Mr. Chairman and committee members, thank you for the opportunity to appear before your committee.
The Canadian Veterinary Medical Association, CVMA, provides a national and international forum for over 5,500 veterinarians working across Canada. Veterinarians promote animal health and welfare, strive to relieve animal suffering, and protect public health. Veterinarians provide unique expertise on the health and welfare of all types of animals and have a professional obligation to ensure the welfare of animals. Animal welfare advocacy is a strategic priority for the CVMA.
I am a member of the CVMA animal welfare committee and a professor at the Atlantic Veterinary College, University of Prince Edward Island, where I hold a chair in animal welfare. My main area of research is the transportation of animals.
The importance of animal welfare to society and our understanding of how animals respond to management practices such as transportation have increased considerably since the existing health of animals regulations were written. They are in urgent need of revision. As you already would have heard in the evidence presented, both transportation and animal welfare are complex issues. Different stakeholders adopt different positions on the regulatory amendments.
Scientific research on animal welfare has clearly demonstrated that mammals and birds have the capacity to suffer and that aspects of transportation can place animals at risk of suffering. The good news is that if care is taken over the fitness of animals, the quality of the journey, and the associated handling and management of the animals, many if not most animals can be transported without experiencing severe welfare issues. However, situations are rarely ideal and different types of animals are more susceptible to aspects of transportation than others. Unfortunately, some animals experience suffering and others die as a result of transportation.
There are patho-physiological and emotional aspects to suffering associated with transportation. Handling, loading and unloading, vehicle movement, and interactions with other animals can cause injury, pain, and discomfort. Restriction of feed and water during long journeys can result in hunger, weakness, exhaustion of body energy reserves, thirst, and dehydration. Exposure to thermal extremes due to an inability of the transport arrangements to protect the animals from harsh external conditions, both hot and cold, and from the buildup of heat and moisture within the vehicle, can cause thermal distress and death. Animals can experience fear and distress by exposure to novel factors and can develop fatigue during long journeys.
Animals that are weak or suffering from disease or injury are most likely experiencing welfare issues such as pain and sickness before they are transported. They're likely to experience increased suffering because transportation will exaggerate any pre-transport issues. They're less able to cope with challenges such as getting on and off the vehicle, maintaining stability, avoiding fatigue, and coping with feed and water restriction and extreme thermal environments. They're likely to deteriorate during long journeys and more likely to die, become non-ambulatory, or have to be euthanized on arrival than those that are healthy.
The regulations need to address these issues by defining how the management of the animals during transport can reduce the risk of suffering. Unfortunately, the proposed amendments to the health of animals regulations do not fully reflect international standards, scientific research, and veterinary understanding of the implications of transporting animals.
Our main comments on the proposed regulatory amendments can be summarized as follows.
First, on fitness of animals for transportation, the CVMA believes that the proposed conditions listed in the compromised animal category should be reconsidered and that many of these conditions should be placed in the unfit for transport category. It is the CVMA's opinion that proposals that would permit the transport of animals for up to 12 hours with the types of conditions listed under the “compromised animals” category would result in considerable suffering.
The second point is about the intervals that animals may be transported without feed, water, and rest. The CVMA strongly supports the reduction in the time intervals that animals may be transported without feed, water, and rest. However, it is the CVMA's opinion that the proposed maximum intervals for animals are still longer than they should be to reduce the risk of suffering. In some situations, scientific research can provide evidence that indicates deterioration in animal welfare after a specific journey length. However, in most situations, the responses are linear and do not indicate a clear cut-off point. Research on this and associated topics is under review by the NFACC transportation code scientific committee.
Our third point relates to the suffering of animals during transportation. The CVMA believes that multiple approaches are required in the regulations to ensure that even though an animal arrives at its destination alive, suffering has not occurred along the way. In addition to the proposed outcome-based measurements, the CVMA believes that weight must also be given to the research evidence, professional advice, and opinion of veterinarians with respect to the assessment of suffering and the enforcement of regulations.
The CVMA strongly supports the removal of the term “undue suffering” from the current regulations and endorses its replacement with the word “suffering”. In addition, we made a number of detailed suggestions to various sections of the proposed regulations.
The CVMA encourages the federal government to dedicate the necessary resources for enforcement, training, and research in order to implement and sustain the new regulations so as to achieve the desired animal welfare outcomes.
The CVMA wishes to express its support for the general direction being taken by the proposed regulations. However, the CVMA is strongly of the opinion that modifications are necessary to ensure that the new regulations are effective and meaningful in strengthening the humane treatment of animals during transport. We look forward to working with the various stakeholders to develop solutions to the challenges of transporting animals, bringing to the table our knowledge, skills, and experience as veterinarians.
Thank you, Mr. Chair.