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.