Written by: Heather Clemenceau
“The increasingly global marketplace for food commodities has created more opportunities for the introduction and spread of contaminants that may put Canadian food safety at risk. Food-borne illness continues to impose significant health and economic costs on Canadians and recent food safety incidents in Canada have demonstrated where the current federal food regulatory framework must be strengthened.” ~ Canadian Food Inspection Agency
The Government of Canada has recently launched a public consultation on new rules to strengthen food safety – the Safe Food for Canadians Regulations. The proposed regulations are supposed to better identify and manage food safety risks before products are sold to consumers. As members of the public, we are stakeholders in this process and entitled to send comments on the proposed regulations. I’ll be writing to Dr. Arsenault (contact info below) and each of us should take this opportunity to give input. The consultation process closes on April 21, 2017, so we need to get our letters written before then. If you would like background reading on this consultation process, here are some links:
- Pre-publication of the proposed regulations in the Canada Gazette, Part I
- Backgrounder: Proposed Safe Food for Canadians Regulations
- Safe Food for Canadians Act
- Learn more and have your say
- Chemical Residues
What topics should you address? Here are a sampling of issues that are derived from recent events and longstanding issues that have been identified by horse advocates and advocacy groups:
- The presence of drugs in meat (the CFIA refers to these as “non-food agents”) and the low testing rate of carcasses. Focus should be testing kidneys and liver rather than skeletal muscle. Carcasses must be held until all laboratory results are received.
- Transport issues – horses can remain in transport for up to 36 hours with no food, water, or rest. Transport guidelines, such as they are, do not reflect current science regarding the handling of animals by land, sea, and air. Late term pregnant mares are sent to auctions and subsequently to slaughter, and sometimes foals are born in transit (this information was obtained through CHDC Access-To-Information documents). Were any penalties meted out to the transgressors?
- Live shipment of horses not following IATA regulations
- No traceability. Horse owners will not pay for a system to track horses from cradle to grave in order to satisfy a food safety requirement. The fact that no group in Canada – neither Equestrian Canada or Agriculture and Agri-Food Canada (AAFC) has so far developed a workable system for horses is a testament to how unworkable such a system would be. Horses are not food.
- In June 2016, a butcher shop in Montreal was caught adding horsemeat to hamburger patties advertised as being entirely made of beef. An investigation by Radio-Canada (and not the CFIA) found the meat sourced from La Maison du Rôti, which supplied many hotels and commercial establishments in Montreal, advertised as being 100 per cent beef. This is consistent with a study from 2015 that found that nearly 5% of all ground meat products tested in California had horse meat in the product. What did the CFIA do to address this adulteration? It does not appear that the company was ever fined or had their operations suspended – if not, why not?
- Wild horses ending up in the food supply – in 2014, 3 wildies from the Williams Creek cull were sent to the Bouvry plant. Complaints to the CFIA resulted in an investigation, because a permit holder cannot determine if he has captured a truly wild horse, or a barn yard escapee. The CFIA, concluded that Bouvry did slaughter two of the Wildies, and that a kill buyer purchased the horses from the permit holder without having the required 6 month history as required by the EID (Equine Information Document). The third horse could not be verified (lack of traceability once again). If punishment has not been meted-out against these two individuals, ask the CFIA why? How will the CFIA prevent this from happening in future?
- Native owned horses in British Columbia are rounded up and sent to slaughter periodically despite roaming free on private land and being unaccounted for during much of the year.
- I do not wish to throw any animals under the bus, but unlike “traditional” farm animals, there is truly no verification system in place to ensure that horses who do go to slaughter are sent there by those with rightful legal ownership. Horses sold to slaughterhouses or kill buyers without the owner’s knowledge or permission are sold with Equine Information Documents (EIDs) that were fabricated during the last leg of the horses’ journey to the plant, often by someone who has owned the horse for a few days or weeks if that. Such individuals have no basis to make any claim that the horse has not received any prohibited substances. EIDs do not sufficiently identify horses who look similar and it cannot differentiate between them with any degree of certainty. Once again, any form that only asks for voluntary declaration of drugs is unlikely to be complied with when the seller wishes to profit from the sale of that horse.
- EIDs (Equine Information Documents) are property of slaughterhouses. Some EID forms are even branded with the name of the slaughterhouse and not the CFIA. This is a food safety issue and should not be decentralized to the slaughterhouse – the CFIA needs to exert control over EIDs and publish the results of audits in the interest of transparency.
- The recent and well-publicized cases of missing horses Sargon and Apollo (Sargon was sold to slaughter by someone other than his legal owner). Urge the CFIA to take action against false statements made on EIDs and to report the results of audits to satisfy public interest. Send them information on the impact on victims of stolen horses.
- EIA (Equine Infectious Anemia) has now appeared in Quebec after a years-long absence. Are the presence of slaughterhouses in Massueville and Saint-André-Avellin, in Quebec risk factors? Private owners of horses are required to have a Coggins test when moving practically everywhere, but slaughter-bound horses are not. Now that there is an expectation by the EU that American horses will need to reside in Canada for six months prior to slaughter, you may feel that this residency requirement increases the risk of disease transmission in Canada. Do you feel that slaughterbound horses from the US should require a Coggins? Why should slaughter haulers be allowed to evade what amounts to a biosecurity issue for every place they travel through, since Equine Infectious Anemia is incurable and biting insects the principal vector? We live in an era where animals are hauled long distances and to’from different countries – large numbers of unvaccinated and untested animals are coming into Canada. This is surely a threat to any responsible horse owner and this law could be easily changed though the slaughter buyers would have to bear the costs (as everyone else already does) when purchasing and transporting a horse for any purpose.
Call To Action:
Write now to Dr. Richard Arsenault before April 21st!
Domestic Food Safety Systems and Meat Hygiene Directorate
Canadian Food Inspection Agency
1400 Merivale Road, Tower 1