Thank you for giving me the opportunity to present to the committee.
Most of you know who CFA is and who we represent, so I don't think there's a lot of use in going through that explanation, but I would say that CFA represents all agricultural producers, because of the membership we have.
I'll be speaking to some high-level concerns and recommendations that Canadian producers have, and I encourage you to continue to reach out to commodity-specific organizations on how these proposed regulations would affect individual species. They are better informed to provide specific examples from within their industry and to address some of the species-specific concerns and requirements set out within the proposed regulations.
Overall, the transport of farm animals is an area in which Canadian producers have a very strong interest in maintaining high care standards. The thorough and hard work accomplished through the National Farm Animal Care Council, of which CFA is a member, continues to play a strong role in providing sound scientific guidance for the best practices of assuring animal care outcomes for producers and during transport.
The National Farm Animal Care Council brings together producers, the value chain, animal welfare scientists, and NGOs with an interest in farm animal care to collaboratively develop codes of practice for the industry to follow. These multi-stakeholder approaches provide the best process for developing the needed authoritative guidance to a continuous improvement approach to animal care.
There's no doubt that maintaining high standards of care during transportation is a matter of public trust and something that the industry has come under scrutiny for in the past. From the producer's perspective, poor animal care outcomes during transport open up the industry to increased public criticism, the likelihood of increased regulation, and also a lower price received due to shrinkage or a compromised animal. It is clearly in the best interest of industry to look to continuously improve our standards of animal care, and a component of this is the regulatory backbone to the system. We've also recognized that bringing Canadian regulation up to international standards set by OIE is an important component.
Overall, we'd like to thank the department for moving towards regulatory language that is outcome-based rather than prescriptive. This enables regulation to better keep up with rapid technological and market changes. That being said, there are a number of concerns that we'd like to raise regarding the proposed regulations.
As Canada is geographically very large, some components of agricultural production rely on shipping animals over large distances for domestic production, especially for breeding and processing. Over the past number of decades, we've seen declining numbers of processing facilities, so there's been no choice for producers but to ship animals further.
Similarly, as one of the few countries in the world that exports food, Canadian producers ship live animals to many countries, and therefore, stand to be impacted by the lowering of intervals that animals can spend in transit without access to feed, water, and rest. This is compounded by the additional requirement to attain reasonable expectations that sufficient care will be provided throughout the length of a journey, once the animal has left Canada.
While every effort is made to ensure animal care standards are achieved and exceeded once the shipment leaves Canada, this is easier with known businesses and countries than with new ones. Therefore, there is some concern that this requirement could act as a disincentive to grow new markets or expand current ones by working with new business partners in new countries. We support the requirement in principle, but would like to see clear guidance for how the industry would comply with this requirement and address potential hindrances in market development.
I'd like to encourage the committee to closely assess the potential impact of lowering the maximum intervals based upon the testimony of national commodity organizations. With immense diversity within industry from species to species, the intervals should remain at different levels based on the best science. We have therefore asked CFIA to revisit the proposed intervals and regulatory impact analysis statement to more carefully consider the impact on the full value chain for all types of farm animal transport.
Overall, we'd recommend a four-hour extension for all categories, to cover unforeseen circumstances that rarely, but inevitably, arise. This allows for those transporting animals to adequately respond in rare situations that are simply not foreseen in a contingency plan. We would also like to ensure that the requirement of a contingency plan does not require a written plan. In many cases, for experienced transporters, routes are well known and issues that could cause significant delays can be mitigated through experience.
Increased focus on offering training to those actually transporting the animals would improve outcomes as people begin to better understand the animals and the regulatory requirements.
Producers and those who transport animals all strive to reduce the potential stress and suffering for animals during transport. Differences in breeds and how animals have been raised, coupled with unobservable conditions, will mean that some animals are more used than others to transportation, confinement, and being with other animals, resulting in different stress levels depending on many factors. The regulation should be clearer to determine the extent of undue, unwarranted, disproportionate, and unjustified suffering. By doing so, the regulations would be able to support improved animal care outcomes and current legal interpretations with consistency and clarity.
Additionally, the term “visibly observable” should be included as it relates to those responsible for loading, unloading, and transport of compromised and unfit animals. There are many potential conditions that could lead to an animal being determined as compromised or unfit, but these are not always visibly observable to those who hold the responsibility for transport. No one responsible for transport wants to unknowingly transport compromised or unfit animals. Without this term, confusion around whether people would be held liable for a situation in which they did not reasonably have access to information or visible indication that an animal was compromised or unfit could cause problems.
We also recommend that CFIA pursue a flexible implementation option to allow smaller businesses the time needed to ensure that operators receive appropriate training. It is expected that with the coming into force of these regulations there would be a significant demand for training, and allowing more time to phase that in would be beneficial to both employers and employees.
The agriculture industry requires strong yet workable regulations to guide the humane transport of farm animals in order to maintain and build public trust while providing guidance to the industry. Once the regulations have been updated, we remain committed to working with the National Farm Animal Care Council to develop and continuously update codes of practice and share information across commodities.