Animals >
Humane Transport
Nonambulatory livestock transport:
The need for consensus
Gordon Doonan, Martin Appelt, Alena Corbin
Canadian Food Inspection Agency, 59 Camelot Drive, Ottawa, Ontario K1A 0Y9.
The following article was published in the Canadian Veterinary Journal in
August 2003 and is presented on the CFIA Web site with the kind permission of the
Journal's editor.
Address all correspondence and reprint requests to Dr. Gordon Doonan; e-mail.
Introduction
The disparity in veterinary recommendations on the fitness of nonambulatory livestock
for transport and other recent information indicate that the growing concern of the
public, the industry, and the veterinary profession about the fate of these animals in
Canada is well founded. Incompatible perceptions among provinces and within each sector,
including the veterinary profession, are apparent. As a profession, veterinarians need a
common understanding of what comprises "fitness for transport" and humane
methods for the handling of compromised livestock. The focus of this article is on making
a decision whether or not such animals should be loaded onto a transport vehicle, and
Canadian veterinarians are invited to provide input to the development of a nationwide
consensus.
Animal welfare issues regarding livestock can be contentious, due to their direct
conflict with economic and competitive pressures. With regard to nonambulatory livestock,
self-regulating bodies are quickly moving ahead of current legislation. Con-sumer opinions
and expectations regarding animal welfare have proven to be a major driving force - so
major that food chains and restaurants have developed animal welfare standards that their
suppliers must meet. Such developments require that Canadian producers keep up with
societal expectations, so that they are not disadvantaged, and consumer confidence in the
Canadian agriculture industry is maintained both at home and abroad. In order to guide the
industry’s approach to meeting consumer demands and to offer the best advice to
producers, veterinarians must be aware of these advancements.
Review of standards and legislation
The Health of Animals Regulations prohibit loading or transport, by air, land,
or water, of an animal that "by reason of infirmity, illness, injury, fatigue, or any
other cause cannot be transported without undue suffering during the expected
journey" (1). This would include a large animal that is unable to stand without
assistance or is unable to move without being dragged or carried. Such animals are
referred to as "nonambulatory" or, more commonly, "downers."
Each province has its own animal health legislation, which may or may not encompass the
humane transportation of animals. While some provinces have made their positions very
clear, most have only broad guidelines in place. The farm veterinarian is left to
interpret these guidelines and make a judgment call. This leads to large discrepancies in
the assessment of identical or very similar cases. Ontario is the only province requiring
veterinary certification of a nonambulatory animal before it is allowed to be loaded (2).
Most provinces allow on-farm slaughter as an alternative way of dealing with nonambulatory
livestock. However, provincial legislation differs as to whether the carcass is restricted
to private consumption. If the carcass can be taken to a processing facility for
postmortem inspection and sale, the financial loss for the producer is less severe.
A peek across our borders illustrates how other countries deal with nonambulatory
livestock.
The European Union allows the transport of animals as long as it does not entail
further suffering of the animals (3). In Britain, animals may not be dragged, pushed, or
lifted, and loading of nonambulatory animals may only commence in the presence of a
veterinarian (4). Germany has gone one step further by listing conditions that make an
animal unfit for transport as part of its Animal Welfare Transportation Order. This order
also mandates veterinary certification for transport and on-farm slaughter for those
animals not found to be fit for such transportation (5).
A United States federal bill, currently under review, makes it unlawful for any
stockyard owner, market agency, or dealer to buy, sell, give, receive, transfer, market,
hold, or drag any nonambulatory livestock unless the nonambulatory livestock has been
humanely euthanized (6). California has incorporated a "Downed Animal Law" as
part of the Penal Code and has prohibited any slaughterhouse not inspected by the United
States Department of Agriculture, stockyard, or auction from buying, selling, or receiving
nonambulatory animals (7). The City of Cincinnati passed an ordinance that bars
transportation or delivery of nonambulatory animals, due to the impossibility of
transporting them humanely (8).
The American Veterinary Medical Association takes the position that animals that are
down, but not in extreme distress, should be treated. Animals in extreme distress should
be slaughtered on-farm or euthanized (9).
The Canadian Veterinary Medical Association’s position statement regarding
nonambulatory livestock states "If the animal is to be moved to a suitable processing
facility, a veterinary inspection of the nonambulatory animal must be performed on the
premises of origin. The animal must be accompanied by an antemortem veterinary certificate
declaring whether the animal can or cannot be humanely loaded, that the animal is fit for
slaughter and that the owner has observed all applicable withdrawal times for drugs used.
The loading and transportation of nonambulatory animals must be performed in a manner to
avoid pain, suffering and distress to the animal and upon arrival at the processing
facility the animal must be humanely stunned or euthanized on the vehicle prior to
unloading. Equipment currently being used includes slide boards and mats, forklifts,
front-end loaders, hand carts, slings, "cow caddys" and stone boats or sleds. In
those situations where the nonambulatory animal is passed for slaughter, but where the
veterinarian deems loading and transportation inhumane, the Canadian Veterinary Medical
Association recommends on-farm slaughter. Nonambulatory animals deemed unfit for slaughter
should be humanely euthanized on-farm and the carcass disposed of in accordance with local
regulations" (10).
Industry stakeholders have introduced their own policies. For example, Burger King
prohibits their United States suppliers from using meat from nonambulatory animal sources
or from actively procuring such animals (11), and the company is in the process of asking
the same standard from its Canadian suppliers. McDonald's Canada prohibits the use of
downer cattle in their raw material specifications (12).
The Animal Welfare Audit Program is a United States national program cooperatively
developed with the National Council of Chain Restaurants, the Food Marketing Institute,
and the producer community. The policy regarding nonambulatory livestock under this
program is identical to the position statement issued by the American Veterinary Medical
Association, with the additional prohibition of dragging or pulling a downer animal by its
extremities (13).
The Canadian Food Inspection Agency is responsible for enforcing the humane
transportation of all animals in accordance with the federal Health of Animals
Regulations (1). The Canadian Food Inspection Agency’s Compromised Animals
Policy provides general guidelines on the evaluation of fitness of compromised animals for
transport and options for the handling of nonambulatory livestock on arrival at federally
inspected slaughter plants.
Through collaboration with stakeholders, the Canadian Agri-Food Research Council has
developed voluntary animal care standards, which are described in the "Recommended
code of practice for the care and handling of farm animals" series. Section 6 of the
transportation code provides advice on the evaluation and handling of animals that are
"at risk" and require special consideration before it is decided whether they
should be loaded for transport. This includes nonambulatory animals (14).
Nonambulatory livestock surveys
In order to quantify the frequency of nonambulatory cattle being transported to
federally inspected slaughter plants and auction markets, the Canadian Food Inspection
Agency conducted a national, nonstatistical survey, focusing on inspection sites at 19
slaughter facilities and 3 auction markets across Canada. These represent only a portion
of all such federally inspected facilities. During the year 2001, 7382 nonambulatory
cattle were observed to arrive at these sites. Of this total, 89.8% were classified as
dairy carcasses, while 10.2% were beef carcasses. The data strongly suggested that the
vast majority of nonambulatory animals originate on-farm, with less than 1% becoming
nonambulatory in transit or accidentally. Inspection led to carcass condemnation in 37% of
nonambulatory dairy animals.
A similar survey concentrating on slaughter hogs and cull sows is in progress.
Discussion
Arguably, the most important step in reducing the numbers of disabled livestock is
on-farm prevention through training, proper facilities, and good husbandry. Several
national and provincial industry groups have prepared guidelines regarding the prevention
of animals from becoming nonambulatory or for helping the producer to assess a downer
animal. In 2002, Alberta Pork, the Alberta Farm Animal Care Association, the Alberta
Veterinary Medical Association, the Alberta Society for the Prevention of Cruelty to
Animals, and Alberta Quality Pork produced a booklet entitled "Humane Handling of
Swine - Standards for the Care of Unfit Animals." Ontario Pork launched a new
"Caring for Compromised Pigs" booklet and the decision tree "Should this
pig be transported?" in 2003, and the Ontario Humane Transport Working Group
developed a decision tree for the transport of compromised cattle, sheep, and goats.
At the same time, due to the wide variety of causes for downers, a certain number of
individual animals will continue to become nonambulatory. So the issue of dealing with
these cases in a manner that is compatible with federal and provincial legislation, with
the economic considerations of both producer and abattoir and with Canadian public
expectations, has to be addressed.
At the very core of this discussion stands the finding of the Canadian Food Inspection
Agency survey that nearly 4 out of 10 nonambulatory dairy cows could not be passed for
human consumption at the meat plant. Considering the extra time and labour involved from
initial loading through to processing at the slaughter plant, industry must ask whether it
really pays to ship, transport, and accept these animals. The answer is probably
"no", especially when condemnation is a likely out-come. It seems that
"economic pressure" is a weak argument for subjecting a sizeable portion of
downer animals to the additional stress of transportation.
While the Canadian Food Inspection Agency’s findings are based upon data collected
nationwide, there are limitations to the study; but it is safe to say that the numbers do
justify the need to address this issue further. The results have revealed inconsistent
standards on all levels - from governments to individual veterinarians - in respect to the
humane transportation of downer animals.
The matter of inconsistency should be a concern for the veterinary profession. The need
for information is apparent: A report issued by Alberta Milk and Alberta Farm Animal Care
in May 2002 showed that producers estimated that their cull dairy cows would be
slaughtered within 1.5 to 24 h after shipping (15). In fact, the collecting of full
truckloads of cull cows meant that the cows could spend up to 3 wk in transit before they
arrived at a plant (15). These facts have to be known in order to make an informed
decision on whether a particular animal should be shipped, or better slaughtered or
destroyed on the farm.
Slaughter plants have no interest in dealing with animals that should not have entered
marketing channels in the first place. Growing numbers of federal and provincial slaughter
plants are refusing to handle "downers." Several federal plants now charge a
small fee to put these animals down. The marketing of livestock compromised by disease or
injury degrades the welfare of the animal; is an economic burden to the producer, the
transporter, and the processor; damages the prestige of the livestock production industry;
and potentially endangers public health. The veterinary profession and the agricultural
industry nationwide should arrive at the same conclusion regarding the transportation of
nonambulatory animals. It is simply impossible to move mature nonambulatory livestock
humanely, no matter how close the slaughter plant. Early treatment, on-farm slaughter, or
euthanasia should be the course of action to deal with these animals. Alberta proves that
this approach is feasible, as over 80 mobile slaughter units are currently licensed and in
operation.
Conclusion
Most often, producers ship nonambulatory livestock because they see no alternative - be
it due to provincial restrictions, lack of inspectors, or missing infrastructure.
Veterinarians have a professional responsibility to educate producers in the prevention,
proper care, handling, and humane disposition of the nonambulatory animal. The veterinary
profession needs to take the lead in developing uniformity across Canada, in concert with
the Canadian livestock industry and other stakeholders.
Ideally, a consenting view of the veterinary profession will lead to a national policy
that gives Canada a credible and respected humane transportation and compliance system for
dealing with nonambulatory livestock.
Your participation
The Canadian Food Inspection Agency is planning stakeholder consultations for the fall
of 2003. Your comments on this article are welcomed and encouraged. They will help to
shape the recommendations given during the upcoming consultations. Please direct your
comments to Dr. Gordon Doonan at the postal address listed at the beginning of the
article, or by e-mail to gdoonan@inspection.gc.ca.
Please use "nonambulatory" as your subject line!
References
All electronic references were accessed and verified on June 4, 2003.
Government of Canada. Health of Animals Regulations. SOR/91-525, Canada
Gazette PC 1998-2146, December 3, 1998. Canadian Government Publishing, Communication
Canada, Ottawa, Ontario K1A 0S9, http://canadagazette.gc.ca/index-e.html
Government
of Ontario, Regulation 732/94 Transporting Non-Ambulatory Animals, Queen’s
Printer for Ontario, Publications Ontario, 50 Grosvenor Street, Toronto, Ontario M7A 1N8,
http://www.e-laws.gov.on.ca
Council of the European Union, Council Directive 91/628 on the protection
of animals during transport, November 19, 1991 in its corrected, amended form from October
10, 1997. Advanced Information Databases Inc., 361 Dundas Street, PO Box 248, N4S 7W8
Woodstock, Ontario.
The United Kingdom Parliament, 1997 No. 1480 The Welfare of Animals
(Transport) Order 1997, Queen’s Printer of Acts of Parliaments, July 1, 1997. TSO, PO
Box 29, St Crispins, Duke Street, Norwich NR3 1GN, United Kingdom.
Bundesministerium fuer Ernaehrung, Landwirtschaft und
Forsten, Tierschutztransportverordnung, 11.Juni 1999. (German Federal Ministry
of Nutrition, Agriculture and Forestry, Animal Transportation Order, June 11, 1999). Bundesministerium für Verbraucherschutz, Ernährung und Landwirtschaft
Referat Õffentlichkeitsarbeit, D-53107 Bonn, Germany.
Senate
of the United States, Bill S.267 to amend the Packers and Stockyards Act of 1921,
107th Congress, 1st Session, 2001. http://www.gpoaccess.gov/bills/index.html
Government
of California, Penal Code of January 1, 1873 in its current form, section 599(f),
http://www.leginfo.ca.gov/
City
of Cincinnati Code of Ordinances, §§ 701-3. Transporting Downed Animal Prohibited,
ordained by Ord. No. 206-1997, Eff. July 18, 1997. http://www.cincinnati-oh.gov/
American
Veterinary Medical Association, Position Statement Disabled Livestock, July 15, 2002.
http://canadianveterinarians.net/publications-informations-position-animal.aspx
Canadian
Veterinary Medical Association, Animal Welfare Position Statement Non-Ambulatory
Animals, November 2000. http://www.cvma-acmv.org/welfare.asp
BKC
Animal Handling Policy, Status of Animal Handling Practices,
http://www.burgerking.com/CompanyInfo/public_policies/
McDonald’s
Restaurants of Canada Ltd., Corporate Social Responsibility, Canadian Fact Sheet,
April 15, 2002, p. 4. http://www.mcdonalds.ca/en/community/animal_principles.aspx
Food
Marketing Institute and National Council of Chain Restaurants, January 2003 Report, FMI-NCCR
Animal Welfare Program. http://fmi.org/animal_welfare/013103rpt.pdf
Canadian
Agri-Food Research Council, Recommended code of practice for the care and handling of
farm animals - Transportation, 2001.
http://www.carc-crac.ca/english/codes_of_practice/index.htm
Alberta Milk and Alberta Farm Animal Care Association, A Report on the
Handling of Cull Dairy Cows in Alberta, May 2002. AFAC, Cambrian, PO Box 75028, Calgary,
Alberta, T2K 6J8.
|
