Tag Archives: Meat Hygiene Manual

Horse “Passports” Come Up Lame At Saskatchewan Auction – Will CFIA Take Corrective Action?

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larry_the_cable_guy_health_inspector_xlgWritten by:  Heather Clemenceau

Hat Tip:  Debby

The Johnstone Auction Mart in Moose Jaw Saskatchewan sells over 1,000 equines per year  in lots or as riding horses – minis, yearlings, bucking stock, mares and geldings in both “medium” and “good” condition.   Selling prices range from about $25 up to $4,400 (more for lots).  The average prices for horses they advertise as “older” is $200-$400,  which of course are within the realm of slaughter prices.

Like most auction websites,  they provide a link to the Equine Information Document (EID) which the CFIA has always told us is mandatory for slaughter-bound horses.  But  auction management have a rather unique way of interpreting who needs to fill one out.

Their website states:

“Horses sold at Regular Horse Sales must have the following document filled out regarding  and drugs [sic] which may have been given to the horse in the previous 180 days.  Although not mandatory,  it is in the seller’s interest to fill one out for each horse so the price is not discounted.

Yearlings, and miniatures and donkeys do not need an EID form.”

johnstone-auction-mart

 

This statement struck me as extremely odd,  mainly because they touted the EID as a “mandatory,  yet optional” document,  and also because they indicated that it was not required for yearlings, minis, or donkeys.  It is the slaughterhouses’ responsibility to ensure that a valid EID has been submitted for each equine they receive,  but if it is only optional at any auction,  who will collect it if not the sale barn itself?  And why were some equines seemingly exempt?  Both the Meat Hygiene Manual of the CFIA and farming Codes of Practice,  when referring to equines,  consider that the term “horse” refers to all domestic equine species, namely horses, ponies, miniature horses, donkeys, mules and hinnies.

eid-from-meat-hygiene-manual

From the CFIAs Meat Hygiene Manual….

After navigating my way through the CFIA’s new phone system with 78 menu options and 7 levels,  designed to discourage all but the most indefatigible caller,  I was transferred to various people whose mailboxes were all full and there was no way to backtrack.  The whole idea of all the options and levels is to deter you from actually getting anything done. It cuts down on the number of complaints and support that must be provided.  Normally,  to get the fastest service I would press any number that indicates to the organization that I am likely to spend money on more service,  but that clearly won’t work with the CFIA. Ignoring the menu options and sitting on hold waiting for someone to answer won’t work either. When when I finally reached a live person they both grilled me to find out why an Ontarian would have any interest in something happening in Saskatchewan.  How about just answering the question?

Mini horses are uneconomical to ship long distances to slaughter. But if an opportunity presents itself, they are still considered to be “meat on the hoof.” Photo courtesy of Tierschutzbund (Switzerland) taken on a feedlot in Alberta.

Mini horses are uneconomical to ship long distances to slaughter. But if an opportunity presents itself, they are still considered to be “meat on the hoof.” Photo courtesy of Tierschutzbund (Switzerland) taken on a feedlot in Alberta.

I finally spoke with two veterinarians,  neither of whom appears to have any idea what really happens at a horse auction even though both were familiar with this particular business. Dr. Allison Danyluk Ross,  a supervisory veterinarian for the western operations of the CFIA  helpfully reassured me that not all horses at auctions go for slaughter.  She reiterated that it was not the auction mart’s responsibility to collect EIDs at all,  but that somehow,  they must arrive with horses presented for slaughter.  So it’s the owner’s responsibility to fill out the EID,  but it’s not mandatory, and it doesn’t have to be filled out at the actual auction, so by what other means would it arrive at the slaughterhouse if the horse is sold to a kill buyer? (that’s a rhetorical question,  dear readers).

Once again, any form that only asks for voluntary declaration of drugs is unlikely to be complied with when the seller wishes

These young mules were photographed by me at the OLEX auction in Waterloo Ontario on July 5, 2016. I was unable to stay to find our whether they went to a private home or were sold to a kill buyer. The fact that they are mules is not an impediment to slaughtering them, despite what the CFIA thinks.

These young mules were photographed by me at the OLEX auction in Waterloo Ontario on July 5, 2016. I was unable to stay to find our whether they went to a private home or were sold to a kill buyer. The fact that they are mules is not an impediment to slaughtering them, despite what the CFIA thinks.

to dispose of the horse for profit. I had to ask Dr. Danyluk Ross twice why minis, yearlings,  and donkeys do not require EIDs at this auction before she finally responded that she would pass my concern onto the Red Meat Specialist. Obviously Dr. Danyluk Ross believes everything is fine because the CFIA audits the paperwork – audit reports are only useful if someone in authority at the CFIA  reviews the results, understands the risks addressed by the standards and makes risk-reduction decisions based on the results.  Indeed,  Canada’s food safety system is a patchwork of third-party audits, personal assurances (like Dr. Danyluk Ross’ email), and profit before protection.

When veterinarian Dr. Harry King was asked why Johnstone Auctions would indicate on their webpage that minis, yearlings and donkeys brought to the auction would not require an EID,  he replied,  “because we don’t slaughter them in Canada.”  He also said that Johnstone Auctions focuses primarily on goats and cows and not horses,  and that they are not a “horse slaughter auction.”  Dr. King is dead wrong,  since the Donkey Sanctuary in Guelph acknowledges rescuing donkeys from slaughter (albeit,  in the province of Ontario) and kill buyer Eddie Kohlman is known to frequent the Saskatchewan horse auctions.

So much energy is spent on denial rather than enforcing legislation and regulations that already exist. Any belief or

suggestion that EIDs are consistently completed by owners invites some serious criticism.  In the Canadian Horse Defence Coalition’s investigation – “Pasture to Plate,” there can be no dispute that, when reviewing the EIDs included in the document, a pattern emerges and it is very clear to see that some EIDs have obviously been “pre-written” across the top with “Drug-free six months,” and the appropriate boxes checked to agree with this information.

Why did the CFIA inspectors and slaughter plant operators not flag this for concern? What remedial actions have the CFIA taken against auctions and owners that have submitted incomplete, incorrect or falsified EIDs?  In addition, what actions has the CFIA taken to ensure Canadian and American horses sold at auctions have EIDs that are filled in completely, correctly and truthfully by their owners?

Epiloque – September 21, 2016

Apparently the CFIA decided to act quickly on this one.  Johnstone’s horse auction page with incorrect EID instructions was quickly modified to remove the references to donkeys, minis, and yearlings.  You can see the change has been made here.  I believe someone at the CFIA intended to let me know of the outcome by phone,  as I had received a call,  but no one left a message.

Embryo Transfer – A Shadowy Market Ripe for Exploitation

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mare-services

Written by:  Heather Clemenceau

We’ve known for many years that farm animals have been exploited to produce more meat, milk, wool etc.  Embryo transfer in horses is another technology that is unrivalled for its inefficiency and costliness.  There’s also some evidence that embryo transfer (ET) is exploitative because it can be painful, requiring analgesics.  We recently read about the cast-off recipient mares (the “gestational” carriers that give birth to foals of a different mare/stallion) from the Arnold Reproduction Center  who were consigned to the Kaufman kill pen/kill buyer Mike McBarron for eventual slaughter.   Once exposed on social media platforms, veterinarian Leea Arnold responded:

“I recently sent some mares to the Cleburne Horse Sale.  I certainly never intended for them to end up in the slaughter pen. Many of these mares came to me through the sale barn system, were sick, completely unbroken and certainly destined for slaughter at that time (15 or so years ago). As long as these mares are reproductively sound, they stay in my herd – many probably longer than they are useful. My staff and I have taken the time, money, and resources we have to help these mares become useful and give them a viable purpose.

“I will use another avenue to re-home these mares in the future. If you are a non-profit organization and have your 501(c)3 at hand, I would be more than happy to donate any older or reproductively unsound recipients to your facilities as they become available.”

Dr. Arnold did not otherwise offer to help the animals that were scheduled to be sent for slaughter.

gypsyIn addition to horses, mules are also being used in at least one euphemistically named “mule mom” program  using embryo transfers from gypsy vanner mares.  The Gypsy Gold breeding program  in Ocala Florida charges up to $14,000 for a purebred gypsy vanner foal carried by a mule, who is often shipped to and from the Gypsy Gold Horse Farm and the contractor of their service.  They also helpfully offer a service for purchasers of the gypsy foal who are not satisfied with the quality of their new purchase – they will connect you with an “appropriate buyer” – quite possibly the same buyer who will purchase the mule moms once their fertility wanes.  At the moment, this farm offers 11 mares for breeding, so one can only imagine how many times they are being flushed out and the number of “mule moms” that are being used as gestational carriers.

Currently, most equine breed associations permit embryo transfer. Notable exceptions include the Jockey Club (thoroughbreds), the United States Trotting Association, and the American Miniature Horse Association. Brazil and Argentina are currently the leaders in equine ET, although it’s believed that about 10,000 embryos were collected and transferred in the USA in 2014. The practice seems to have become more widespread in 2015, with more countries reporting embryo transfer activities, including Canada, South Africa, France, Poland, Switzerland, the USA, and Mexico.

Why is Equine Embryo Transfer Also A Welfare Issue?

Because veterinarians can only flush fertilized eggs (embryos) from the uterus of a donor mares at specific times the cycles of one or more recipient mares must be synchronized with the donor mare. This is why reproductive vet clinics tend to have a wide selection of recipient mares from which to choose. The number of mares that some vet clinics keep on hand for this purpose varies from dozens of mares to hundreds.   In many cases the donor mare is synchronized with two or more recipient mares in the event that multiple embryos are recovered from the donor mare.  Obviously,  these mares’ “jobs” come with no guarantee of a home placement after their careers are over and may easily fall into the wrong hands.

There are potential welfare issues for a donor mare, including those associated with the flushing procedure and with repeat injections to attempt to induce ovulation when used. Because more than two mares may be involved, the number of invasive rectal and ultrasound examinations is increased. Where recipient mare numbers are limited, greater pharmacological manipulation (often involving repeated injections) may also be used to achieve ovulatory synchronization between donor and recipient mares.

While there are apparently no studies on whether ET is painful in mares, it is known to be painful in other species, especially those in which embryo flushing is a surgical procedure. Perhaps because of this it is common practice to sedate mares both during flushing and ET.

Transvaginal ultrasound-guided follicular aspiration in women is known to be associated with pain, the severity of which is dependent upon needle design. In sheep and goats, repeated surgical egg retrieval has been associated with the development of adhesions. In a study of pony mares who were the subject of invasive follicular procedures, it was observed that heart rates and cortisol levels increased considerably as soon as a needle was introduced into the procedure.

Lastly, the development of the “super ovulation” protocol and the resulting production of more oocytes (cells that develop into an ovum/egg) will heighten the possibility of more foals using larger herds of recipient mares, greater numbers of horses born that aren’t needed,  and more slaughter after the recip mares are no longer required.

Drugs/Hormones  Commonly Used in Equine Reproduction Practices and Their Withdrawal Times

Sources for withdrawal times were the Meat Hygiene Manual of the CFIA or drug datasheets.  It is important to note that withdrawal times are often extended when drug

Most donor mares are sport horses, Arabians or Quarter Horses. It’s an appealing option for those who can afford it, since it allows the option of the owner taking their mare out of competition for only about a week in order to produce a foal.

Most donor mares are sport horses, Arabians or Quarter Horses. It’s an appealing option for those who can afford it, since it allows the option of the owner taking their mare out of competition for only about a week in order to produce a foal.

combinations are used. Drugs used off-label in unapproved species may have differing withdrawal times even though appropriate dosage is given and whether used in combination with other drugs. The dose itself along with the frequency of use (repeated oral administrations can greatly extend withdrawal times) are two of the most important factors.  Compounded drugs (as opposed to generic or branded drugs sold OTC or through veterinarians) can vary widely in potency as well.  The amount of body fat, the breed, gender and health of the horse are also factors that affect kinetic decay of drugs.  Lastly, the amount of stress that the horse is subject to may also affect withdrawal times.  And even though a pharmacological effect on the animal may be over, the drug and its metabolites may still be detectable, and those metabolites may also be prohibited. The CFIA manual doesn’t tell anyone this, nor could they expect the lay horse person to understand any of the factors that also affect withdrawal times and drug tests,

Altrenogest/Progesterone/ Medroxyprogesterone (synthetic variant of hormone progesterone)

  • Trade name: Regumate®, Depo-Provera® (medroxyprogesterone)
  • Class of Drug: Hormone
  • Use:   Clinical uses include synchronizing the ovulations of a donor mare with a specific recipient mare. It may also be used to alter or manipulate the estrous cycle of a mare for a scheduled breeding due to stallion availability.
  • CFIA Withdrawal/Prohibition:  42 days withdrawal

Flunixin meglumine

  • Trade Name: Banamine®
  • Class of Drug: non-narcotic, nonsteroidal, analgesic agent with anti-inflammatory and antipyretic activity
  • Use: Reduces moderate inflammation by stopping the formation of prostaglandins, which are mediators of inflammation.  They also reduce the formation of certain pain-causing products of inflammation.  Embryo recipients may receive flunixin meglumine i.v. at the time of transfer.
  • CFIA Withdrawal/Prohibition: IV – 10 days/IM 30 days

Vedaprofen

  • Trade Name:  Quadrisol, VETRANAL
  • Class of Drug: Analgesic, antipyretic and anti-inflammatory agent, Non-steroidal anti-inflammatory drug, NSAID
  • Use: For the control of inflammation and relief of pain associated with musculo-skeletal disorders and soft tissue injuries in horses
  • CFIA Withdrawal Prohibition: 21 days (oral and IV)

Human chorionic gonadotropin (hCG)

  • Trade Name: Chorulon®
  • Class of Drug: Gonadotropin releasing hormone or GnRH
  • Use: Can also be administered to mares to accelerate ovulation selectively where needed to improve the degree of synchrony between the donor and recipient mares. Induces ovulation in mares. Induction of ovulation is advantageous if a mare is in a timed breeding, shipped semen, frozen semen or embryo transfer program.
  • CFIA Withdrawal/Prohibition:  0 days

Deslorelin Acetate

  • Trade Name: Ovuplant™ SucroMate™
  • Class of Drug: Gonadotropin releasing hormone or GnRH
  • Use: A potent, synthetic form of GnRH. The drug is administered as a subcutaneous implant.The most common use in a breeding program is the induction of a timed ovulation, such as when mares are being bred with cooled-transported semen or frozen semen
  • CFIA Withdrawal/Prohibition:  not on CFIA website but listed with a “WARNING: For use in horses (estrous mares) only. Do not use in horses intended for human consumption. For intramuscular (IM) use only. Do not administer intravascularly. Not for use in humans. Keep this and all drugs out of reach of children.”

Lidocaine Hydrochloride

  • Trade Name: Lidoject, Lidocaine HCI 2% etc.
  • Class of Drug: Local anesthetic and anti-arrhythmic agent.
  • Use:  Skin block for sutures and implants
  • CFIA Withdrawal/Prohibition: 7 days

Prostaglandins

Domperidone

  • Trade Name:  Equidone®
  • Class of Drug: Dopamine antagonist. Neurotransmitter
  • Use: Modulates or suppresses production of the hormone prolactin from the pituitary.  In breeding programs it stimulates lactation or the induction of lactation in nurse mares or the induction of follicular development. Also used as a preventative for fescue toxicosis.
  • CFIA Withdrawal/Prohibition: “no known manufacture for veterinary use in Canada”

Oxytocin

  • Trade Name: OxoJect™, Oxytocin-S
  • Class of Drug: Hormone
  • Use: Administered to mares for evacuation of uterine fluid and treatment of retained placenta. It may also be used for induction of labor in late term mares and milk let-down.
  • CFIA Withdrawal/Prohibition: not on website: 0 days

eFSH

 

The welfare of the animal is always compromised when greed is involved.  The ability for breeders to implant multiple embryos with no limits caters to the wealthy individuals in the industry. Rakhassa Bey While one might argue that ET is less risky than foaling for a mare,  horses should not have litters, especially since there is some question whether it is humane to repeatedly subject both recipient and donor mares to invasive procedures, after which many horses are dumped.  The worst  but hardly the only offender of this practice, the AQHA, allows multiple-embryo-transfer rules that facilitate overpopulation by allowing mares to have more than one foal per year. Rules about using frozen semen or eggs from long-sterile or dead animals  have allowed horses to breed from beyond the grave.  Consider that First Prize Dash,  a 1988 quarter horse mare – produced  44 offspring!  Her sire, Dash for Cash, sired 1,233 foals!  

It is also very doubtful  that either Canadian or Mexican slaughterhouses have tested for some of these lesser used or less obvious drugs or hormones.  Since some drugs/hormones are not even line items in the Meat Hygiene Manual, it would be easy for sellers of horses to plead ignorance of the requirement to disclose on an EID. Embryo transfer therefore facilitates  an already unsavory horsemeat industry in novel, previously unanticipated ways.