According to its website, the European Commission’s Directorate-General for Health and Food Safety (DG SANTE) is responsible for the implementation of European Union laws on the safety of food and other products, on consumers’ rights and on the protection of people’s health. It conducts audits, inspections and related non-audit activities for both EU and non-EU countries aimed at ensuring that EU legislation on food and feed safety, animal health, animal welfare, plant health and in the area of medical devices is properly implemented and enforced.
From September 10 to September 24, 2018 an audit was undertaken to evaluate Canadian control systems in place governing the production of horse and game meat intended for export to the European Union.
The report has been released and identifies a number of concerns, most notably the unreliability of the Equine Information Document (EID) which must accompany each horse presented for slaughter.
The audit team comprised two auditors and was accompanied during the audit by representatives from the Central Competent Authority (CCA), the Canadian Food Inspection Agency (CFIA), representatives of the regional CFIA offices, and by officials of the provincial authorities.
In terms of scope, the audit included the verification of controls over veterinary residues and veterinary medicinal products (VMP) in relation to live horses and horsemeat.
The following sites were visited:
Certain issues in relation to the reliability of the controls over both imported and domestic horses whose meat is destined for export to the EU are described, with the exception of horses kept in feedlots for a minimum of six months. “The system does not provide full guarantees that horses have not been treated with illegal substances within the last 180 days before slaughter, or that the withdrawal periods of VMPs (Veterinary Medical Product) had been respected. The official follow-up of non-compliant results is limited: whilst the CA puts the responsibility for corrective actions and follow-up of non-compliances largely on the shoulders of the slaughterhouses, it does not carry out inspections of holdings keeping horses to verify and ensure the effective implementation of corrective actions. The CA’s action is, in this regard, hampered by a lack of direct powers over primary producers, and transient agents. The same finding was noted during the 2014 audit”.
However, the CFIA “is of the view that a reliable system is in place for EID’s accompanying horses to slaughter to be reliable and correctly record the VMP status of the animal”.
In response to the 2014 audit, the Central Competent Authority (CCA) stated that they will work with the horse industry to strengthen the ways and the means of ensuring that animal identification and treatments records are credible and complete for these 180 days before slaughter. The audit found “the work of the CFIA done together with the horse industry to strengthen the system has not resulted in tangible actions: tests carried out by one Food Business Operator (FBO) met during the audit demonstrate that EIDs are not always reliable and do not always correctly record the VMP status of the relevant animal”.
The CFIA reports 344 horses were tested in the 2017-2018 sampling year under the National Chemical Residue Program (NCRMP) with each animal tested for roughly 100 different residues. It reports six violations were found in nearly 37,000 individual results resulting in a compliance rate of over 99%. However, it should be noted that as the total number of horses slaughtered in Canada has been unavailable since 2017, it is unclear what percentage were actually tested.
From Page 22 of the Audit Report Concerning Banned Substance Phenylbutazone:
107. Health Canada has published a list of VMPs being used in horses (for instance, various formulations of phenylbutazone, estradiol and anthelmintics contain a warning on the label and/or package insert “not to be used in horses for food production”), and a list of VMPs considered essential medicines. The Health Canada website also indicates the withdrawal periods for most of them, as well as national MRLs for pharmacologically active substances.
111. Whilst in the EU horses are food producing animals until and unless they have been signed out of the food chain, in Canada horses are by default not considered to be food producing animals until they have been designated for this purpose.
From page 20 of the Audit Report:
The CHDC is encouraged by the diligence of the European Commission (EC) to ensure compliance is met in Canadian slaughter plants. However it is quite troubling to confirm that shortcomings continue to befall the CFIA when it comes to meeting food safety regulations set out by the EC.
The six-month drug-withdrawal rule for equines to reside in the country in which they’re to be slaughtered still does not address the CFIA’s own regulation that equines that have been administered phenylbutazone (amongst other medications) are not to be sent to slaughter.
In addition to traceability, there’s an important point to mention regarding horse health while residing on equine feedlots. Horses with compromised health and dying horses are prone to parasites that can infect humans. Not only is horse health a major welfare concern on equine feedlots, the auditors appear to overlook the risk to humans from compromised and dying horses with parasites raised on these massive, highly populated feedlots.
Also, the report is disappointing from an animal welfare perspective. EC auditors are obliged to assess animal welfare at the slaughterhouses, and only a very short section addresses this:
Horse holding pens situated next to, and owned and managed by slaughterhouses, should be considered as field lairages, according to the European Union’s Council Regulation (EC) No. 1099/2009 – On the Protection of Animals at the Time of Killing dated September 24, 2009.
According to Article 2.6 of Annex II of Regulation 1099/2009 – Layout, Construction and Equipment of Slaughterhouses:
However, it appears the audit team did not inspect the outdoor holding pens at the Bouvry slaughterhouse, otherwise they would have noticed the complete lack of shelter from the elements.
The EC’s tightening of regulations were first implemented in 2010. Almost 10 years later, Canada continues to fall short on its obligations to meet EC requirements. Even with only two equine slaughterhouses left, owned by one family, we still cannot – and will not – meet the standards. This is simply because horses in North America are not raised for human consumption. As long as traceability is a requirement, we will remain non-compliant according to EC standards.
The report may be read in its entirety here.
All photos included in this document were taken in September 2018 at the Bouvry-owned Granum Feedlot in Alberta where American horses are held for slaughter.