The CHDC has drafted a response to the form letter being sent to advocates from the Party Liaison. If you have received the standard form letter below, please take the time to RESPOND to your MP and enlighten him or her with a response. You may wish to send this response as-is or make your own changes, but please send a response, and we suggest following up with a phone call or meeting to ensure that your MP has read the response. Ask them what action they are going to take on behalf of horses and tell them that this will be AN ELECTION ISSUE. The text of the letter, which appears to have been sent out to anyone who wrote with a concern about horsemeat, is in red; our response is in BOLD Italics.
The letter begins:
Thank you for taking the time to write to me about the slaughter of horses in Canada.
I can appreciate that some people have difficulty with the slaughter of horses for meat production, and I certainly share your belief that animals should be treated humanely. It is not acceptable for animals to be starved or abused. The Government of Canada takes the issue of proper animal treatment seriously. Canadian Food Inspection Agency (CFIA) inspectors work hard to enforce the Meat Inspection Act, which sets standards for the humane handling and slaughter of animals in federally registered abattoirs.
One of the concerns for horse advocates is that we have added another non-food animal to the already short-staffed CFIA and inspector roster. Consumers in Canada and elsewhere are already at risk as a result of the acknowledged demoralization and shortage of inspectors in the CFIA. There are already several incidents of wide-spread food contamination that have prompted both illness and food recalls of “conventional” foods.
Anyone who witnesses animal suffering is encouraged to report it to the CFIA, which may then investigate and take appropriate action. For more information about the CFIA’s work to enforce these standards, please visit www.inspection.gc.ca/about-the-cfia/accountability/enforcement-and-compliance/eng/1299846323019/1299846384123.
Various levels of government including the CFIA, the Chief Veterinary Officer for Canada, Chief Food Safety Officer, Minister of Agriculture and Agri-Food, Transport Canada, and the Attorney General have been made aware of transport violations both on the ground and during the live transit of slaughter-bound horses to Japan. Yet these various levels of government have consistently and repeatedly failed to accept any responsibility for the issues of food safety and transport violations, as identified in various Access-To-Information documents detailing dead or downed horses, mares delivering foals in transport trailers or on the slaughterhouse lot or production floor, and many other violations.
In order to protect Canadians, the Canadian Food Inspection Agency has set in place numerous regulations for meat production in Canada, including horse meat.
The public has a legitimate concern that chemicals used in drugs, commerce, and foods, will be prudently evaluated for unreasonable risk. Unreasonable risk adds consideration of technical, economic, and societal impacts. The Meat Hygiene manual does not even begin to address the legal, off-label, and illegal drug use in horses, particularly that which is endemic in the horse racing industry. Drugs such as cocaine and dermorphin are not even accounted for or considered in the Meat Hygiene Manual of the CFIA, yet they have been given to racehorses to improve performance.
Approved use of medications in food animals is specifically contingent upon observation of recommended withdrawal times. Withdrawal times have been experimentally determined in traditional food animals; however, withdrawal times for these drugs have not been established in horses. Thus, medications that are approved for use in traditional food animals come with specific withdrawal schedules printed on the packaging, while the same medications purchased for horses do not include the requisite withdrawal schedule, but simply state “NOT FOR USE IN HORSES INTENDED FOR FOOD.”
Unlike the United States and Canada, European Union and United Kingdom member countries have a distinct safety policy with regard to horses entering the food chain. All EU/UK horses must carry “equine passports” in which the animal is declared to be either “eligible for slaughter as human food,” or “not eligible for slaughter for human food.” American and Canadian horses, including wild horses, live in uncontrolled situations for indeterminate periods of time, have inadequate health histories and may not have not been reliably vaccinated and monitored for illnesses such as rabies, brucellosis, anthrax, glanders, leptospirosis, or ehrlichiosis. The Equine Information Document or EID is a totally voluntary system that rewards those who are dishonest and have a motivation to profit from the sale of their horse at an auction. It’s unbelievable that the Canadian government allows private individuals to control inputs to the food chain. Do we buy meat off the street from people we don’t know? It really amounts to the same thing.
Withdrawal times also vary depending on drug delivery methods – whether oral/IV/IM and whether used in combination with other drugs. The dose itself along with the frequency of use (repeated oral administrations can greatly extend withdrawal times) are two of the most important factors. Compounded drugs (as opposed to generic or branded drugs sold OTC or through veterinarians) can vary widely in potency as well. The amount of body fat, the breed, gender and health of the horse are also factors that affect kinetic decay of drugs. Lastly, the amount of stress that the horse is subject to may also affect withdrawal times. And even though a pharmacological effect on the animal may be over, the drug and its metabolites may still be detectable, and those metabolites may also be prohibited. The CFIA manual doesn’t tell anyone this, nor could they expect the lay horse person to understand any of the factors that also affect withdrawal times and drug tests, so the person completing the Equine Information Document (EID) even if honest, is never provided with the appropriate information.
Furthermore, Equine Canada (via the FEI) has classified approximately 1,000 different drugs as either “Banned” or “Controlled” in the 2015 Equine Prohibited Substances List. The Meat Hygiene Manual is sparse by comparison – are these 1,000 drugs all deemed safe for consumption? As previously mentioned, the system isn’t designed to encourage former owners to give too much thought to what drugs a horse may have been given on or off-label during the course of its life. It’s to the benefit of the slaughterhouses that short-term owners will be unaware of the existence of a list of prohibited drugs or drugs that must be withdrawn for days or months, since this means fewer declarations of drug administrations, and allows the CFIA to claim that there is a “98% compliance rate for drugs.” If there were adherence to the Meat Hygiene manual, the majority of horses would be disqualified outright because of phenylbutazone and other drug usage, including virtually all former race horses. Those that were not disqualified outright would probably need to be held for six months for withdrawal. You couldn’t even immediately slaughter a horse that had recently been wormed. What does that say about the horsemeat supply that the animal must sit on a feedlot for six months before the meat might be “safe” to eat?
Among these is the requirement that all horse meat producers must obtain the health and medical history – complete with information on all drugs and vaccines used – of each horse for the 180-day period before consumption. Horses known to have been given phenylbutazone as indicated on their Equine Information Document covering at least the six months prior to slaughter are not permitted to be slaughtered for human consumption. This timeframe allows for horses and other animals to naturally eliminate remnants of any-and-all medication that may have been previously administered. These requirements also apply to horses imported from the United States.
It’s clear that the government is unaware that most horses sent to slaughter are not bred by “horse meat producers” but sent to auctions or sold to kill buyers by their former owners after a life of service to humans as racehorses, children’s ponies, trail horses, PMU mares, etc. Should the food chain be a dumping ground for non-food animals? The EID only asks the preparer of the form to declare drugs used on the horse “to the best of their recollection” in the last six months. We also know that horses sold to kill buyers at auction are not owned for six months, as they are typically driven directly from the auction (often in the US) to one of several slaughterhouses in Alberta and Quebec. Once again, any form that only asks for voluntary declaration of drugs is unlikely to be complied with when the seller wishes to dispose of the horse for profit.
Banned drugs have no place in the food chain, not after 180 days, not ever. In a survey, 96% of respondents said they used nonsteroidal anti-inflammatory drugs (NSAIDs) to control the joint pain and inflammation in horses, and 82% administer them without always consulting their veterinarian. More than 1,400 horse owners and trainers were surveyed to better understand attitudes toward NSAIDs. Additionally, 99 percent of horses that raced California last year raced on phenylbutazone, according to Daily Racing Form.
In addition to enforcing these regulations, the Canadian Food Inspection Agency also conducts regular reviews and examinations of meat production facilities across the country to verify that they comply with Canadian law, as well as random testing of meat under the National Chemical Residue Monitoring Program.
By their own admission in Order Papers and Access-to-Information documents, the CFIA tests less than 1% of all horsemeat for the presence of drugs. A review of the latest reports for the National Chemical Residue Monitoring Program reveal that a very tiny number of samples, hardly representative of the number of equines slaughtered, are taken. It took investigations from W-5, the Toronto Star and a Global News 16×9 investigation to uncover gaps in regulation that have allowed banned drugs unfit for human consumption into the food chain. A private investigation also uncovered a far-reaching food fraud in Montreal where horsemeat has been widely substituted for other meats. What has the CFIA done to prevent not only the fraud but ensuring that people are not being poisoned by drugs in a species of meat that they did not intend to purchase or ingest?
Similarly, countries that import Canadian horse meat conduct their own inspections, and the low rate of detection of unacceptable residue levels in Canadian horse meat demonstrates continuing improvement in consumer health protection, both here and abroad.
Yes, and in 2012, two years after the EID system was introduced, European regulators announced a shipment of Canadian horse meat tested positive for Phenylbutazone and Clenbuterol. Harm is assumed. The EU Banned horsemeat from Mexico, the source for which is virtually identical to that of Canadian exported horsemeat – comprised of approximately 60-65% American animals.
In conclusion, this is a barbaric, unsafe, discredited business – one giant trash heap of cruelty and drugged meat. It’s also a facade of false and incomplete paperwork, concealing incompetence and often outright deceit at the highest levels. Science SHOULD inform politics, but unfortunately, that doesn’t often happen. Furthermore, the “precautionary principle” is recognized in international law, and it of course stresses that the absence of scientific certainty about a risk should not bar the taking of precautionary measures in the face of possible irreversible harm.
While you are writing a response to your MP, please sign and share the following e-petitions:
- Petition to amend the Health of Animals Act and the Meat Inspection Act, thus prohibiting the importation or exportation of horses for slaughter for human consumption, as well as horsemeat products for human consumption.
- Petition to update animal transport regulations