Our federal government takes issues of animal welfare seriously, and is currently in the beginning stages of proposing amendments to strengthen the Health of Animals Regulations. The current regulations were developed in 1977, and few amendments have been made since then. For that reason, there is a clear and substantive need to update the regulations. The proposed amendments are the product of ten years of consultation with industry, the public and special interest groups. This consultation process was based on a commitment to evidence-based policy and to ensuring that the proposed amendments improve, update, and strengthen protection for animals
The Canadian Food Inspection Agency (CFIA) is seeking public comment on proposed amendments to the Health of Animals Regulations: Part XII which deals with humane transportation. The proposed draft amendments first appeared in the Canada Gazette, Part I on December 3, 2016 and the public comment period will run until February 15, 2017. This is an opportunity for Canadians to share their views on the transportation of animals. If you are interested in reviewing or providing your comments on the proposed regulations, you may do so by visiting this website: http://www.gazette.gc.ca/rp-pr/p1/2016/2016-12-03/html/reg2-eng.php
Vol. 150, No. 49 — December 3, 2016
Regulations Amending the Health of Animals Regulations
Health of Animals Act
Canadian Food Inspection Agency
(This statement is not part of the Regulations.)
Issues: The current provisions of the Health of Animals Regulations (HAR or the Regulations) dealing with the transportation of animals do not reflect current science regarding the care and handling of animals, do not align with the standards of Canada’s international trading partners, and are not aligned with the World Organisation for Animal Health (OIE) welfare standards for animals transported by land, air, and sea. This leads to a continuing risk that animals will suffer during transportation.
Description: The HAR would be amended to
- Provide clarification by adding definitions (for example definitions for compromised and unfit animals) and establishing clear requirements for regulated parties to better understand what is expected of them;
- Improve animal welfare and reduce risk of suffering during transportation by establishing clear and science-informed requirements that better reflect animals’ needs and current industry practices;
- Better align with the standards of Canada’s international trading partners and the OIE animal welfare standards for animals transported by land, air, and sea; and
- Remove obsolete or unnecessary requirements to reduce the burden on the industry.
Cost-benefit statement: It is anticipated that a small portion of commercial carriers that transport animals by land would bear additional costs, as an estimated 98% of all shipments are already in compliance with the proposed amendments. Some processors in the poultry industry may experience incremental costs associated with changes in management practices, but will realize cost savings in relation to the benefits resulting from these changes. The present value of the total industry costs is estimated to be approximately $3.9 million.
In addition to improving animal welfare, the proposed amendments would reduce transport losses and improve marketability and product quality, leading to benefits for consumers.
“One-for-One” Rule and small business lens: The “One-for-One” Rule would apply to the proposed amendments. The total administrative cost increase is estimated to have an annualized value of approximately $320,000. The small business lens would also apply. The total cost savings of the flexible option for small business is estimated to have an annualized value of approximately $87,000.
Domestic and international coordination and co-operation: Protecting animal welfare in Canada is a shared responsibility between federal, provincial and territorial governments, producers, transporters, processors, retailers, and many other stakeholders.
The proposed amendments to the HAR would significantly improve alignment with the OIE animal welfare standards for animals transported by land, air and sea. Furthermore, based on a comparative review conducted by the Canadian Food Inspection Agency (CFIA), the proposals respecting feed, water and rest would align Canada’s regulatory outcomes more closely with those of its trading partners, such as New Zealand, Australia, the United States, and the European Union (EU).
Animals are valued by people for social, cultural, economic and emotional reasons. They provide food, fibre, and companionship; are used in sport, recreation, education, and scientific study; and have increasing importance as aesthetic assets in their own right.
Canadians strongly support animal-handling processes that allow animals to express normal behaviours and do not result in animal pain, injury, or ill health. (see footnote 1) Good animal welfare practices contribute to reduced food safety risks and increased environmental sustainability by reducing the risk of disease. (see footnote 2) Similarly, poor animal welfare practices can contribute to economic losses. (see footnote 3)
The transportation of animals in Canada is a complex and wide-ranging activity carried out by a diverse set of stakeholders. Humane transportation of animals is a shared responsibility between several partners, including owners, producers, buyers, sellers, auction markets, assembly points, abattoirs, and transporters. Businesses range from small operators that move one animal to vertically integrated systems that transport multiple animals over short and long distances. It is estimated that 700 million animals are transported per year in Canada.
Transportation is an unfamiliar event for animals that can cause significant anxiety. (see footnote 4) Poor welfare leads to increased physiological and psychological stress, which in turn can lead to increased susceptibility to disease among animals and increased shedding of pathogens due to increased intestinal motility. This poses a risk to human and animal health. (see footnote 5)
Animals are transported, sometimes for long distances, for many reasons, including breeding, shows, feeding, sale, and slaughter. The continual consolidation of growing and finishing operations in the Canadian agriculture sector, as well as processing plants, has contributed to an increase in the distances animals are transported to reach production points. For example, the number of federal facilities processing beef decreased from 400 in 1976 to 30 in 2015. Similar consolidation has occurred at the farm level. For example, the number of farms decreased by 45.8% between 1976 and 2001. (see footnote 6)
Due to these increased distances, animals may be loaded and unloaded multiple times, over prolonged periods, and can be exposed to adverse environmental conditions such as excessive heat, cold, snow, and rain. The equipment used to transport animals is similarly varied, ranging from home-made trailers to commercial stock liners to containerized jumbo jets and specialized ships.
Part XII (Transportation of Animals) of the Health of Animals Regulations (HAR), which was first passed into law in 1977 pursuant to the authorities of the Health of Animals Act (the Act), regulates animal transportation, including the loading and unloading of animals within Canada as well as entering into or leaving Canada, by imposing requirements on those individuals involved in the transportation of animals and setting out prohibitions to address the welfare (humane treatment) of animals during transportation.
Part XII of the HAR was enacted to address animal welfare problems encountered during the long distance transport of cattle by rail. At the time, there was little research or information pertaining to the effects or risks of transportation on the well-being of animals. The provisions of the HAR were consequently written in general terms, using words such as “undue” as it applies to suffering, to qualify prohibitions. This can lead to inappropriate decisions, such as loading animals deemed unfit for transportation or loading compromised animals for transportation over long distances without special measures. This, in turn, may increase the risk of animal welfare issues.
By extrapolating from the rate of compliance in inspection data, it can be estimated that 2% of all shipments of animals being transported in Canada are not in compliance with the current regulatory requirements. This represents an estimated 14 million animals per year that may be suffering during transportation, of which 1.59 million animals per year are reported as dead on arrival at their final destination. Given the strong public support for preventing the suffering of animals, and the risk to human and animal health, this must be addressed.
More recent scientific evidence shows that transportation can be one of the most stressful experiences for animals, when animal welfare is not taken into account and addressed. (see footnote 7) The HAR do not reflect current science regarding the care and handling of animals, and frequently do not take the physical, behavioural, and physiological needs of animals into consideration. In addition, the HAR do not consistently align with current, generally accepted industry practices. The joint industry– government National Farm Animal Care Council (NFACC) develops codes of practice, which are nationally developed guidelines for the care and handling of farm animals. A code of practice for the transportation of farm animals was released in 2001. While the transportation code of practice considered the current requirements of the HAR when it was drafted, the recommendations in more recent codes of practice for the care and handling of farm animals meet, and in certain circumstances exceed, the requirements of the HAR.
Finally, the HAR do not consistently meet the standards of Canada’s international trading partners, such as the United States and the European Union (EU), and are not adequately aligned with the World Organisation for Animal Health (OIE) welfare standards for animals transported by land, air and sea. As a member country of the OIE, Canada is expected to meet or exceed OIE standards. This lack of alignment could compromise market access for Canadian products in the future. For example, a recent European survey concluded that 93% of Europeans agree it is important to establish animal welfare standards that apply to products sourced from within and outside of the EU. (see footnote 8)
The proposed amendments to the HAR would
- Move towards a more outcome-based regulatory framework (for example replacing the requirement for a plane to “provide a change of air not less than once every five minutes” with a requirement to provide “adequate ventilation
Cornelius Kiley’s team
|Daniel Schwartz||Veterinarian – Biosecurity Specialist||604-541-5950||17735 1st Avenue, Room 175||Surrey||British Columbia||Canada|
|Geneviève Bénard||Transportation of Animals Program Specialist||613-773-7436||59 Camelot Drive, Floor 3 E, Room 234||Ottawa||Ontario||Canada|
|Lorne Jordan||Chief Biosecurity Specialist||613-773-7257||59 Camelot Drive, Floor 3E, Room 232||Ottawa||Ontario||Canada|
|Michelle Groleau||Veterinarian – Humane Animal Transport||613-773-7439||59 Camelot Drive, Floor 3 E, Room 233||Ottawa||Ontario||Canada|
|Patricia Pentney||Veterinary Inspector||905-937-9147||9, 350 St Catharines 13||St Catharines||Ontario||Canada|