
We have a world-class livestock industry in Canada, some of the best farmers, the best transporters, and the best processors producing the best beef and pork in the world. Let's all work together to achieve our common goal of enhanced animal welfare within a successful and thriving livestock industry.
I'm going to talk in French, so you might want to put on your headsets.
My comments will be in the same vein as Mr. Anderson's.
We know that in Europe, the regulatory framework contains extremely high standards. The standards regarding animal transportation are probably among the highest in the world.
Could you tell us a bit about your assessment of the European system? You spoke at some length about shortening the maximum period animals can go without food and water, with which you are more or less comfortable. In Europe, when transportation lasts for eight hours, that is considered a long period, and trucks must be equipped with ventilation systems and drinking troughs, among other things.
What is the situation in Europe? Why is this system cited as an example everywhere on the planet? Could we not get closer to that standard?
You may all answer in turn.
Mr. Novak, you can go first, please.
Thank you to all of you for your testimony today.
Being from Atlantic Canada, I'm going to ask a few questions about the impact to industries in Atlantic Canada. In our last meeting with CFIA, I brought to the table the fact that we have seen a significant decrease in the number of slaughter facilities in Atlantic Canada, meaning that there needs to be more transportation.
Dr. Metzger, you mentioned the flow from Nova Scotia and that it would need to be stopped, or you felt it would need to be stopped. Could you speak to that?
Then perhaps I'll speak to the industries, if I have a chance.
For this second hour, the technical problem has been fixed. Everything is good.
For the second hour, we have with us, from Mercy for Animals, Ms. Krista Hiddema. We also have Lauri Torgerson-White, an animal welfare specialist.
From Animal Justice, we have Ms. Anna Pippus. She is on video conference from Vancouver, B.C. She is the director of farmed animal advocacy. Also, with the Canadian Veterinary Medical Association, we have Michael Cockram, member of the animal welfare committee.
You have seven minutes each, and we can start with Ms. Hiddema.
Members of the committee, it is our honour to have been asked to present to you today. My name is Krista Hiddema, and I'm the vice-president of Mercy for Animals in Canada. I am here with my colleague Lauri Torgerson-White, our animal welfare scientist.
On March 22, in his post-budget interview on Power & Politics, stated that the government is committed to “beat the world” in agriculture. Since Canadian laws governing animal transportation are arguably the worst in the western world, sweeping changes are needed to realize his goal. These changes must ensure that Canada is competitive on a global basis, not just on par with the also-outdated standards of the United States.
Every year, approximately 700 million animals are transported and slaughtered for food in Canada. The government has an obligation to ensure that these animals are not abused. A survey of Canadians regarding farmed-animal transportation revealed that the overwhelming majority believe that animals raised for food must be treated humanely. The reality is that they are not. The CFIA admitted that 14 million animals per year may be suffering during transport, with 1.6 million animals arriving at slaughterhouses dead. One particularly noteworthy finding in our survey was that 95% of Canadians from coast to coast, representing both rural and urban regions, agreed that they would pay more for food that came from animals that were treated humanely.
I will now comment on each of the nine main issues that our evidence-based research has determined to be the most critical factors in assuring the humane transportation of animals.
The first is that the absolute maximum amount of time that an animal should be transported without food, water, and rest is eight hours. This is the practice in many of the major livestock-producing countries, including Italy, France, and Germany, and it is supported by the most current animal welfare science. Not only does increasing journey lengths negatively impact welfare, but it makes us less competitive on the global stage, and it also impacts meat quality.
The second fundamental component is that animals must be protected from weather and have appropriate ventilation. To allow animals to maintain appropriate body temperature, the environment inside the transport trucks must be kept between five degrees Celsius and 30 degrees Celsius, and animals must be protected from rain, snow, and sun. Trucks must be fitted with temperature sensors, a warning system must alert the driver when temperature goes above or below the acceptable limits, and immediate action must be taken when it does.
The third factor is that animals must be provided with enough room so they can assume natural postures and movement. The regulations must include stocking density limits that are species-specific and based on scientific equations that account for the variations in animal weight.
The fourth factor is that only healthy animals should be transported. Transportation is one of the most stressful times in the life of an animal, and under no circumstances should an animal that is already ill or injured be transported. To do so would cause extreme suffering. The determination of the fitness of an animal for transport must be made by properly trained individuals, and where necessary, a veterinarian.
The fifth factor is that there should be a zero-tolerance policy for any form of rough handling of an animal. This means that there must be a complete prohibition on beating, dragging, kicking, and the use of electric prods. Video cameras that are live-streamed to the Internet must be installed in loading and unloading areas.
Sixth, certain animals must be transported separately. The most critical animals this applies to are boars. Boars are often detusked with no painkillers by using bolt cutters below the gum line. This practice is done to allow more boars on a truck, and as you can imagine, it is excruciatingly painful. The practice of detusking boars must be banned, and boars must be transported in separate pens within the trucks.
Seventh, drivers must be required to undergo annual species-specific certification training, which includes animal physiology, drinking and feeding needs, animal behaviour and stress, emergency care, and contingency planning.
Eighth, detailed records of all aspects of animal transportation must be kept and made available to the public.
Last, the government must ensure regular oversight, together with dissuasive fines and penalties for non-compliance. The government has the obligation to treat animals humanely to meet the expectations of its citizens. As indicated, the government also has the obligation to remain competitive on the global stage regarding animal agriculture.
Budget 2017 provides the Treasury Board Secretariat with $6 million over three years to continue its efforts in supporting business growth by promoting regulatory alignment with Canada's trading partners, and agriculture is a key element of this. Given that these regulations were last updated four decades ago, fundamental and substantial changes are critical now, and must be based on new science, not decades-old science.
Thank you for your time. We now look forward to answering your questions.
Thank you very much for the opportunity to be here today to speak on behalf of animals.
Because my special expertise is in law, I'd like to open with some comments about the role of regulation in a democracy. Regulators exist to protect the public interest, not to protect the industries they regulate. I urge vigilance against the common but democratically inappropriate tendency for regulatory schemes to devolve into regulatory capture because of undue industry influence on the substance of regulations.
Justice Wright of the appellate court in D.C. once wisely observed that a recurring question has plagued public regulation of industry, and that is whether the regulatory agency is unduly oriented towards the interests of the industry it is designed to regulate rather than towards the public interest it is designed to protect. The role of the regulator is to establish science-based standards that reflect societal values, in this case the value that animals should not suffer in involuntary service to us. The role of industry is to adhere to those standards in carrying out its economic activities.
Industries the world over resist regulation. This is not due to any particular ill intent but occurs because regulation inherently adds burden and expense. Yet a civilized democracy needs regulation. Vulnerable groups need rules to protect them, and animals are the largest and least politically powerful class of individuals in our society.
The public needs rules in place to ensure that industries don't compromise our cultural values in the pursuit of their own bottom lines, and the public cares deeply about animals and wants them to be free from harm. In a democracy, regulators answer to the electorate, not to the industries they regulate.
In its cabinet directive on regulatory management, the Government of Canada made a commitment to Canadians to protect and advance the public interest to ensure that its regulatory activities result in the greatest overall benefit to current and future generations of Canadians. In addition, the government has promised to make decisions based on the best available knowledge and science, and to encourage entrepreneurship and innovation in the economy.
Many members of the public would be shocked and appalled to learn that according to government figures, 1.59 million farmed animals arrive dead at slaughterhouses each year. This is a crisis. These are animals who suffered to death at human hands. They may have been crowded aboard jostling, jerky vehicles; suffocated and injured; exposed to extreme weather or a lack of air circulation and frozen or overheated to death; collapsed from dehydration, starvation, or fatigue; or all of the above. Many more animals also suffered in these same conditions but managed to hang on to life long enough to avoid becoming a DOA statistic.
This brutal reality doesn't reflect Canadian values or desires.
Canada also has world-class animal agriculture research facilities, including those at the University of Guelph and the University of British Columbia. We should be heeding the fruits of their cutting-edge science. Instead, we're largely ignoring them.
It is said that necessity is the mother of invention. If the regulator only regulates in ways that industries find convenient, what incentive is there for innovation and entrepreneurship to solve the urgent issue of millions of animals suffering and dying? Without meaningful regulation, animal welfare is the inevitable casualty of the consequent race to the bottom.
I'll now say a few words about comparing Canada with other jurisdictions. It is complex to adapt laws from one jurisdiction to another jurisdiction. In fact, there's an entire field of study devoted to the intricacies of comparative law. Situations vary based on culture, economics, demographics, geography, existing political structures, and so forth, yet we can learn valuable lessons by looking to comparable jurisdictions.
One thing is clear. Other jurisdictions are doing a superior job of hearing the public's concerns for animal welfare and of pushing regulated industries to innovate rather than stagnate.
Moreover, the goal should be to be a world leader, not to require only the bare minimum of industry. Canada is a world-class country, and we should be forging new boundaries in the frontiers of compassion and justice for the vulnerable, of respect for science, and of innovation and entrepreneurship, just as the Government of Canada has promised Canadians it would do.
We are particularly concerned with the use of solely outcome-based measures in the weather exposure and loading density provisions. Outcome-based measures rather than prescriptive measures define an outcome but leave it to regulated parties to determine how to achieve the outcome.
In other words, the regulation expresses a vague goal instead of establishing quantitative numbers-based standards. There is a role for outcome-based measures as a regulatory tool, but they must be used appropriately. It is a basic tenet of the rule of law that laws have flexibility as needed, but are as predictable and foreseeable as possible. Specific numbers—quantitative regulations—aid predictability and foreseeability. Vague outcomes do not.
We know from the existing health of animals regulations that outcome-based measures for weather exposure and loading densities do not work, yet these provisions remain essentially unchanged in the proposed regulations. Jurisprudence in the United States has found that outcome-based measures in the context of animal welfare do not work to establish enforceable, minimum animal-welfare standards.
We need prescriptive measures in the areas of weather exposure and loading densities to promote consistency between producers; to avoid a race to the bottom at the expense of animal welfare; to ensure that laws are justly, foreseeably, uniformly, and regularly enforced; and to maintain public trust. Outcome-based measures ought to be used to augment evidence- and numbers-based rules.
Please refer to our brief for more specific detail and for further concerns. I also rely on and endorse the proposals of my colleagues from other animal protection organizations.
Thank you again for hearing my concerns today on behalf of animals, the public, and democracy.
Mr. Chairman and committee members, thank you for the opportunity to appear before your committee.
The Canadian Veterinary Medical Association, CVMA, provides a national and international forum for over 5,500 veterinarians working across Canada. Veterinarians promote animal health and welfare, strive to relieve animal suffering, and protect public health. Veterinarians provide unique expertise on the health and welfare of all types of animals and have a professional obligation to ensure the welfare of animals. Animal welfare advocacy is a strategic priority for the CVMA.
I am a member of the CVMA animal welfare committee and a professor at the Atlantic Veterinary College, University of Prince Edward Island, where I hold a chair in animal welfare. My main area of research is the transportation of animals.
The importance of animal welfare to society and our understanding of how animals respond to management practices such as transportation have increased considerably since the existing health of animals regulations were written. They are in urgent need of revision. As you already would have heard in the evidence presented, both transportation and animal welfare are complex issues. Different stakeholders adopt different positions on the regulatory amendments.
Scientific research on animal welfare has clearly demonstrated that mammals and birds have the capacity to suffer and that aspects of transportation can place animals at risk of suffering. The good news is that if care is taken over the fitness of animals, the quality of the journey, and the associated handling and management of the animals, many if not most animals can be transported without experiencing severe welfare issues. However, situations are rarely ideal and different types of animals are more susceptible to aspects of transportation than others. Unfortunately, some animals experience suffering and others die as a result of transportation.
There are patho-physiological and emotional aspects to suffering associated with transportation. Handling, loading and unloading, vehicle movement, and interactions with other animals can cause injury, pain, and discomfort. Restriction of feed and water during long journeys can result in hunger, weakness, exhaustion of body energy reserves, thirst, and dehydration. Exposure to thermal extremes due to an inability of the transport arrangements to protect the animals from harsh external conditions, both hot and cold, and from the buildup of heat and moisture within the vehicle, can cause thermal distress and death. Animals can experience fear and distress by exposure to novel factors and can develop fatigue during long journeys.
Animals that are weak or suffering from disease or injury are most likely experiencing welfare issues such as pain and sickness before they are transported. They're likely to experience increased suffering because transportation will exaggerate any pre-transport issues. They're less able to cope with challenges such as getting on and off the vehicle, maintaining stability, avoiding fatigue, and coping with feed and water restriction and extreme thermal environments. They're likely to deteriorate during long journeys and more likely to die, become non-ambulatory, or have to be euthanized on arrival than those that are healthy.
The regulations need to address these issues by defining how the management of the animals during transport can reduce the risk of suffering. Unfortunately, the proposed amendments to the health of animals regulations do not fully reflect international standards, scientific research, and veterinary understanding of the implications of transporting animals.
Our main comments on the proposed regulatory amendments can be summarized as follows.
First, on fitness of animals for transportation, the CVMA believes that the proposed conditions listed in the compromised animal category should be reconsidered and that many of these conditions should be placed in the unfit for transport category. It is the CVMA's opinion that proposals that would permit the transport of animals for up to 12 hours with the types of conditions listed under the “compromised animals” category would result in considerable suffering.
The second point is about the intervals that animals may be transported without feed, water, and rest. The CVMA strongly supports the reduction in the time intervals that animals may be transported without feed, water, and rest. However, it is the CVMA's opinion that the proposed maximum intervals for animals are still longer than they should be to reduce the risk of suffering. In some situations, scientific research can provide evidence that indicates deterioration in animal welfare after a specific journey length. However, in most situations, the responses are linear and do not indicate a clear cut-off point. Research on this and associated topics is under review by the NFACC transportation code scientific committee.
Our third point relates to the suffering of animals during transportation. The CVMA believes that multiple approaches are required in the regulations to ensure that even though an animal arrives at its destination alive, suffering has not occurred along the way. In addition to the proposed outcome-based measurements, the CVMA believes that weight must also be given to the research evidence, professional advice, and opinion of veterinarians with respect to the assessment of suffering and the enforcement of regulations.
The CVMA strongly supports the removal of the term “undue suffering” from the current regulations and endorses its replacement with the word “suffering”. In addition, we made a number of detailed suggestions to various sections of the proposed regulations.
The CVMA encourages the federal government to dedicate the necessary resources for enforcement, training, and research in order to implement and sustain the new regulations so as to achieve the desired animal welfare outcomes.
The CVMA wishes to express its support for the general direction being taken by the proposed regulations. However, the CVMA is strongly of the opinion that modifications are necessary to ensure that the new regulations are effective and meaningful in strengthening the humane treatment of animals during transport. We look forward to working with the various stakeholders to develop solutions to the challenges of transporting animals, bringing to the table our knowledge, skills, and experience as veterinarians.
Thank you, Mr. Chair.
That is the theory you are coming forward with.
I'll just get back to transportation, but at the end of all this, I believe that my job is to balance proper regulations with making sure that we don't increase the price of food. Otherwise, I'm going to have poverty advocates here saying that the price of food is too high. We're talking about.... You've mentioned that over 700 million animals being transported are slaughtered. That's 2% of animals that would be suffering when they're being transported, if you do the math. It's also less than 1% of animals who arrive dead on arrival.
At the end of all this, the proposed regulations, how much—and I'm asking all members here; they can answer the question—will it reduce that percentage? At the end of it, if it doesn't reduce that percentage, we're doing this for nothing. I want to make sure that what we propose, what we come forward with, and what recommendations we propose in this committee reduce that number. If they don't, then we did this exercise for no reason.
Thank you, Chair. I'd like to thank our witnesses before committee today on this study on animal transport.
I'm just trying to go through this. When we're done our day in the House, I always go home and I try to prepare for the following days.
I must commend you on the amount of documentation provided for this study. Thank you. I'm still trying to process it all.
I'd like to start off by asking a question. We had laws put in place in 1977. Now in 2017 we're going over them after a 10-year consultation period. I know we're trying to get in line and harmonize our laws and certain of our practices in Canada with international standards. I know what we do has to be made in Canada and has to take into account the geography and the weather we have here in Canada, the four seasons.
Could you maybe comment on where Canada is as compared with the States, and maybe comment on Europe's practices and standards in comparison with regard to international animal health?
We've actually done an analysis of where Canada sits in comparison to every major country, including the OIE. That can be found in our documentation, in chart format. Unquestionably, we fall behind every other civilized country in terms of animal transportation. While we don't fall particularly far behind the United States, we are still behind. We certainly take the position very strongly that, as Canadians, and in particular as Canadians who don't want animals to suffer, we have an obligation to make dramatic change at this point.
The other thing I just want to comment on is the ongoing question about the EU. At the end of the day, while we are not the EU, animals certainly have the same capacity for suffering, whether those animals are sitting in Germany or they're sitting in Canada.
When we talk about the number of hours in transport, there are alternatives. When we talk about animals being offloaded and reloaded, yes, that's extremely stressful, but there are trucks available that have on-board food and water, on-board ventilation, and on-board monitoring of temperatures. When we know those transport times are going to exceed maximums like eight hours, they should be utilizing separate trucking systems.
We also believe that there is an opportunity for job development in having more slaughterhouses so that they simply would not have to be in transport for 52 hours, which is grossly unacceptable. We know there are job opportunities here, and there are better trucking systems.
It's no different. If you're going to take your kids to Florida, what are you going to do? You're going to pack a lunch and put it in the back of your car, and you're going to do a few other things, and you're going to stop. There are opportunities for animals as well. As Michael has indicated, every animal feels suffering, and not one death is acceptable. Where we can reduce that dramatically, we have that obligation on the global stage, to Canadians, and quite frankly, to the animals.
An “unfit“ animal is an animal that cannot legally be transported. Canada is quite unique compared to, say, the EU regulations, by having a separate category of “compromised animals”, whereby those animals are not fully fit but they are allowed to be transported under special circumstances.
The difficulties we in the CVMA have when we look at the proposed regulations are, first, the maximum time they could be transported is 12 hours—that's a long time for an animal to go downhill—and, two, there are a number of conditions listed for compromised animals, meaning that the suffering will be exaggerated by the transport. Having sick or injured animals enter the human food chain is a way of allowing industry to get an economic return from them.
We are suggesting that the list of compromised animals be reconsidered so that animals that shouldn't be transported at all are not transported, and that the only option for these animals should be local slaughter, say within an hour of the livestock unit. Otherwise those animals are going to suffer unduly, and that's not acceptable.
If the management of the animals during transport was okay, there shouldn't be the need to put so much emphasis on journey times and times off feed and water.
A number of animals, as you've heard, can be transported on long journeys, if it's done well. It's not impossible to do. In Europe, as you've already heard, there are specialized vehicles for animals to be transported over eight hours. They can only be transported in vehicles that are able to feed and water them on route and that provide good conditions for them.
When looking at the regulations, you need to look at where the major risk factors are. Pigs, for example, are more susceptible to time off water than, say, a ruminant would be. As you heard in the evidence earlier today, ruminants and the ruminant animal—
My thanks to all the witnesses, not only you guys but also the previous group of witnesses.
Your testimony was extremely helpful to my understanding and balanced the need to have a vibrant agriculture industry with the need to take care of the legitimate welfare requirements of animals.
Ms. Hiddema, I agree with you that our agriculture sector is very important. I would take it one step further and talk about the statement of our agriculture minister, , that we should be a superpower in agriculture. That includes animals: hogs, chickens, pigs. I was blessed to have the minister in my neck of the woods, which is Steveston—Richmond East. We have over 200 farmers: hog producers, chickens, cattle.
How do you think your proposals would impact the industry in British Columbia?
Animals under the law are property, but they are a special kind of property. The law doesn't really explicitly recognize that, but it does implicitly recognize that. Quebec's move to classify animals as sentient beings was an explicit move toward that.
For example, it's a criminal offence to abuse an animal. It's not a criminal offence to abuse a table. That's because we implicitly understand in the law that animals are sentient individuals. When it comes to their ability to suffer, animals are no different from us humans, and in fact, we sometimes forget that humans are also animals.
Generally, the world over, there is a trend toward recognizing that animals are a special type of property, that we use them as property, but that we're also increasingly in science recognizing that they are sentient. Also as a society we're becoming much more empathetic and compassionate toward animals as vulnerable individuals in our society.
I think that global trend paints the background a little bit for why it is so important to move these regulations. There is discussion of the difficulties, and there are discussions of whether this is really going to change things, but of course, that's what we're here for. We have to believe that regulating works and is essential to a functioning democracy.
As to the case in which Anita Krajnc has been charged with criminal mischief in Toronto for giving pigs water, I think that case really illuminates the problem with pigs in particular aboard these hot, metal trucks that are not climate controlled. In the winter they can become very cold, frozen even. Ms. Krajnc has documented pigs with frostbitten ears. Conversely, in the summer they can arrive panting, which the code of practice for transportation of animals says is a sign of heat distress in animals and needs to be addressed immediately or the animals risk dying.
We didn't get into too much detail, but in New Zealand, for example, pigs and other monogastrics can't go without water for more than six hours, so they parse out water and food in a species-specific way to recognize that pigs don't have sweat glands, and on board metal trucks they are dropping dead. About 15,000 animals a year are dying in transport.
I'm proud to be the son of pig farmers and the son-in-law of dairy farmers, and I simply cannot let the statement stand that there's some kind of systemic abuse of animals on Canadian farms. That's simply not the case.
I'm very proud of the 5,600 farmers in my riding. We have more than half a million pigs, more than 50,000 cattle. They are not being abused. They are not subject to undue abuse by farmers. I'm proud of our Canadian farm families. I'm proud of the work they do. I think it's a slap in the face to the hard-working farm families to imply, even make an implicit statement, that there's abuse going on in these farms and in the standards. It's simply not happening. I think that's a slap in the face of so many farm families.
My question is to Dr. Cockram. In your comments you mentioned that loading and unloading increases the stress and the opportunity for harm and pain to animals, yet you're at the same time advocating a decrease in the amount of time that an animal can be on this truck, thereby increasing the number of times that an animal is going to be unloaded and reloaded.
How do you justify that statement, where on the one hand you're saying it increases the risk, and on the other hand you're saying we should have more loading and unloading?