Agriculture Committee on April 4th, 2017

[The Chair, Liberal, Pat Finnigan]

Welcome, everyone, to this 51st meeting. Pursuant to Standing Order 108, we continue our study of amendments to health of animal regulations, regarding humane transportation.

We have a very packed table to give us some information today and to answer some of the questions we will have. With us this morning we have, from the Canadian Pork Council, Gary Stordy, public relations manager, and Frank Novak, vice-president. From Chicken Farmers of Canada, we have Steve Leech, national program manager, food safety and animal welfare; and Mike Dungate, executive director. From the Canadian Cattlemen's Association, we have Matt Bowman, who is a director and the president of Beef Farmers of Ontario, and Brady Stadnicki, policy analyst. Also, from Metzger Veterinary Services, we have Kenneth Metzger, veterinarian.

Welcome, everyone. We will start with the presentations by the groups, for seven minutes each.

Mr. Novak, would you like to start for seven minutes?

[Frank Novak, Vice-President, Canadian Pork Council]

Thank you.

Good morning. My name is Frank Novak. I'm a producer from Alberta and first vice-chair of the Canadian Pork Council's board of directors. I'm joined today by Gary Stordy, who is our manager of government public relations. I want to first thank the House of Commons Standing Committee on Agriculture and Agri-Food for the invitation to appear before you this morning and to discuss the amendments to the health of animals regulations.

I'd like to spend a little time this morning outlining some of the CPC's industry activities related to animal care and transportation and why we have concerns with the proposed amendments to the health of animals regulations. First of all, I just want to point out that the CPC represents more than 7,000 pork producers across Canada. We produce, as a group, more than 25 million animals per year and are responsible for over 100,000 jobs across our industry. The industry generates almost $24 billion in economic activity and last year exported 3.8 billion dollars' worth of pork.

Raising livestock is a 24-hour-a-day, 365-day-a-year commitment, and those who do it take the responsibility very seriously and consider it much more than just a job. Hog producers want to ensure that our animals arrive at their destination in the best condition possible. Canadian farmers are dedicated to the highest quality standards. Registered producers demonstrate their commitment to national standards for food safety and animal care through the national Canadian quality assurance program known as CQA. To be a registered CQA producer, a producer has to undergo an annual assessment for compliance to program requirements.

Producers recognize the importance of animal welfare and led the process to update the code of practice for care and handling of pigs on our farms, which was released in 2014. It was developed through a reasoned and scientifically informed debate that goes far beyond minimum requirements and includes provision for further progressive changes in the future.

I'd like to point out also that the livestock transportation industry is also in the process of updating its code of practice for livestock trucking, and pork producers plan to be engaged in the development of that code. Producers raise their animals to the highest standards to ensure health, safety, and high-quality product, and it is in our best interests to maintain this through transportation.

Hog producers and hog transporters take specialized training courses addressing the specific needs of animals in transport. This includes training staff on how to handle pigs, load and unload pigs, account for weather conditions, be prepared for emergency responses, and understand the potential impacts of those actions on the animals' well-being. Education tools like the Canadian livestock training program, or more specifically for swine, the transport quality assurance program, are mandatory training for anyone who wants to handle or transport pigs to Canada's federally inspected plants.

The CPC supports the move to outcome-based regulations and recognizes the need for continuous improvements, including in areas such as preventing undue stress for animals during transport. We believe that the welfare of animals in transit is dependent on a wide variety of conditions including vehicle condition, weather, handling, etc. It's not possible to describe every possible situation that you might incur.

Outcome-based approaches allow transporters and animal handlers the flexibility needed to ensure good animal welfare by identifying best practices to align with the regulatory requirements. This is why we are unsure why the CFIA has chosen to use both prescriptive measures, such as time off feed and water, as well as outcome measures to address the same concern. We feel that this is unnecessary.

The CPC does not agree with the proposal to reduce the maximum interval for restricting access to food and water from 36 to 28 hours. We feel that the prescriptive time limit does nothing to contribute to the goal of improved animal welfare and only serves to take away from progress that could be made by designing and implementing outcome-based regulations that are grounded in unbiased science.

Very little scientific evidence is offered to support the CFIA's claim that the change will improve animal welfare and reduce risk of suffering during transportation. Despite claiming that the position is establishing clear and science-informed requirements, no research has been cited demonstrating the impact of long transportation times for pigs. The small amount of data available on transportation is limited to market hogs, and no data has been presented for early-weaned pigs, feeder pigs, or breeding stock.

Most of the movement with a duration of between 28 and 36 hours in our industry is for isoweans transported to nursery barns in the midwestern United States. These shipments experience extremely low mortality rates and the U.S. nursery barns report exceptional performance from our pigs when they arrive. These newly weaned pigs have very low feed and water intake in the first couple of days at any rate, even without being transported. It is unreasonable to expect them to eat much, if anything, during this time.

Stopping also compromises biosecurity and increases the risk of exposing these animals to disease. The unloading of pigs will create significant stress leading to even more sickness and death losses, and both of these issues do nothing to improve animal welfare.

In 2016, Canadian producers shipped over 20 million market hogs to federally inspected plants. Our numbers, or the CFIA's own public numbers, show that 0.3% of those animals were found to be sick, injured, or dead upon arrival. This, to me, suggests that we don't have a problem that is out of hand. Rather, it shows that we can always improve. Longer hauls often show reduced rather than increased losses.

CPC is supportive of the efforts to improve animal welfare; however, we believe that better progress can be made by designing and implementing outcome-based regulations that are firmly grounded in unbiased science.

I would also like to add that research on newly weaned pigs' ability to withstand long-distance transport is being initiated currently at the University of Saskatchewan. This project will determine the maximum reasonable transport time that does not significantly impact the pig's welfare. Our recommendation would be that these regulations not be amended, or at least that this particular section not be amended, until that research is complete.

In conclusion, I would like to thank the committee for the opportunity to appear before you today.

[The Chair, Liberal, Pat Finnigan]

Thank you, Mr. Novak.

We'll now go to the Chicken Farmers of Canada.

Mr. Dungate, you have seven minutes.

[Mike Dungate, Executive Director, Chicken Farmers of Canada]

Thank you, Mr. Chairman.

Good morning committee members. I'm here with my colleague Steve Leech today.

Chicken Farmers of Canada appreciates the opportunity to provide input on the proposed health of animals regulations regarding transport.

Canada’s 2,800 chicken farmers willingly accept that they have a serious responsibility in terms of animal care, and they take that responsibility seriously. CFC takes pride in its long-standing, progressive approach to animal care. We have a third party, audited, mandatory animal care program that has been in place since 2009. Unlike any other programs that may be proposed out there, the CFC animal care program is the only program that establishes one national standard for all chicken production and is verified by annual third party audits. It's also the only program that is capable of ensuring animal standards on all farms in Canada.

Our program has credible foundations. It's been designed based on the code of practice developed by the National Farm Animal Care Council. The National Farm Animal Care Council is a world leader in bringing together stakeholders with different perspectives and a broad spectrum in terms of input to develop robust and sound codes of practice.

We want to take it one step further. That is why we are, as part of the next agriculture policy framework, seeking a recognition protocol for animal care similar to the one that we have in place for food safety. We think that would provide additional assurance as part of a public trust of agriculture component.

In light of our commitment to animal care, CFC believes that transport regulations should be science-based and developed to work in unison with food safety regulations. We can't do them in isolation. They have to be mindful of the operational structure of Canadian production, and developed with a view as to how they'll be interpreted by the courts. CFC's full comments and the proposed regulations are detailed in our submission, which we've provided to the committee. Specific areas of concerns that we'll address today are the definition of suffering; changes to the feed, water, and rest intervals; and the assessment of compromised and unfit animals. Clearly, I'm not going to try to address in seven minutes all the issues here, but I'll point out some highlights.

The first concern is with the definition of suffering. Under the current health of animal regulations, the reference is to “undue suffering” whereas the proposed version has removed all references to the word “undue”. CFC believes that “undue” must be maintained in the regulations.

The Canada Agriculture Review Tribunal and the Federal Court of Appeal have already developed a balance between animal welfare requirements and normal legal practices of agribusiness in transporting animals and chickens. The word “undue” provides the ability for the courts to interpret if the suffering was unwarranted, disproportionate, or unjustified. Without the word “undue”, any suffering would be illegal, and farmers would be constantly at risk of being before the courts. CFC is of the opinion that maintaining the word “undue” in the regulations will ensure that the objectives of the regulations are met without unduly harming the industry.

Moving on to the transport time—and I'm speaking specifically of the interval for chickens—the proposed regulations would reduce the transport time for chickens from 36 hours to 24 hours. That is a one-third reduction in terms of the time that we're allowed to transport animals. However, the impact is far greater, because the proposed regulations would incorporate feed withdrawal, which can be six to eight hours. Effectively, chickens would now have to be loaded, transported, and unloaded in 16 to 18 hours, so we're talking about more than a 50% reduction in the transport time. This is not continuous improvement; this is radical change.

Feed withdrawal is a food safety issue. This is where we think that we have to pay attention. CFIA has both food safety regulations and animal care regulations. It is there as a food safety issue to reduce the pathogen load on carcasses, and thus reduce public health risks. The proposed transport regulations would compromise food safety, making industry decisions a fight between human health and animal welfare. To remove the inconsistency between CFIA's food safety and animal care requirements, the maximum interval time should be modified to begin once water is withdrawn, not feed.

In Canada, water is available right up to the point at which we load the birds for transport. In CFC's view, radically reducing the transport time by 50% could be considered if there were definitive and compelling scientific evidence to do so. While we won't go into specifics, the consultation submission by Dr. Trever Crowe from the University of Saskatchewan raises significant questions about the scientific evidence to support the proposal. It is a detailed piece from a researcher on animal welfare who is globally recognized, and I think it's an important submission that should be considered by the committee.

CFIA's regulatory impact analysis statement indicates that changes are required to better align with the standards of Canada's international trading partners and the OIE animal welfare standards. However, there is no consistency in feed, water, and rest regulations for chickens among international trading partners. In the United States, there are no federal regulations for transport times; there are only industry guidelines.

Australia, one of the jurisdictions in the proposed regulations, commented that time off feed and water must not exceed 24 hours for chickens, while feed must not be withdrawn longer than 12 hours prior to transport. Since 24 hours plus 12 hours is 36 hours, that's exactly where we are today, although it's being claimed that it's 24 hours. They're not seeing, however, that the regulations are not covering just the transport time. They're expanding what is considered transport.

In Europe, the maximum times that chickens cannot have access to feed and water is 12 hours. However, this does not include loading and unloading times. To Mr. Novak's point, it's interesting that loading and unloading times are not included because of animal welfare concerns. They don't want to put pressure on quickly loading or unloading the birds just to meet time requirements. They want to give them the time necessary to do it properly.

[The Chair, Liberal, Pat Finnigan]

If you can, conclude quickly. We're—

[Mike Dungate]

Yes.

If you assume four hours for loading and three hours for unloading, the maximum feed and water rest interval in the EU is 19 hours. Our understanding is that the feed withdrawal is 12 hours on top of that, for a total of 31 hours. As there is no international harmonization, coming back to a species-specific point of view, we are prepared to go from 36 hours to 28 hours but not to expand beyond what is the current transportation timeline.

I will skip over the visibly observable and just conclude by—

[The Chair, Liberal, Pat Finnigan]

I'm sorry, we're very pressed for time so I'm going to have to conclude—

[Mike Dungate]

I'll just conclude. I'll stop that part and conclude.

[The Chair, Liberal, Pat Finnigan]

Thank you.

[Mike Dungate]

CFC will continue its leadership role on animal welfare, whether on the farm or in transport. We have the only program that retailers and restaurants can rely on with confidence to assure their customers and all Canadians that the chicken they sell has been raised under the most credible, mandatory, third party audited program in Canada.

Thank you.

[The Chair, Liberal, Pat Finnigan]

Thank you very much, Mr. Dungate.

Now, with the Canadian Cattlemen's Association, we have Mr. Bowman.

You have seven minutes.

[Matt Bowman, President, Beef Farmers of Ontario, and Director, Canadian Cattlemen's Association]

Thank you for the invitation to speak with you this morning. My name is Matt Bowman, and my family and I raise cattle in Temiskaming, Ontario.

I'm currently the president of the Beef Farmers of Ontario and a director of the Canadian Cattlemen's Association. The CCA is the national voice of Canada's 68,000 beef farms and feedlots. With me today is Brady Stadnicki, a CCA staff member here in our Ottawa office.

Transportation is a critical element in modern cattle production, marketing, and distribution. All cattle are transported at least once in their lives. Successfully hauling cattle requires particular skills and a strong emphasis on good pre-transportation decision-making and ensuring that the animals are fit for the entire journey, not just fit enough to get on the truck.

Proper animal care and welfare is paramount in the beef industry and producers continue to ensure the best life possible for their livestock. This proactive approach includes maintaining animal health; minimizing stress when handling, treating, or transporting animals; and continually updating and improving our practices.

When it comes to understanding the effects of transportation on cattle, the Canadian beef industry has not taken a backseat in this approach. In collaboration with Agriculture and Agri-Food Canada, academia, animal welfare experts, veterinarians, truckers, and animal care advocacy groups, cattle producers have invested substantial dollars into research to benchmark how the industry has been performing and to seek ways to minimize the stress on the animals.

Canadian research has shown that the outcomes for cattle transported in Canada are very positive. Studies have found that 99.95% of animals on a longer haul of over four hours reach their destination incident free, and 99.98% of the animals on a short haul of less than four hours reach their destination injury free.

We want to ensure that any amended regulations do not inadvertently move this number farther away from 100%. While we believe this is a good news story, it hasn't stopped industry from continually looking at ways to improve these outcomes. Researchers are always looking into more specific aspects of cattle transport and how they affect the well-being of animals. Examples of such areas include comparing the stress of unloading and reloading versus the stress of completing the journey, and the effects of temperature, trailer design, loading densities, and how a trucker drives.

In addition, it is important to understand whether rest stops do in fact relieve stress. For example, rest stops can facilitate the spread of respiratory and other diseases, especially on vulnerable animals.

With respect to the proposed regulatory changes, Canadian beef animal producers and CFIA share the goal of continually improving animal health and welfare outcomes. It is CCA's position that any regulatory change needs to be based on scientific evidence, and wherever possible, uses outcome-based guidelines that focus on the animal. The CCA believes that for a new rule to be meaningful, the supporting research needs to be conducted using commercial cattle, transport trailers, and drivers under typical commercial distances and conditions in Canada.

CCA is supportive of the efforts to modernize the regulations by bringing more clarity to certain definitions and make regulations less prescriptive and more outcome-based. However, we are concerned with some aspects of the regulatory proposal and the effect they could have on our industry.

First, we're concerned with the change in the maximum number of hours that cattle can be transported, which has been reduced to 36 hours from 48 hours. The geography, climate, and infrastructure that the Canadian cattle industry operates in are much different from other cattle jurisdictions, such as the European Union's, which is a jurisdiction that CCA believes has limited applicability to the Canadian context.

There is little existing evidence that suggests a prescriptive change in the number of hours cattle can be in transit will make the small number of negative outcomes in the cattle industry even smaller. Instead, CCA believes that regulations should be consistent with an outcome-based approach, which would allow experienced and competent drivers to use their judgment and get cattle from point A to point B as safely and efficiently as possible.

CCA also recommends that more research on rest stop intervals and durations is required before any regulatory change comes into force to avoid unintended, negative consequences on animal welfare outcomes. Furthermore, CCA recommends that the existing four-hour grace period in transport times be retained as there is need for reasonable flexibility for unforeseen circumstances that occur during long-distance travel.

CCA is also concerned that the regulatory impact and cost-benefit statements included in the proposal do not accurately represent the cattle industry. It also fails to acknowledge that producers will bear the majority of the added costs created by these regulations. CCA is concerned about the capacity for existing rest stations to handle increased volume, as well as the suitability of existing rest station locations across Canada.

I've recommended that CFIA provide a more sector-focused analysis before any new rules come into force.

Finally, there are concerns about the transfer of responsibility requirement and some of the proposed definitions, which we would be happy to elaborate on a little later during questions.

In closing, I would like to say that cattle producers are continually working to make demonstrable improvements in animal health and welfare outcomes with all aspects of our industry. As we move forward, it is critical that any regulatory change also contributes to real welfare improvements rather than unintentionally risking the high prevalence of positive outcomes delivered by industry today.

Thank you for the opportunity to present this morning, and we look forward to your questions.

[The Chair, Liberal, Pat Finnigan]

Thank you very much, Mr. Bowman.

Now we'll go to Metzger Veterinary Services.

[Dr. Kenneth Metzger, Veterinarian, Metzger Veterinary Services]

Thank you, Mr. Chairman.

I know what you're all thinking. Who is this Ken Metzger, and what is he doing in this meeting?

I'm not a national organization and I don't represent thousands of people. I'm just one little vet from Linwood, Ontario, but I am hands-on and my clinic provides the veterinary service for about 10% of Ontario's hog production and about 75% of Ontario's beef production.

When I read the Canada Gazette, I became worried that the government may just be naive enough to believe these fantasies and actually implement the changes, so I wrote to my MP, my MPP, and Dr. Kiley, expressing my concerns, and I guess that's how I ended up here today. Thank you for inviting me.

One of the main proposed changes in the Gazette would reduce the maximum transport time from 52 hours to 36 hours for cattle, and from 36 hours to 28 hours for pigs. This should not be done because it would seriously disrupt our industry in Ontario. Remember that pigs cannot be unloaded and reloaded for biosecurity reasons.

Every week in Ontario, we bring about 8,000 early weans from Nova Scotia and Manitoba. These trucks can't make that journey in 28 hours, so that entire flow would have to be discontinued. In the case of the Nova Scotia producers, many of them would go out of business. Many of the Manitoba farms are owned by Ontario producers to supply their Ontario pig flow, and many of those farms would have to be sold.

In addition, Ontario has a shortage of hook space, and we need the ability to market pigs to Manitoba for slaughter. There are also over 100,000 cattle per year from Manitoba that would have to be unloaded unnecessarily. Currently, they come straight through.

There is no scientific evidence that shorter transport times would enhance animal welfare. In fact, the research shows that loading and unloading is the most stressful part of the journey and where most of the injuries occur.

Another argument you'll hear is that calves become dehydrated during the journey. That's simply not true, because they have a five- to 10-gallon rumen capacity. Just think about it. The driver might consume three litres of water, but the calf already has 30 litres of water in its rumen. Calves don't become hungry, either, again because of the large rumen capacity and because they eat straw while they're on the truck.

It's already been mentioned that the unnecessary unloading of Manitoba cattle at Thunder Bay is a biosecurity risk. In our own vet clinic every year, we do a survey of our producers on cattle health. We consistently find that long-distance western calves have half of the sickness rate that our Ontario and Quebec calves have. The current transport times are working just fine. Western calves arrive in Ontario in excellent health.

If the committee feels the need for reassurance on that, I'd encourage you to simply open your laptop, go on Twitter, type in “Ken Schaus”, and take a minute to watch some of those videos of unloading western calves in Ontario. Those calves tell the real story.

The second main part of the Gazette deals with a series of definition changes. Now let me be clear. The only group I can see that would benefit and cares about these exact definitions is the CFIA, because they use these definitions to assign AMPs. In four and a half years, the CFIA has issued over 1,000 AMPs that have generated $8.5 million in fines. In my opinion, many of the AMPs that my customers have received are unjustified.

Kathy Zurbrigg, who is a Ph.D. student at the University of Guelph and now works at Ontario Pork, has presented her research to the CFIA. I have it here. It is about in-transit losses in hogs, meaning pigs that die on the truck on their way to slaughter. Her findings were that many of these pigs had heart lesions that caused their death, and that there was no way that producers or transporters could know ahead of time which pigs were affected or if or when they would die.

These pigs simply died, and it's no one's fault. The CFIA assumes, however, that it's from overcrowding, even though the scientific research says otherwise. The CFIA does not seem to be influenced by scientific research, and they continue to issue AMPs for this.

I'd like to give you one more example of how disastrous these definition changes would be. In paragraph 136(1)(f), any animal with “slightly imperfect locomotion” would be deemed compromised and could only be transported if it's segregated, loaded last, and unloaded first, etc. There are tens of thousands of animals with slightly imperfect locomotion every year in Ontario. It would be simply impossible for the industry to comply with that regulation.

In summary, I implore this committee to do the right thing. Don't give in to the irrational objectives of the animal activists. Don't make it even easier for the CFIA to issue AMPs when there are already too many unjustified AMPs. We all want improved animal welfare, both the activists and the livestock industries, but what the activists don't understand is that these changes would actually backfire and reduce animal welfare.

We have a world-class livestock industry in Canada, some of the best farmers, the best transporters, and the best processors producing the best beef and pork in the world. Let's all work together to achieve our common goal of enhanced animal welfare within a successful and thriving livestock industry.

Thank you.

[The Chair, Liberal, Pat Finnigan]

You're right on time, Mr. Metzger. Thank you so much.

We'll start our questioning round. I want to welcome Mr. John Nater here, replacing Mr. Shipley. We'll start with Mr. Anderson for six minutes.

Go ahead, Mr. Anderson.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

Thank you, Mr. Chair. We have some organizations here.

These changes have been discussed for several years or whatever, off and on, but my understanding from the information from the bureaucrats was that they really haven't followed up on this in the last couple of years.

Can you tell me, have your organizations had direct conversations about these issues in the last couple of years with the government, or was this dumped on you without recent consultation?

[Steve Leech, National Program Manager, Food Safety and Animal Welfare, Chicken Farmers of Canada]

Thanks.

Certainly over the last number of years, there have been discussions with the Canadian Food Inspection Agency on transport regulations. For a number of years, the file, I think, was fairly inactive, and we were actually trying to work with CFIA to look at the transport regulations. Over the last couple of years, there's been some interaction back and forth, but it's been fairly limited in some situations in terms of the amount of discussion that we've had. But certainly we've been working to put forward the notions that we have, which Mr. Dungate spoke about and which are in our submission report, about some of the complexities of the definitions and how the changes in transport times could negatively impact the industry.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

Would anybody else like to add?

[Brady Stadnicki, Policy Analyst, Canadian Cattlemen's Association]

I'd just echo those comments. In 2013 there was a survey and a kind of pre-consultation questionnaire that went out, and the CCA did provide comments to that. At value chain round tables and meetings like that, we kind of got an update that they were being worked on but the details weren't in detail.

I guess one thing is that, even with that process going on, industry has been working, on our own part, in terms of researching and trying to really get a better understanding of the effects of transportation on animals and to benchmark, essentially, trying to answer the questions of today and tomorrow, not just sitting still on the topic.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

Two of you, at least, or your organizations, have said that over 99% of the animals are moved without incident, without issues, or whatever. Do we need a revamp of these entire regulations just to deal with less than 0.5%, and are these things that you can take care of internally, that you can change the standards on?

You've talked about animal care programs and those kinds of things. Is that the kind of thing that industry can take care of themselves, do you think?

[Brady Stadnicki]

Yes, with the research benchmarking the cattle industry has done—as you mentioned—we're having over 99% success at a national level. The analogy I use is that we're playing darts and we're hitting the bull's eye 99% of the time. If we have wide-sweeping changes to the regulations—or, in the analogy's case, our technique of throwing that dart—we're less likely to get closer to 100% and more likely to get further away. Certainly, if we look at the specific small issues that deal with 0.05% of areas we can improve on, I think that comes around training, industry education, and further research.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

Dr. Metzger, will you talk a little bit more about the challenges of unloading and reloading animals? You talked about biosecurity. I wonder if you can go a little bit further into the issues animals face if they're going to be unloaded and reloaded a couple of times between, say, here and my area in western Canada. What does that do to animals, and how is that in their best interest at all?

[Dr. Kenneth Metzger]

Sure. I'd be glad to comment on that.

One of the main things to keep in mind is that respiratory disease is our biggest health challenge with new cattle. Also keep in mind that the incubation period for Mannheimia haemolytica, the main pneumonia-causing bacteria, is five days. An unnecessary stop of eight hours, which turns into 12 hours with rest, doesn't seem like that much—it's just half a day—but that extra 12-hour delay in getting those cattle to Ontario and into the feed-yard where they can be properly cared for is absolutely critical. There's absolutely no question that the groups of cattle that give us the most trouble, from a health perspective, are the ones that have long delays in getting to Ontario. Without a doubt, the best ones come straight through.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

We want to have science-based regulations. You've all talked about the interest in outcome-based and science-based regulations. Also, the CFIA has expressed a desire to better align with the standards of Canada's trading partners. I'm just wondering if you can give me a little information. What happens if those two things are not the same, and their standards are not based on science but on politics? How do we deal with that? That seems to be what's happening here. The idea that we would have European standards is in a lot of ways ridiculous because of the complete difference in geography, transport issues, and those kinds of things. Does anybody have a comment on that?

Go ahead, Mike.

[Mike Dungate]

I agree.

New Zealand has a 12-hour limit, but you can go from one end of the country to the other in 12 hours. Did they put it at the maximum so that you're not going to drive a couple of times around the island before you get there? I think you're going to look at what you're going to put in place depending on your geography.

We don't know the reasons why they are there. What we do know is that they're inconsistent from one country to another, so there has to be something other than science that's driving them to have that basis. We are fully supportive of the science aspect in doing research and in continuous improvement. The better you know, the better you do. I don't think radical change is necessary.