In a recent blog post, the CHDC alerted its readers to the CFIA’s intention to modify the Health of Animals Regulations so that they are aligned with the National Farm Animal Care Council Codes and regulations of our international trading partners. The CFIA requested that stakeholders and interested parties direct questions and comments to:
Dr. Cornelius F. Kiley
Animal Welfare, Biosecurity and Assurance Programs Section
Canadian Food Inspection Agency
59 Camelot Drive
3rd Floor West, Room 231
(By submitting representations, interested persons consent to having their representations posted on the CFIA’s website).
Here is a sample letter from an advocate that you can use as a template for your own letter:
Attention: Dr Cornelius F. Kiley, Canadian Food Inspection Agency
I am writing to comment on the following: Amendments to Part XII of the Health of Animals Regulations, which pertain to the transport of animals, are now in the public comment phase in the Canada Gazette, Part I, Vol. 150, No. 49.
There are a number of concerns with the proposed regulations. Firstly no provisions have been made to prevent transport of animals in weather extremes. In Europe, transportation of animals is not allowed in weather extremes and trucks have to be temperature controlled. They are required to have on board ventilation systems. The proposed regulations do not deal with the issue of temperature extremes in Canada, and the kind of conditions (extreme Canadian cold and heat) that it is inhumane to transport animals in.
Secondly, the length of time of animal transports is still a concern. While there has been a proposed reduction in the times animals can be transported without food and water, it is still 28 hours in the case of horses and pigs. Considering the clock is re-set to zero when shipments of animals leave Canadian borders, slightly reduced Canadian traveling times will not make any difference to the actual traveling times between countries. For example , there will still be horse shipments to Japan from Alberta that are approximately 30 hours long from the time of loading at feedlots until arrival and unloading in Japan (longer if there are flight delays). Numerous studies have shown that horse health and welfare deteriorates significantly after 8 – 12 hours of travel without rest (for example the European Scientific Committee on Animal Health and Welfare (SCAHAW) and Stevenson: ”Long Distance Animal Transport in Europe. A cruel and unnecessary trade”– 2008).
Another concern with the live draft horse shipments is that horses are not being segregated currently, and I believe under the new regulations there will no longer be any requirement to segregate horses over 14 hands high. According to veterinarians, this practice of loading multiple horses into crates, while obviously cost effective and financially beneficial to the exporter, is detrimental to horse welfare in airplanes. From FOIP/Access-To-Information documents it is apparent that horses in the live shipments frequently go down during takeoff and landing, and with multiple horses in crates there is greater potential for injury if they are not segregated or no divider is used.
Another regulation that should be kept, not eliminated, in the horse shipments is the regulation requiring sufficient head space for horses, especially considering the fact that they will be standing in one position in the same wooden crate for approximately 24 hours (from the time they are first loaded into the crates until they are unloaded in Japan). It would be inhumane to have the heads of taller horses bent in unnatural position the entire 24 hours.
I am unclear as to how things will be improved for animals with the new transport regulations, and in fact with proposed removal of some of the existing regulations (segregation and head clearance) designed to protect horses during live horse shipments to Japan, the situation could become even worse for these animals. If Canada is going to make changes to animal transport laws, please ensure that they make significant improvements to animal welfare instead of maximized profits for exporters and producers.