I first became aware of MP for Lambton-Kent-Middlesex Lianne Rood when she appeared in an AGRI – Standing Committee on Agriculture and Agri-Food meeting video on the issue of live horse export. As you might expect of a Conservative MP and one who is wholly in favour of this disgusting trade, her comments are a template of idiocy. She believes that expensive competition and sport horses are shipped the same way as slaughter-bound horses – in wooden crates with no food or water. Her comments in the committee suggest that she believes that every horse owner “recovers the cost” of their horse by selling them for live export at the end of their careers. In the AGRI standing committee meeting she actually asked Animal Justice’ Kaitlyn Mitchell if she had ever been on a flight with the horses to Japan, as if that were ever an option for any interested observer.
This former farmer, who served as the shadow minister for Agriculture and Agri-Food (2020), and Deputy Shadow Minister (2019), for Agriculture and Agri-Food, is also a member of the Canada-Japan Inter-Parliamentary Group, and is simply a bad actor who is making a career out of spreading disinformation. Who do Conservatives advocate for? Certainly not animals or the environment.
Most recently, Rood, who gets paid six figures, has decided that she’s unhappy about paper coffee lids, in effect bringing American Republican culture wars to Canada, where inanimate objects are considered “woke” – a code for any Conservative grievance. Rood’s post is a work of daft frivolity: it succeeds at showing the pettiness of Conservatives, and their utter disregard for the environment, in a single post. Does a sitting MP have nothing better to do than vent about lipstick on a cup lid?
Every day, the equivalent of 2,000 garbage trucks full of plastic are dumped into the world’s oceans, rivers and lakes, according to the United Nations Environment Programme (UNEP). The UNEP says plastic pollution can alter habitats and the natural world, reduce ecosystems’ ability to adapt to climate change and directly affect livelihoods and food production for millions of people, when they release microplastics into the environment. But Ms. Rood is hardly concerned with her cup lid taking 200 years to bio-degrade in a landfill. After all, there is rage to be farmed…
It’s free to send mail to any MP in Ottawa. That includes sending any single-use plastic waste that we find, to her for free. You could also send her a sippy cup, even though she makes about $200,000 a year, this option has never occurred to her.
Mail any single-use plastic waste you have (or send her a message detailing your opposition to live horse export, or both), to:
Lianne Rood M.P – House of Commons, Ottawa, Ontario, Canada, K1A 0A6
Part of the re-election campaign Prime Minister Trudeau included a commitment to ending the trade of horses for the production of horsemeat for export. The 2021 Mandate Letter to then-Minister Bibeau stipulated that she be committed to fulfilling this ban, but she failed to execute the ministerial mandate letter. The government has acknowledged that it has been stung by criticism for its inaction on this mandate. The lack of fulfilment has since been identified as a trade irritant (any issue or policy that creates tension or friction in international trade relations between countries) between the EU and Canada through a little-known mechanism of the Comprehensive Economic and Trade Agreement (CETA).
Further embarrassment for the Liberals continued – in December of 2022, the Globe and Mail published an article that highlighted the inaction by the government in fulfilling this election promise, while underscoring calls for action by public figures. Another such piece the Globe and Mail published further condemned the practice and called for the realization of this campaign promise. The failure to implement this commitment was interpreted by the federal government as a future issue in the next election cycle.
For more than two years, the Government of Canada has been reviewing (at a glacial pace) the legal and policy framework to address the Liberal mandate to ban the live export of horses for slaughter. Unfortunately, much of this 1,200+ page series of FOIA documents has highlighted the degree of obstruction due to the complexities and inefficiencies of bureaucratic systems within government agencies. Disappointingly, an entire team from the CFIA/AAFC/Legal Services, and Canadian Border Services Agency crafted the typical self-congratulatory response letter we’re all too familiar with, about the CFIA maintaining high standards, The Health of Animals Act (HAR) ensuing humane transport, variations of which was sent to Japanese agencies.
Health of Animals regulations are the absolute minimal standards for shipping an animal. The HAR does not ensure humane treatment. Politicians are shocked to discover that competitive horses are shipped with food and water, often in a single compartment, sometimes with their own dedicated veterinarian who travels with them through to their designated stop.
Agriculture and Agri-Food Canada also endorsed and disseminated misleading information from pro-slaughter individuals and organizations that has been debunked more than a decade ago. One wonders why so much effort has gone into this analysis when the trade largely benefits only a few individuals, and the government’s own legal analysts have stated that the process to end trade seems reasonably straightforward and a decision not necessarily requiring bilateral agreement:
“Article 12.1 of the WTO agreement on agriculture provides that a member must notify in writing and in advance of implementing an export restriction or prohibition, as well as consult with another Member that has a substantial interest as an importer (e.g. Japan) that requests it. The notification is the include the rationale and duration of the measure.”
Excessive redaction of the most important information in this FOIA will raise questions about transparency and accountability. Notable redactions include the certification process to export horses, any information about the exporters themselves, and perhaps most importantly, Japanese response to the prospect of ending the trade. There have been some Japanese media reports about reports made in Canadian and UK media regarding the concerns over transportation of these animals but there is no Japanese opinion provided anywhere.
History of Trade Relations with Japan:
• Japan is the fifth largest importer of agri-food and seafood products in the world, and Canada’s third largest market for agri-food and seafood.
• Horse meat is a traditionally eaten food in Japan. In particular, in Kumamoto Prefecture where horse meat is considered a centre of local cuisine that has been part of the culture for over 400, consumption is focused on fresh horse meat. MAFF promotes horse meat as a low-fat, low-calorie, high-protein food rich in minerals such as iron,calcium, and zinc.
• Since 2012, Canada’s exports of live horses for slaughter have been almost entirely destined for Japan, and Canada has been Japan’s largest supplier in most years with a market share ranging from 29% to 46% over the years. Japan receives about two shipments per month of livehorses for slaughter from Canada, and on average, a shipment contains 100-125 horses. Foals from 6-9 months are transported to feedlots where they remain until the age of 2. Then they are flown overseas from Edmonton, Calgary, and Winnipeg.
• With the lowest food self-sufficiency level ratio among G7 countries (38% in FY 2021/22), food security is a major concern for Japan. This concern was further aggravated by the spate of export restrictions on agricultural goods that governments implemented as supply chains were roiled by COVID-19 and Russia’s invasion of Ukraine.
• Canada and Japan are both members of the Comprehensive and Progressive Agreement on Trans-Pacific Partnership (CPTPP) and share a likeminded view regarding an international rules-based trading system.
• Any Canadian exporter who has successfully negotiated a commercial contract with an importer in Japan and who can comply with Japan’s import conditions (as specified in an established health certificate) may export horses to Japan. What is required to meet these expectations was redacted from the FOIA.
• In 2021, Canada was the world’s eighth largest exporter of horse meat, with exports valued at $28.6 million.
Understanding and mitigating unintended consequences is important for effective governance and policymaking. Whenever you read any claims about horse slaughter from the following groups, you know they are going to be about as impartial as David Duke’s critical review of Alex Haley’s “Roots.” Most exasperatingly, AAFC included numerous references to outdated and debunked articles, from as far back as 2006 (preceding the cessation of horse slaughter in the US). It’s unclear why promotional material for horse slaughter was included at all, since most horses shipped for export are purpose-bred or are “byproducts” of an industry that breeds horses for other purposes.
These supplemental materials included:
• A 2006 document from Animal Welfare Council, Inc. Colorado Springs, Colorado.
• An assortment of refuted references and pro-slaughter organizations who want to convince you to upgrade to a new $5,000 AQHA horse, but need to provide you with a pathway to dispose of your $500 horse who is stubbornly clinging to life.
• Canadian Meat Council, prepared in consultation with Bouvry Exports and Jennifer Woods of J. Woods Livestock Services.
• The inclusion of an article from BEEF magazine blaming horses for irreversibly damaging rangelands, and proclaiming slaughter as needed for “good horse welfare.” The author, Courtney L Daigle, an Assistant Professor of Animal Welfare at pro-slaughter Texas A&M University, claims that horse slaughter is “doing the right thing for the animals.”
These pro-slaughter articles, which somehow found their way into a discussion on live horse export, are very familiar to those of us who have been advocating against slaughter and live export for years. Over time, the purported claims became truth to many in the horse industry who were saddened to hear of such reports, and while conflicted about slaughter, began to believe that it was the better alternative for horses facing such neglect and abuse.
The “Horse Welfare” Alliance of Canada, which churns out its own brand of pro-slaughter propaganda and receives hundreds of thousands of dollars in grants from the Canadian government, asserted that live export is needed to enrich 347 breeders who provide purpose-bred horses, 25% being indigenous. A request for clarification on the number of indigenous exporters was answered by the CFIA National Issues Manager, who stipulated that there are no known indigenous producers of horses for export. While 347 breeders seems like a huge number of suppliers in this industry, the reality is that there are only 4 active exporters and the 2 largest breeders for export are in Ontario. The bulk of the profit from this industry goes to Ontarians, including WillJill Farms.
These primary exporters purchase horses from a few hundred producers (the remaining 343 approved “exporters”) from different farming situations. Most horse breeders supplying this market breed horses for other purposes and comprise a very small secondary market in an industry that is less than 20 years old.
There is little support by humane agencies and the general public for the continuation of this barbaric trade. A poll conducted by the BCSPCA found that only 22% of those polled want to continue the export of live horses. Equestrian Canada was approached as part of the stakeholder communication process and acknowledged that most of their members opposed horse export for slaughter. The BCSPCA also weighed-in with their opposition to the transport of horses overseas. Katherine Curry – President Racetracks Canada, announced full support for the Bill. Toolika Rastogi, PhD, senior manager, policy and research for Humane Canada, also reached out to decry the trade. Other stakeholders included the Winnipeg HS, The Canadian Horse Defence Coalition, and Animal Justice, who has recently carried out a successful private prosecution of live shipper Carolyle Farms (a legal avenue that would not be necessary had the CFIA decided to take action themselves). The government also acknowledges receiving letters in the “tens of thousands,” from individuals opposed to live export. Also included in the FOIA documents were several redacted letters from the general public.
Bill C-355 has passed the Agriculture Committee; once this process is complete, the chairperson of the committee submits a report back to the chamber and will move onto its third and final reading and vote at the House of Commons. It will go for a final vote in the House before moving to the Senate. Once the Bill receives Royal assent it wouldn’t come into force for 18 months. Senator Dalphond’s concurrent Senate Bill S-270 is also active.
Well-said, Senator!
Reading the contents of the FOIA and watching debates of the Standing Committee on Agriculture and Agri-Food, reminds us of how vigilant we must be challenging propaganda. At numerous points in the aforementioned debate, groups and individuals needed to correct the record on horse transport and the HAR as being some sort of divine document that ensured humane treatment. It’s exasperating to hear that politicians believe the standard of care for high-value, competitive horses is to ship them 4 at a time in flimsy wooden crates without food or water, just like slaughter-bound horses. Refuting incorrect information is essential for combating deliberate disinformation campaigns aimed at manipulating public opinion and sowing division. It requires vigilance, transparency, and a commitment to accuracy from all stakeholders, including governments, media organizations, educators, and individuals. Many groups and private individuals have written to correct the public record on predatory horse industries, including John Holland of the Equine Welfare Alliance. If you’re new to this discussion, please read some of his analytical writings, which directly address many of the falsehoods perpetuated by the above groups.
There is a growing international movement to end live export of animals, driven by concerns for animal welfare, ethical treatment, and environmental sustainability. Canada implementing a ban would signal its commitment to aligning with these global trends and adopting progressive policies:
A desperately lame mare was offered for sale at the Rimbey Livestock Auction Mart in Alberta, on June 16th. Video of the mare taken at the auction showed that she could not bear weight comfortably on her forefeet, and still images showed her standing in the classic laminitic stance, and lying down while other horses in the same pen were standing. This was a 13 year old pasture mate, weighing 1,070 lbs, who was described in the owner statement in the FOIA as “arthritic but not diagnosed by a veterinarian,” having suffered some kind of injury at the age of 5.
The mare was sold to a kill buyer and subsequently to Bouvry Exports, after potential rescuers were out-bid at the auction. As video evidence taken at the auction showed that the horse was barely ambulatory, the horse should not have been loaded on a trailer, yet, the mare had been loaded up for the (highly impractical and unnecessary) 4 hour journey to Rimbey and was ultimately slaughtered at Bouvry for the non-EU market on or about July 19, 2021, after being in transit for 3.5 more hours.
From The National Farm Animal Care Council (NFACC) Equine Code of Practice:
8.1.1 Fitness for Transport
“Horse owners and persons transporting horses have a primary responsibility for determining if an animal is fit for the expected duration of the trip. While the driver should not be relied upon to determine whether the horse is fit for transport, they have the right and responsibility to refuse to load a horse that they recognize as unfit.
Do not load horses with a reduced capacity to withstand transportation. These animals may show signs of infirmity, illness or injury (31). Never transport a horse unless you are sure it is healthy enough to withstand the stress of the entire expected trip (including intermediate stops). Each case must be judged individually, and the welfare of the horse must be the first consideration. If you are not sure whether a horse is fit for the trip, do not transport – contact a veterinarian.
When animals are unfit for transport, you must provide treatment until the animal is fit for the trip or not transport the animal, and, if necessary, euthanize the animal. Per the Health of Animals Regulations, it is illegal to load or unload a non-ambulatory animal unless the animal is being transported with special provisions for veterinary treatment or diagnosis, upon the recommendation of a veterinarian.”
The National Farm Animal Care Council is comprised of stakeholders primarily made up of farmers and veterinarians. What the NFACC has published are merely “guidelines,” which do not have the force of law behind them, as opposed to regulations, which are directly enforceable. So of course, sellers, auctions, kill buyers, and slaughterhouses thrive in the ambiguity of the language and lack of force in the guidelines.
CFIA Response to Growing Public Discontent
The FOIA response from the CFIA revealed that they received many messages of concern (friends might recognize their own message included in the PDF below). So the the Red Deer district office put on their CSI goggles and went to the auction house and contacted the mare’s owner (the EID is included in the FOIA documentation). The inspector’s report of July 22nd specifically made mention of the owner being asked whether the mare was administered any bute or banamine as a result of being “arthritic.”
It’s also revealing that while the owner admitted the horse was “arthritic,” and had a “slight limp” while getting off the trailer, the Rimbey auction response to the CFIA was that the mare was not lame when she came off the trailer, nor was she lame when she went through the auction (??!?) but because they placed her on a concrete pad over the weekend while the pens were being cleaned. Does anyone else think that the “concrete pad” is a convenient excuse for explaining acute lameness away to dismiss any future complaints about horses that can barely stand? And if concrete pads make horses stiff or lame, why put them there? It seems inconceivable after watching the video that this horse could be “offloaded at Bouvry with no apparent problems.” Has any animal ever been deemed too lame to ship by an auction mart or kill buyer?
Where this investigation falls down, as it usually does, is in the lack of accountability for transport by everyone involved, and drug testing of the remains of this poor suffering animal. The auction house claimed that the SPCA was also involved; any action taken by them (highly doubtful) is not included for our review. And as always, the CFIA seems to leave any testing up to the discretion of the slaughterhouse.
It’s my own opinion that it’s heartless and generally illegal to deny an animal pain-relieving medication, especially when a veterinarian or farrier indicates that it is in pain. I can’t decide which is worse – denying an animal medication because it might affect the ability to wring those last few dollars off of it, or “buting” it and sending it to slaughter anyway. This particular owner confirmed to the CFIA that they did not administer bute to lessen this mare’s pain and did not seek veterinary opinion.
When an animal is in this much discomfort, he or she is now on its own timeline, not ours. We can’t choose to euthanize it or otherwise end its life on our schedule. If your animal is diagnosed by a veterinarian as non-viable/in pain/unrecoverable injury, it is now our responsibility to humanely euthanize him or her to avoid further suffering. Auctions are merely dumping grounds used by many miserly, unfeeling owners.
“The pound of flesh which I demand of him Is deerely bought, ’tis mine, and I will have it.I am sorry for thee: thou art come to answer A stony adversary, an inhuman wretch uncapable of pity, void and empty From any dram of mercy.”
How often do you hear or see an ad that leaves you questioning the claims being made? Anyone who knows me knows that both online and IRL, I am a “super-complainer.” You really have no choice anymore, because “fake news” permeates literally every subject.
A few months ago I visited the Richelieu horse slaughterhouse website as I am wont to do every few months, just to see what nonsense they are purporting. There’s usually always something that can be used to launch an official complaint, and they didn’t disappoint. Claims about horsemeat for pregnant women and for those prone to infection really drew my ire. It’s not very smart to put out information that is so easily discredited. But nobody said horse killers are smart.
It took complaints to Ad Standards, Health Canada, and finally the CFIA (who acted upon the complaint) to do something about it. The CFIA didn’t say exactly what they did or what they counselled Richelieu to remove or stop posting on their website, but I was very pleased that they looked at my materials and saw that the horse killers were using language that amounted to a murky sea of nutritional “advice.”
Our community of anti-slaughter advocates is strong and engaged! If you see questionable or false claims being made about the quality or nutritional value of horsemeat or indeed any animal product, please contact:
It can be a daunting challenge for consumers to separate true advertising claims from false ones. This is especially true with industries that slaughter animals – in the interest of public image, they are anxious to avoid any terminology that suggests that animals in the food chain die horrible deaths. The term “processing” is now to be used instead of “slaughter,” because of the latter term’s association with mass murder. And while the CFIA heavy-handedly enforces decades old product descriptions that don’t take into consideration the proliferation of newly available plant-based foods, no one is minding the store at the Viandes Richelieu website, where the company makes claims, without evidence, that horsemeat is “good for pregnant women and anemics” and is advisable for individuals with “an increased risk of infections.” It looks like VR’s marketing department could use a good proofreader, or as they say in French, un bon relecteur. So what’s going on here? Is this a faux pas, or a jeu de mots gone wrong?
These types of random statements are pretty risky claims for a slaughterhouse to make. Health Canada has some pretty onerous “Guiding Principles” for product labels and advertising about food characteristics and related health benefits – obviously, because these types of claims influence people’s buying habits. And Health Canada’s standards of evidence are generally consistent with those of other scientific and regulatory authorities, including the European Food Safety Authority.
Consider that “a health claim is a statement or representation that states, suggests or implies that a relation exists between a food or component of that food and health” in Health Canada’s guidance documents on nutrition. These types of claims (about infection and health in pregnancy) fall under “Disease risk reduction claims” and “function claims.” When someone advertises a claim about their product’s ability to treat a health condition, mitigate a disease, or about restoring, correcting or modifying body functions – they must be prepared to back it up. Ideally, the company is supposed to submit these claims to Health Canada so they can be reviewed BEFORE publishing them anywhere. Neither can a company typically make non-specific or general claims (for example, “horsemeat is beneficial to health” or “horsemeat supports immune health”) since these are subject to multiple interpretations and are potentially misleading.
Making health claims are totally optional for a food product. But if and when a claim is made, it must be truthful and not misleading, according to Subsection 5(1) of the Food and Drugs Act. This means that producers must have scientific evidence to substantiate a food health claim prior to its use. Subsection 3(1) of the FDA goes on to state that no person shall advertise any food, drug, cosmetic or device to the general public as a treatment, preventative or cure for any of the diseases, disorders or abnormal physical states referred to in Schedule A.
There are some great precedents whereby manufacturers have been slapped down for making dubious or unsupported claims in the past. One of the most famous examples occurred when, in 2011, the Kellogg Co. paid $5 million back to consumers for making the common claim that its Rice and Cocoa Krispies can help a child’s immune system, shortly after a similar settlement concerning its Frosted Mini-Wheats.
The marketing folks at Viandes Richelieu must be under terrible pressure – they blame activists for the unpopularity of their product in an article published in the French language Journal de Montréal.
“There is no restaurant that wants to use it because of the threats. We, too, have it continuously. Our equipment must be monitored 24 hours a day,”declared spokesperson Marc Bouvry in a translated statement about the Bouvry operations in Alberta (VR is also part of the Bouvry horse slaughter empire). Hey Marc, maybe this industry isn’t worth it – at least, that’s the consensus of about 69% of Canadians. Time to find more socially acceptable work. So that’s why I’ll be writing to Health Canada, to ask them to make a determination about the appropriateness of these claims made by Viandes Richelieu. Not too long after sending a letter to Advertising Standards Canada about statements made on Richelieu’s website in 2011, I received a response from ASC indicating that the company had revamped their website to remove the misleading claims.
I didn’t realize that you could request a purebred horse steak (or an “old half-bred” for that matter either).
A few months ago the CFIA funded a study of sausages that determined that 20 per cent of samples from grocery stores across Canada contained meats that weren’t on the label. The study, which was prompted by the European horsemeat scandal of 2013, was conducted by researchers at the University of Guelph, and DNA profiling was used to detect the species found in sausages that were labelled as containing just one ingredient – beef, pork, chicken or turkey.
Seven of 27 beef sausages examined in the study were found to contain pork. One of 38 supposedly pure pork sausages contained horse meat. Of 20 chicken sausages, four also contained turkey and one also contained beef. The contamination isn’t exactly surprising (if processing facilities have horsemeat, they need to find a way to get rid of it). The CFIA investigated all cases of mis-labelled sausages and in the case of the chicken labelled as turkey, it was able to find issues with a manufacturer’s “traceability program” – incoming meat and production records were not properly maintained. The incident concerning horsemeat was not investigated because the company responsible voluntarily ceased operations (the way all slaughter operations should end). Explanations for the adulteration of the remaining sausages appears to be more complex.
There are usually two kinds of food adulteration – where the butcher/supplier deliberately or accidentally adds another species, or simple cross-contamination – meat can also come into contact with knives or preparation materials. Since the CFIA reported that the contamination was not found at trace amounts, we should assume the adulteration occurred as a result of either outright fraud or incompetency in handling/labelling meats.
My initial ATI to the CFIA requested the brand/store names where the sausages had been purchased – this is, IMO, one of the most important details that was never published in any report. The CFIA complied with the paperwork included below, but the open-records request remained only partially complete. After much follow-up, the CFIA indicated that they were prepared to release this information, but their attempt to disclose identifying details about the sausage supply chain was met was met with a refusal to comply by the named companies. According to the provisions of the Access to Information Act (ATIA), respondents are asked to agree to disclose information to the requesters in an open-records request. So an application was made for judicial review in order to attempt to remedy this refusal to disclose. Judicial review of an administrative action is only available for decisions made by a governmental or quasi-governmental authority. The practice is meant to ensure that powers delegated by government to boards and tribunals are not abused, and offers legal recourse when that power is misused, or the law is misapplied. Judicial review is meant to be a last resort for those seeking to redress a decision of an administrative decision maker.
It’s alarming that the identity of the companies who failed to protect consumers from this food adulteration may end up being concealed from the public, depending on the findings of the judicial review. Food adulteration, whether unintentional or fraudulent, is not victimless. What is at stake is the entire food economy. Consumer trust is being lost – the industry also hurts itself since it’s unlikely that consumers will pay more for a product they suspect may be adulterated. The Grocery Manufacturers Association (GMA) recommends that voluntary audit and improved detection programs are a deterrence to food transparency issues. Suppliers are encouraged to facilitate appropriate testing procedures and retailers to partner with academia to forecast risk, and with suppliers and manufacturers to verify authenticity of the products they receive. It sure sounds like the retailers who distributed these sausages have no testing/audit programs of their own to verify that the labelling accurately represents the contents of the products they purchase!
We know that despite horsemeat being consumed in Quebec and a few restaurants throughout the country, the only way to sell large quantities of it is to disguise it as something else. Clearly the demand for horsemeat is not there in the marketplace, otherwise it could be sold as-is.
Let’s hope that the protection of brand integrity does not supercede the rights of consumers.
“…all horse meat producers must obtain the health and medical history – complete with information on all drugs and vaccines used – of each horse for the 180 day period before consumption.”
– standard form letter response from Conservative MPs – 2016.
Whenever I read documents obtained through an Access-To-Information request, I think the bar for this industry cannot go lower. The ATI documents included here covered all Equine Lot Inspection Audits for the years 2015-2017 year-to-date, and captured conversations between CFIA veterinarians and feedlot/auction staff. These Lot Inspections are audits that are carried out approximately once a year, although it appears that our favourite Farmville operators, Bouvry Exports’/Prime lot is being audited more frequently. When you read the audit reports, you’ll understand why – the CFIA appears to be doing a fair bit of manual checking of their record-keeping.
It should really come as no surprise that feedlots and auctions have a perpetual struggle with the paperwork required to track horses from receipt to slaughter. Kill buyers are bottom level feeders who travel from auction to auction picking up horses. They have no idea where these horses come from, nor do they care. Auctions and feedlots typically will complete just enough paperwork so that can scrape by, and they’re going to fill it out in the way that it needs to be filled out so that it meets the CFIA criteria. Sometimes though, they can’t even meet the minimum standard and even the CFIA has to write them up when uncomplicated record management tasks are turned into Sisyphean clusterfucks.
So what is the Lot Program and how does it work?
The lot program is used by high volume accumulators of horses for the purpose of slaughter. It’s really a sort of “express lane” in that these producers use a group declaration (the Lot-EID or LEID) in lieu of individual EIDs. The program requires at least a 180 day recorded history prior to slaughter. Lot inspections review the procedures maintained in Lot Programs for equine feedlots – this covers the control of EIDs (Equine Information Documents), vaccines, medications, movement of horses in and out of each lot and a few other criteria. Please note that the lot program does not verify the health of any equines or the condition of the feedlot itself. The CFIA describes the process in more detail if you need it.
If you’re new to the horse slaughter issue, here’s a bit of history on the EID – its implementation was announced by then-Director of the Meat Programs Division of the CFIA, Dr. Richard Arsenault, in a response letter to the European Commission on October 23, 2009. Arsenault announced that, in order to meet EC requirements for exporting horsemeat, every equine presented for slaughter as of July 31, 2010 would be accompanied by an Equine Information Document.
Fast forward to 2014 when the European Commission’s Food and veterinary Office released an audit in 2014 that raised concerns about the tracking process. In 2011 the same issues were raised, so you could say there’s little evidence of improvement. You can read the final report, the response, and the CFIA proposed changes.
The audits reveal that, shockingly, Bouvry Exports/Prime Feedlot holds anywhere from 7,000 – 10,000 horses at any given time. According to the audit reports, a total of 52 lots of horses are sent to their deaths each year (1 lot per week). Additionally, horses who receive any medication while on the lot are subjected to painful branding and re-branding as part of the record-keeping process.
Forms Are So Hard And Confusing!
The February 2016 audit of Bouvry’s Prime Feedlot (where the report indicated 10,000+ horses were on-hand) contained some findings flagged as “unacceptable” by the Veterinarian-in-Charge:
Finding #6 and #7 (see pages 31 and 35): – “…drug list was changed in August but not updated. CFIA wasn’t informed. Instead of Derapen (penicillin G Procain) which is no longer available, Biomycin is used since August 2015. Biomycin is not authorized to be used yet.“ At the time of writing, Biomycin is not even listed on the Meat Hygiene manual for equines. The manufacturer of Biomycin states that is has a withdrawal time of 28 days (for cattle).
Finding #20 (see page 32 and 36): – “One of the records reviewed was not transferred from daily vaccine application records (lot records) to a Lot Equine Information Document. Fluvac vaccine application was missing. All other records verified during the audit were accurately transcribed.”
Finding #25 (see page 33 and 36): – “No EIDS on file, none reviewed. [Redacted] said the horse [kill] buyers did not supply any of EIDS [SIC] along with horses purchased. This issue was discussed at the previous audit and Prime Equine Lot.”
So there were no EIDs on file for an entire lot of horses? What happened to slaughter-bound horses without them? There is no mention of what became of them, or whether anyone attempted to locate the missing paperwork, although I presume the horses were slaughtered anyway, no matter how laughably incomplete or non-compliant the paperwork was.
“It is the responsibility of the Lot Program management to request EIDS and verify for non-permitted drugs.”
Supplemental Export Reports for a May 2016 visit that summarizes communications with regards to an Operational Guidance protocol distributed in February 2016. (page 45-47)
Perlich Bros. Auction gets called out for not collecting EIDs:
“[Redacted] contacted [redacted] of Perlich auction market over the phone in April 2016 (specific date unknown). The purpose of the call was explained, and [redacted] was asked about the creation of EIDs at his auction market. [Redacted’s] response was that, while [redacted] staff were happy to handle any EIDS that are submitted with equines for sale, no effort is made to ensure that horses enter auction with complete EIDS, that is is [SIC] “not their job,” and that the responsibility for obtaining valid EIDS lies with the buying agent. Very few are thus processed at [redacted] auction.” At this late stage (7 years after the implementation of the EID), how is it that the incomprehensibly stubborn auction staff can give the standard disclaimer, “that’s not my department?”
CFIA resorts to googling kill buyers/plant management for follow-up information:
“On 12 April [redacted] received a list of buying agents for the Bouvry plant from [redacted] who was, at the time, a CFIA meat hygiene inspector at the plant. When contact information was requested for these individuals, so that upcoming verifications could be discussed, it was requested that an explanation/reasoning for the request be sent directly to plant management. This was done by [redacted] on 13 April. Having not received a response by early the next week, a Google search was conducted to find a contact number for [redacted] spoke to [redacted] over the phone on 18 or 19 April. The potential for CFIA presence at upcoming horse auctions was discussed, as was the method with which he goes about obtaining EIDS for slaughter horses. [Redacted] reply was that [redacted] no longer buys horses for this purpose (slaughter) at Perlich auction because of the difficulty of obtaining EIDs. [Redacted] rather focuses on the Innisfail Auction Market (IAM) where all horses enter auction with EID unless explicitly declared by the owner that the animal is not for meat sale. There [redacted] is able to enter the ring and verify that the EID is acceptable before bidding on the horse.”
So who is “redacted” in this scenario? Clearly there is more than one person whose name has been concealed. Either this person is a kill buyer(s) or plant management, in which case, if they didn’t respond to the CFIA enquiry, that’s pretty inexcusable.
“[Redacted] encouraged the CFIA to audit [redacted] activities at the IAM.”
CFIA to Bouvry – EIDs must accompany all horses to the feedlot:
“It was felt that in order to conduct the verification task correctly, the district needed to be clear on whether or not it was permissible for horses bought in Canada to enter the feedlot system without an EID…” “The response was that unless there was some other auditable means (on file) of ensuring a history of no non-permitted substances in the horse(s) no horse without a valid EID is allowed to enter the feedlot, despite a six-month waiting period.”
The CFIA’s attempt to enforce what must seem like an unfathomable bureaucracy apparently perturbed staff at Bouvry’s, who sent an inquiry to the CFIA asking why [redacted] was “asking so many questions.” Due to the difficulties with paperwork at the Perlich auction, the CFIA discussed attending their auction on overtime and it was decided that this was not a valuable use of CFIA resources. Recommendations were passed to the Red Deer CFIA office for a vet inspector presence at Innisfail.
The confusion that continues to this day over the EID and other paperwork is evidence that inputs into the food chain are not something to be taken casually, yet that is exactly what is happening. The doubts highlighted in these reports leave another cloud over the already sordid industry – something policymakers need to pay attention to.
Despite this, Dr. Richard Arsenault, former director of the meat programs division for the Canadian Food Inspection Agency (CFIA), thinks that the regulations are working. “It’s extremely well respected in terms of compliance” – a statement that he has continually championed throughout the years. This is basically the same feeble confirmation that is echoed by anyone in charge of any aspect of the meat program at the CFIA. Downstream, MPs may take months before they reply to our complaints about horse slaughter, and if they do it’s usually nothing more than the standard form letter that doesn’t even address the concerns raised by the constituent. Instead, the response parrots the same impotent reassurances put out by the CFIA.
The horse slaughter pipeline is one of the most unregulated livestock venues in North America. There is absolutely no desire or motivation on the US side to enforce EID authenticity because Americans do not eat horsemeat. There is no resolve on the Canadian side because they are importing horses for the purpose of (primarily) exporting the meat. Regulating this paperwork would cost everyone money, and no one wants to do that.
Phenylbutazone or “bute” was at one time marketed for humans use under the trade name of Butazolidin. It was a Non-Steroidal Anti-Inflammatory (NSAID) used for arthritis and other inflammatory ailments that worked by inhibiting an enzyme that synthesizes chemical mediators called prostaglandins. It was ultimately withdrawn by the FDA for causing a wide range of serious side-effects. It remains however, on the market for treatment for horses and is an effective anti-inflammatory. It is also prohibited in the food chain as residues of bute and its metabolite, oxyphenbutazone are not known to have safe limits. None of this is new information to experienced horse advocates. Therefore, it’s always personally surprising to me when I come across another horse advocate who takes the position that we needn’t be concerned about bute adulteration in food. It’s a pretty rare position to take, IMO, and reaffirms to me that not all champions of the horse are on the same page when it comes to advocacy. This position not only harms our advocacy, it’s also scientifically illiterate IMO.
Writing in a recent blog post, Founder and President of the Equine Rescue Network Janine Jacques goes all-in and on the record as being in doubt that bute is harmful to people. Jacques also assumes that the only possible toxic result from consuming bute or metabolites can be aplastic anemia.
“How did the consumption of over 16 million pounds of horsemeat impact the health of those who consumed horse meat tainted with bute? ~ If Google search deaths from phenylbutazone you will find no relevant deaths for humans.”
While investigation and surveillance of overdoses and poisonings by phenylbutazone are available, there is a tendency to believe that, in order to be hazardous to health, only large amounts of a chemical are needed to cause poisoning. This is not necessarily so. A highly toxic chemical can have a low health hazard if it is used with proper precautions and care. On the other hand, it is possible that a chemical of low toxicity may present a high health hazard if it is used inappropriately, such as in the food supply. The domain of published works in the field of toxicology contain many presuppositions such as this; regulators have always had difficulty establishing acceptable levels of chemicals and they are expected to show evidence that a level of exposure is harmful before they can ban its use.
Virtually all evidence we have about harmful dosages of drugs come from animals where extrapolations are made from high doses (LD50, Draize, and ADME – Absorption, Distribution, Metabolism, and Excretion tests for example) . It is also said that effects found in animals in relatively short-lived species cannot necessarily be used to estimate the effects in a long-lived species such as human. Humans live much longer than most of the species used for drug testing, so we have a longer period of time in which to manifest disease. Compounding this, we know that much of human disease is idiopathic in nature – without known causes. Forensic toxicology testing can detect drugs in the blood stream or urine and overdoses in the emergency room, but it can’t predict the cause of idiopathic disease.
What makes chemicals poisonous?
There are several factors which can influence the degree of poisoning caused by a chemical.
Route of entry into the body – orally, inhalation, etc
Amount or dose entering the body
Chemicals that are weakly toxic require large doses to cause poisoning, Strongly toxic chemicals only need small doses to cause poisoning
Chemicals that are broken down by the body into sub-products before being excreted may be more or less toxic than the original chemical
Biological variation in the person consuming the chemical/drug determines response – slow metabolizers may be affected in addition to those who have susceptibility to phenylbutazone due to different metabolic genes (polymorphisms) that encode enzymes that are involved in the metabolism of drugs.People who are poor metabolizers of a drug may overdose while taking less than the recommended dose. Altered or enhanced drug metabolisms in individuals have been known to cause fatal drug reactions.
PBZ Molecule
Another layer of complexity is added when humans are exposed to chemicals at very low doses – the chemicals may reside in certain regions of the body that are more susceptible to organ damage which is impossible to measure directly. Studies have shown that many chemicals impact cancer-causing pathways at low doses. Taken directly, phenylbutazone is associated with various hematologic disorders, including aplastic anemia. Bute is also a cause of agranulocytosis, which can also be fatal. Hypersensitivity reactions can include anaphylactic shock, arthralgia, fever, angiitis (polyarteritis), vasculitis, serum sickness, adenitis, hepatotoxicity, allergic alveolitis, lymphadenopathy, Lyell’s syndrome, activation of systemic lupus erythematosus, and aggravation of temporal arteritis in patients with polymyalgia rheumatica. Asthma may be precipitated or aggravated by phenylbutazone, especially in aspirin sensitive patients. We also know that phenylbutazone interacts with many other drugs. When administered to lactating cows, it was found that phenylbutazone was distributed into their milk.
When the drug was used therapeutically in humans as Butazolidin, the dose rate would have been around 2 to 6 mg/kg, similar to the current dose for the horse of 4.4 mg/kg. The question is whether the presence of bute in horsemeat can present a risk to human health even in small amounts. Around the time of the 2013 horse meat adulteration scandal in the EU, the highest amount of bute found in a horse carcass was 1.9 mg. If a human had been taking Butazolidin in the 50s, they might have taken 200-400 mg a day in total, if we compare it to the current-day dosage of Tylenol or Advil. Obviously, we would have to consume a significant amount of contaminated horsemeat in order to reach the level of a therapeutic drug dosage. What is not clear, despite reassurances, is the level that is necessary for the average person to consume in order to experience a toxic effect. If a therapeutic dose of Butazolidin was once considered “safe” at 200-400 mg, then how do we know that some individuals are safe at 1.9 mg? If Butazolidin was withdrawn from the market as being unsafe for some people at that dosage, we don’t know whether sensitive individuals may have experienced toxicity at lower levels as well.
If it still seems as though a negligible trace of bute in meat might not be enough to cause harm, there is an analogous cautionary tale of another NSAID – diclofenac, which was also used in human medicine for decades, and was recently introduced for veterinary use in India. Obviously, the dynamics are not the same, but vultures appear to have been exposed to the drug while scavenging livestock carcasses, their main food source, and this has accounted for death by renal failure of many vultures examined in a three-year study by the scientific journal Nature. Further investigation showed tissue residues in livestock treated at the labelled dose rate were sufficient to cause death in vultures. These findings confirmed that diclofenac is the primary cause of the Asian vulture decline.
“Diclofenac is toxic to vultures even in small doses, causing kidney failure. That results in uric acid accumulating in the birds’ blood and crystallizing around their internal organs—a condition called visceral gout.”
Food safety laws are clear. Companies that produce, trade or sell food or food ingredients are legally obligated to implement a quality assurance system called Hazard Analysis and Critical Control Point (HACCP), which maximizes food safety by minimizing chemical, physical and microbiological hazards. There is something wrong with a food system whereby the food animal must sit on a feedlot for six months in order that veterinary drugs “degrade” before it can be eaten.
For years, regulators relied on the old adage “the dose makes the poison, which still holds true for many drugs and chemicals. But one key message there is that source or origin of a chemical usually tells you very little if anything about its toxicity or ability to cause harm. We now live in a time where exposure to chemicals is unavoidable and we can’t evaluate these chemicals in isolation. Having said that, bute is not a chemical that is ubiquitous in the environment like other toxins we are exposed to – we can avoid it by not eating horsemeat and not killing horses for food. In the final analysis, no one is really in a position to make broad statements about the safety of horse meat. Conrad Brunk, the co-chair of the 2001 Royal Society of Canada Expert Panel on the Future of Food Biotechnology, wrote that:
“When it comes to human and environmental safety there should be clear evidence of the absence of risks; the mere absence of evidence is not enough.” This is the essence of the Precautionary Principle, which states that “when an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause-and-effect relationships are not fully established scientifically.” The toxicity of a chemical cannot be changed, but the hazard it presents can be controlled.
“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:
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!
Contact
Richard Arsenault
Executive Director
Domestic Food Safety Systems and Meat Hygiene Directorate
Canadian Food Inspection Agency
1400 Merivale Road, Tower 1
Ottawa, Ontario
K1A 0Y9
Telephone: 613-773-6156
Email: CFIA-Modernisation-ACIA@inspection.gc.ca
In Japan, “premium consumption,” a philosophy in which consumers do not mind spending large amounts of money on trendy products or services, is on the increase. The Japanese are embracing “members-only” clubs and resorts to the tune of ¥355 billion ($4,176,200,000 CDN), up 13 percent from 2015. Horsemeat is increasing in popularity in Japan due in part to a boom in sushi restaurants and exclusive dining clubs, and is sold as sakura nikku (cherry blossom meat) or raw as basashi.
The English language paper The Japan News, provides a first look at these exclusive and often very secretive restaurants serving what must be our Canadian draft horses, who are live exported almost every week on 16-18 hour flights during which time they are neither fed nor watered, generally by Atlas Air. Prior to shipment to Japan, our “gentle giants” are fattened up to gross proportions, and at risk for laminitis. Each horse is worth approximately $20,000 CDN.
In Tokyo, The Roast Horse is a members-only restaurant that has a set course menu of ¥7,500 ($88.00 CDN). The Roast Horse solicited its clientele via crowdfunding to collect money for a custom-made stone oven. The restaurant was able to generate about ¥6 million ($70,000 CDN). Membership at the restaurant is considered a privilege for the investors.
Photo from an Acess-To-Information Request by the CHDC. We know that horses are dying while enroute to Japan, where horsemeat is preferred “fresh,” hence the live export. These flights are illegal as Canada is in breach of two sections of our own Health of Animals Regulations and IATA Live Animals Regulations.
“As the door opened, all 30 or so seats in the restaurant were occupied. Owner Mineyoshi Hirayama was serving customers a series of horse-based dishes, such as raw and roasted horse meat, while describing the details of the horseflesh he bought and the cooking methods. “What’s great about this restaurant is that it is exclusively members who can book a table. What’s more, we can taste horse meat that can’t be eaten at any other places,” said information technology journalist Masakazu Honda, who is a member. “All the people I have brought here have been delighted. This is a special restaurant.”
If you’re not familiar with the entire sordid live horse export business to Japan, please read the Canadian Horse Defence Coalition’s comprehensive investigative report here.
Call To Action:
Please sign and share the active petition to Atlas Air to end the horrid practice of live export to Japan.
Written by: Heather Clemenceau
Subsection 5(1) of the 
Of 20 chicken sausages, four also contained turkey and one also contained beef. The contamination isn’t exactly surprising (if processing facilities have horsemeat, they need to find a way to get rid of it). The CFIA investigated all cases of mis-labelled sausages and in the case of the chicken labelled as turkey, it was able to find issues with a manufacturer’s “traceability program” – incoming meat and production records were not properly maintained. The incident concerning horsemeat was not investigated because the company responsible voluntarily ceased operations (the way all slaughter operations should end). Explanations for the adulteration of the remaining sausages appears to be more complex.
My initial ATI to the CFIA requested the brand/store names where the sausages had been purchased – this is, IMO, one of the most important details that was never published in any report. The CFIA complied with the paperwork included below, but the open-records request remained only partially complete. After much follow-up, the CFIA indicated that they were prepared to release this information, but their attempt to disclose identifying details about the sausage supply chain was met was met with a refusal to comply by the named companies. According to the provisions of the Access to Information Act (ATIA), respondents are asked to agree to disclose information to the requesters in an open-records request. So an application was made for judicial review in order to attempt to remedy this refusal to disclose. Judicial review of an administrative action is only available for decisions made by a governmental or quasi-governmental authority. The practice is meant to ensure that powers delegated by government to boards and tribunals are not abused, and offers legal recourse when that power is misused, or the law is misapplied. Judicial review is meant to be a last resort for those seeking to redress a decision of an administrative decision maker.
from the public, depending on the findings of the judicial review. Food adulteration, whether unintentional or fraudulent, is not victimless. What is at stake is the entire food economy. Consumer trust is being lost – the industry also hurts itself since it’s unlikely that consumers will pay more for a product they suspect may be adulterated. The 
Written by: Heather Clemenceau
Written by: Heather Clemenceau
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?
decentralized to the slaughterhouse – the CFIA needs to exert control over EIDs and publish the results of audits in the interest of transparency.
The 
heatherclemenceau 
