Thank you, Mr. Chair, and all members of the standing committee. The Canadian Association of Bovine Veterinarians, CABV/ACVB, is grateful to be granted the opportunity to present to this standing committee. Our association represents 759 veterinarians who are either in clinical practice, government, academia or industry, across all provinces in Canada.
ELDs, or electronic logging devices, are an effective tool to document service and driving hours. However, ELDs do not provide insight into occurrences during those hours that may necessitate flexibility in the enforcement of regulations. This lack of flexibility will then place drivers in a difficult position: Either the drivers comply with the hours of service regulation by going off duty, or they do what they know is right for animal welfare and get the cattle to their planned unloading site.
The vast majority of animal trailers are passively ventilated, so when the trailer is not in motion, the cattle will not receive appropriate airflow to ensure ideal ventilation rates and temperature control for the cattle. This is a threat to animal welfare.
The Canadian animal transport industry is carefully planned to follow all transportation guidelines. Nonetheless, adverse road and weather conditions, traffic accidents, border crossing delays or delays at packing plants cannot be planned for. It is for these inevitable delays that we are seeking flexibility in the use of ELDs to ensure the well-being of the animals being transported.
The CABV is hoping that a threat to animal welfare will be considered as an emergency situation and then will be covered under section 76 of the hours of service regulations. This will then provide clarity to enforcement officers, peace of mind to animal haulers, and, most importantly, not impair the welfare of cattle in Canada.
Cattle welfare is of paramount concern for the CABV. Hopefully we can attain some clarity of definitions and flexibility in the enforcement of hours of service with ELDs to ensure we maintain the highest level of welfare for cattle in Canada.