Dr. Maureen Harper is a veterinarian who worked for the Canadian Food Inspection Agency (CFIA) for 30 years. Prior to retirement in 2011, Dr. Harper was acting program officer responsible for the delivery of the animal transport program in Ontario. The following article, Legalized cruelty: the gaps in Canada’s animal transport laws, was written by Dr. Harper and appeared in iPolitics.ca on May 27, 2017.
From the article:
“The greatness of a nation and its moral progress can be judged by the way it animals are treated.” — Mahatma Gandhi
“I am writing to express my concerns about the newly proposed amendments to the Health of Animals Transport Regulations. In my view — as a veterinarian who worked for the Canadian Food Inspection Agency (CFIA) for 30 years — the newly proposed regulations do not go far enough in protecting the welfare of animals being transported in Canada.
It has been about 40 years since the federal animal transport regulations have been updated. In that time, current scientific literature and public opinion about animals have changed dramatically. Estimates by the Canadian Food Inspection Agency (CFIA) state that approximately 14 million animals suffer injuries during transportation annually in Canada and almost 1.6 million are reported dead on arrival each year.
In my opinion, Canada has the worst animal transport regulations amongst developed nations. This is based on current allowable maximum transport times for all animals. And unfortunately, the proposed changes will still leave Canada in this unenviable position. Canadians expect far more of their government with respect to protection of animal welfare, and our animals deserve far better.
A recent court case in Ontario, concerning a woman providing water to what appeared to be a very distressed pig being transported to an abattoir, has highlighted the plight of many animals being transported in this country. Although the woman was acquitted of obstructing or interfering with the lawful use of property, the case serves to demonstrate the need for stricter animal transport legislation.
I believe that it is incumbent on the CFIA to further reduce the permitted transport times allowed for all species of animals. It appears that the CFIA is trying to appease industry by not lowering the maximum allowed transport times any further than they did in the newly proposed amendments. In fact, the CFIA has stated in its own impact statement, provided with the newly proposed regulations, that 98 per cent of current shipments of animals would not be affected by the newly proposed allowable transport times.
Current science supports the lowest possible transport times for all animals. The CFIA has admitted that the maximum permitted transport times for spent hens (birds used as egg layers that no longer are able to produce eggs) was first proposed to be reduced from 36 hours to 12 hours. However, apparently industry applied pressure on the CFIA to have that time increased to 24 hours.
“The CFIA is permitting draft horses to be shipped by air to Japan, for slaughter, in containers that are in violation of the current regulations.”
In my view, this is not acceptable. Spent hens are very old and very fragile birds which are often barely feathered and, as a result of being transported for long periods, they can suffer greatly from exposure to the elements. This can result in shipments with as high as 50 per cent of the birds dead on arrival. I was
Here’s another serious concern I have with the proposed regulations. The current legislation is prescriptive in nature, requiring segregation of animals by species and based on the ages and weight of the animals. The proposed regulations will be outcome-based, allowing for animals to be transported based solely on predicted compatibility of the animals so as not to cause death or injury during transportation.
In my experience, it can be extremely difficult to predict the compatibility of animals prior to them being transported. There are no prescribed measures for loading densities of animals, required ventilation, temperature, etc. Outcome-based regulations serve to allow industry more leeway and make it very difficult for the CFIA to admonish the parties responsible for injuries and deaths of animals being transported. Voluntary codes of practice exist (e.g., those from the National Farm Animal Care Council) and that these should be incorporated in newly proposed regulations. That would go a long way toward improving the current legislation and, in the process, provide for more humane methods of transporting animals.
Another issue of concern with the proposed amendments is the allowance for movement of compromised animals for up to 12 hours. This is not permitted under the current legislation. In my view, sick and injured animals should not be moved except, as required, to the closest place for treatment.
As mentioned, there are no requirements in the proposed regulations for temperature and ventilation measurements in enclosed conveyances transporting animals. In the absence of such requirements, there are no prescribed maximum and minimum permitted temperature requirements for transporting animals. There is much scientific literature supporting the need for this.
Finally, I am most concerned that the CFIA is not enforcing the current Health of Animals Animal Transport Regulations. The CFIA is permitting draft horses to be shipped by air to Japan, for slaughter, in containers that are in violation of the current regulations. Horses over 14 hands are currently required to be segregated and the containers are required to be built high enough to ensure that the tops of the heads of the horses do not come in contact with the tops of the containers. Neither of these requirements is being enforced.
The current regulations are in place to ensure safe and humane shipments of these large horses by air. But sadly, there are documented cases of death and injury of horses in these shipments. Interestingly, the CFIA has proposed to remove these two requirements in the new legislation. I do not believe that this is a wise decision on the part of the CFIA.
I would encourage the CFIA to carefully consider the changes that they have proposed to the federal animal transport regulations. I understand that the Agriculture Committee struck a Transport Study to review the proposed amendments. And although I was not permitted to testify in front of this committee, I was allowed to provide my comments about the new legislation via a written submission.
After waiting 40 years for this new legislation, I believe that it is imperative that the government gets this right. The welfare of our animals is dependent on it, as is the credibility of Canada as a nation.”
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