The Canadian Food Inspection Agency (CFIA) has finally released its proposed amendments to the Health of Animals Act Regulations, which govern farmed animal transportation in Canada.
As a biologist and former investigator who has documented animal transport in Canada for over a decade, I am deeply dismayed. In the preamble to the proposed regulations, animals are spoken of as commodities, rather than the living, sentient beings they are. An extensive discussion regarding the potential costs to producers and haulers is also oddly included. These costs should be viewed as secondary to the welfare of the animals being transported, particularly by the agency charged with the enforcement of those regulations.
Animal advocacy organizations, including Canadians for Ethical Treatment of Farmed Animals (CETFA), have been raising serious concerns over animal transport in Canada for decades only to have those concerns summarily dismissed by the CFIA. Many investigations have also clearly implicated CFIA veterinarians and inspectors in animal abuse, yet these violations too have been ignored.
The agency's dismissal however always came with the assurance that amendments to the Health of Animals Act were imminent. With such assurances, we would be led to believe the amendments would be progressive and based on current science, as well as existing legislation in Europe. Sadly, neither has turned out to be the case.
None of these requirements has been met in the CFIA's proposed amendments.
Europe updated its animal transport regulations back in 2004 -- 13 years ago. Their regulations outline clear, specific rules based on animal behaviour and biological needs, rather than financial considerations. The regulations in Europe are also actually enforced through effective, proportionate and dissuasive sanctions.
Contrary to the agency's assurance that the new regulations will bring Canada into alignment with European standards, they won't even come close. In Europe, regulations require that all animals who are transported longer than eight hours must be loaded onto trucks equipped with automatic water troughs and fans; that trailers must have tachographs which record the length of time a vehicle is in motion; and that strict loading density requirements be met to ensure all animals are able to stand up and lie down in their natural positions. European regulations also prohibit the transport of animals below and above specific temperatures and require temperature monitors on trucks. None of these requirements has been met in the CFIA's proposed amendments.
Of additional concern is that the proposed amendments specifically allow compromised animals (including those who are blind in both eyes, bleeding from an operation, or heavily lactating) to be transported for up to 12 hours. Previously, sick or injured animals could not be transported if it was expected to cause undue or additional suffering. In this regard, the amendments are actually worse than the existing antiquated legislation.
"Boar bashing" (the beating of boars' snouts with crude implements such as crowbars or baseball bats) and "tooth-breaking" (snapping off the animals' innervated tusks with bolt cutters) have also not been addressed and no regulations have been outlined against either practice. In Europe, boars must be segregated during transport to avoid the blatant cruelty that both bashing of boars and breaking of their teeth entail.
Trailers carrying animals also continue to not be given priority at border crossings, affecting an estimated 2.5 million pigs each week who are shipped to the United States to be slaughtered. This is particularly a problem in the summer months when temperatures inside stationary trucks can quickly reach 40 to 50 degrees Celsius. This, combined with high ammonia levels, can cause death by suffocation.
Perhaps most importantly, the amendments fail to cover actual enforcement of the regulations.
Electric prods also continue to be allowed. Other violent handling practices, such as the lifting of animals by their legs, wings, head and horns, continue to be allowed while European standards prohibit all of these.
The regulations also fail to mention in-transit mortality insurance -- insurance coverage available to Canadian haulers. The insurance awards drivers for loading severely health-compromised animals expected to die en route. Because this insurance promotes blatant cruelty, it has been forbidden in Europe.
And finally and perhaps most importantly, the amendments fail to cover actual enforcement of the regulations. With investigations exposing the involvement of CFIA veterinarians and inspectors in transport violations (when they do actually inspect trailers), along with CETFA's own experience of hearing from CFIA whistleblowers concerning pressure from upper and middle management to comply with industry bullying and drop cruelty investigations, we expected this to be a priority for the CFIA.
It is as though those who drafted the amendments have not ever been in the field or seen any of the evidence we and other animal advocacy organizations have provided over the years of the rampant cruelty inherent in Canada's animal transportation system.
If these amendments represent how the federal agency charged with the protection of sentient, vulnerable beings actually views those beings, we finally have an explanation for why it repeatedly failed to do its job and take action on horrific cases of cruelty. Financial interests should never supersede scientific knowledge, basic ethics and common decency.
The CFIA is accepting comments on the proposed amendments until February 15, 2017. Please take a moment to email yours to Dr. Cornelius F. Kiley. Thank you.
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