ABP: What Producers Need to Know about the New Transport Regulations

On Feb. 20, 2019, the Health of Animals Regulations Part XII, humane transport were updated.  These regulations come into force one year from now, on Feb. 20, 2020.

ABP, along with CCA, provided extensive comments on the regulatory proposal.  Cattle producers strongly support animal welfare, and our objective is to achieve the best possible outcomes for cattle that are transported, while recognizing some of the logistical challenges associated with our unique geography and infrastructure.  We emphasized that regulatory changes should be science and outcome based, focusing on what is best for the animal.

We strongly advocated for regulatory revisions based upon research conducted under commercial conditions, with cattle, transport trailers and drivers, under the typical transport distances and conditions experienced in Canada.

We expressed concerns around the lack of data supporting altering the current time in transit and rest stop regulations, some of the ambiguity in the proposed verbiage of the regulatory proposal, the ability of our current rest stop infrastructure to adequately service an increased volume of cattle and the subsequent biosecurity requirements, as well as the practicality of having someone physically present to assume responsibility for delivered cattle around the clock, a requirement which was removed from the official regulatory text.

We are disappointed that the majority of our comments seemed to be overwhelmed in favour of activist positions that Canada’s livestock transit times are too long and rest durations too short, without the necessary science and outcome-based evidence to support this change.

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What does the research say?
Research conducted by Agriculture and Agri-Food Canada (AAFC) found that 99.95% of cattle on long-hauls (over 4 hours) reached their destination in good condition (Gonzalez et al. 2012).  In that study, 95% of long-haul cattle spent less than 30 hours in transport.  In addition, more recent research conducted by AAFC, along with Alberta Farm Animal Care (AFAC), supports this conclusion through an examination of the fitness of cattle arriving at auction markets, provincial, and one federal abattoir in Alberta; indicating that the majority of cattle observed at auctions were fit for transport (Heuston et al. 2017).  Adjustments to regulations are more likely to move the industry away from 100% than to make up that final 0.05%.

Rest stop research is in short supply, there is a lack of information on the effectiveness of rest stops in mitigating the potential stressors of long distance transport (Ross et al. 2016).  A small AAFC controlled research study focused on the duration of rest stops indicated that rest stop periods less than 10 hrs did not prevent short-and long-term stress after transport in weaned calves, but suffered from small samples sizes, no behavioural observations during the rest stop itself, and potential confounding due to time-of-day effects (Marti, 2017).

Rest stop infrastructure is limited in Canada; east of Winnipeg there are two at Thunder Bay with a combined holding capacity of 38 pens. It is unclear how these facilities will handle an increased volume of cattle and necessary biosecurity protocols, especially if loads end up forced to share pens due to space constraints.

To help close this knowledge gap, a project was initiated in 2018 under the Beef Industry Science Cluster to examine the effects of rest stop duration and quality under commercial hauling conditions (http://www.beefresearch.ca/factsheet.cfm/effect-of-rest-stop-duration-and-quality-during-transport-on-cattle-welfare-259).  This project will have completed two years of data collection by the time the new regulations come into force.  It is unclear at this stage whether the project will be granted an exemption from the regulations to continue.  ABP recommended that rest stop duration remain unchanged until results from this project were available to inform the regulations appropriately.

What has changed?
The full text of the regulations, along with the Regulatory Impact Analysis Statement can be found here: http://www.gazette.gc.ca/rp-pr/p2/2019/2019-02-20/html/sor-dors38-eng.html.

The biggest change in the regulations is the reduction in transport time from 48 hours to 36 hours, without any flexibility in that 36-hour cut-off time for unforeseen circumstances.  After 36 hrs of transport, rest stop duration where feed and water must be provided has increased to 8 hours from 5 hours.  An exemption from these mandated times exists for trailers or other conveyances that are specially equipped to provide feed and water to all animals throughout the journey, but these trailers do not yet exist in any great numbers in North America.  Compromised animals can be transported for a maximum of 12 hours before mandatory feed, water, and, rest.  Young animals that can’t be fed exclusively on hay or grain can be transported in a single trip only for a maximum of 12 hours (i.e. a baby calf is not permitted to be transported for 6 hours, unloaded, reloaded, and transported again for 6 hours).

The regulations also prohibit anyone from leaving an animal at a slaughter plant or assembly centre (for the definition of an assembly centre, see the regulations) unless the person transporting the animal provides the receiver of the animal with written notice that the animal has arrived and a document that contains information regarding the condition of the animals, the date and time it was last provided access to feed, water, and rest, and the date and time of the arrival of the animal at the slaughter establishment or assembly centre.  The receiver of the animal assumes responsibility for the transported animal’s care as soon as the receiver acknowledges receipt of the notice and accompanying information.  The transporter retains responsibility for the care of the transported animal until the received has provided that acknowledgement and documentation.

Every commercial carrier or any other person that transports animals during the course of business or for financial benefit must have a contingency plan that establishes measures to be taken if there are unforeseen delays or circumstances that could result in the animal’s unnecessary suffering, injury or death; or if the animal becomes compromised or unfit during loading, unloading, or transport.  In addition, commercial carries will be responsible for training, or ensuring that training is received, by their employees.  Canadian Livestock Transport (https://www.livestocktransport.ca/en/) would be one of the available options, but in addition, after March 1, 2019 mandatory entry level training (MELT) is required for all new Class 1 and Class 2 drivers from Alberta Transportation.

There have also been a few changes to the definitions of what sort of conditions equate to “compromised” or “unfit” animals, as outlined in the table below.

*Can only be transported for a maximum of 12 hours
*Can only be transported to the nearest place (not an assembly centre, unless seized or detained under a provincial or federal Act) where it can receive care or be humanely killed, needs to be segregated for the trip (or with a familiar companion), individually loaded and unloaded without navigating ramps within the trailer, and measures are taken that prevent suffering, injury, or death during loading, transport, and unloading.
*Cannot be transported, unless the animal is to receive veterinary care on order of a veterinarian.  If so ordered, the same conditions apply to the transport as for compromised animals
Bloated, with no signs of discomfort or weakness Non-ambulatory (downer)
Acute frostbite Has a fracture that impedes mobility or causes signs of pain or suffering
Blind in both eyes Has a prolapsed uterus or severe rectal or vaginal prolapse
Has not fully healed after a procedure (including dehorning or castration) Exhibits signs of a generalized nervous system disorder
Is lame in a way that is not described in the definition of “unfit” Is lame in one or more limbs to the extent that it exhibits signs of pain, suffering, halted movements or a reluctance to walk
Has a deformity or fully healed amputation and does not demonstrate signs of pain as a result Is lame to the extent that it cannot walk on all of its legs
Is in peak lactation Has laboured breathing
Has an unhealed or acutely injured penis Has a severe open wound or laceration
Has a minor rectal or vaginal prolapse Has sustained an injury and is hobbled to aid in treatment
Has mobility limited by a device applied to the body, including hobbles (but not hobbles that are applied to aid in treatment) Is extremely thin
Exhibits any other signs of infirmity, illness, injury, or condition that indicates a reduced capacity to withstand transport. Exhibits signs of dehydration
Exhibits signs of hypothermia or hyperthermia
Exhibits signs of a fever
Has a hernia that impedes movement (including if a hind limb touches the hernia as the animal is walking), causes signs of pain or suffering, touches the ground when the animal is standing, or the hernia has an open wound, ulceration, or obvious infection
Is in the last 10% of gestation or has given birth during the previous 48 hours
Has an unhealed or infected navel
Has a gangrenous udder
Has severe squamous cell carcinoma of the eye (cancer eye)
Is bloated to the extent that it exhibits signs of discomfort or weakness
Exhibits signs of exhaustion
Exhibits any other signs of infirmity, illness, injury, or condition, that indicates it cannot be transported without suffering