New Canadian Horse Slaughter Regulations – Part II

My last post on this subject addressed the new Canadian regulations for horses that will be slaughtered and processed for edible meat.

Check here for a recap of the new rules. 

How will the new regulations change the way horses are handled, both before and after shipment to Canada? 

Will the new regulations affect the number of horses sent to Canada for slaughter? 

Will the new regulations put additional pressure on the current alternatives to Canadian slaughter (rescues and/or slaughter shipments to Mexico, for example)? 

Probably no one knows the answers to the above questions for certain, at least not yet.   A few things are certain, though.  The new regulations pertain to documentation that must accompany a horse (domestic or imported) presented to a slaughterhouse that is inspected by the Canadian Food Inspection Agency (CFIA).  The regulations require, along with information identifying the animal, a statement about the animal’s health record and medications/drugs administered during the previous six months.  The only exception is a horse that’s younger than six months old.  Each person who owned the horse over the previous six months must make a statement about what drugs or vaccinations were administered to the horse and on what dates.  In the case of drugs, the statement must include dosages.  The statement must also disclose any illness diagnosed within the past six months, and specifically whether the owner has knowledge of the animal being treated with a drug on a list of banned substances.  The owner must certify that the information supplied is accurate and complete.

Is Canada’s move a good one?  From a food safety standpoint, it’s certainly a move in the right direction.  This is only the first in a series of new regulations that are intended to result in a database with full medical histories of horses by 2013.  By that time, horses that have been administered a banned substance will be flagged and ineligible for slaughter.  Much of the incentive for the new Canadian regulations is the issuance of new European Union regulations which went into effect in April, 2010.  The new EU rules pertain to all horse meat intended for human consumption – both domestic and imported.  In the EU where horses are more commonly raised for food, horses have an electronic “passport” linked to databases recording the entire health history of animals placed into the food chain.  Electronic passports are flagged as suitable for human consumption or unsuitable for human consumption.  In the absence of a full health history, the EU requires the horse to have a 180 day quarantine prior to slaughter.  Canada exports horse meat for human consumption to the EU, and is thus subject to the new rules.  It appears that the new Canadian rules are meant to comply with the 180-day quarantine rule.

What do the new rules mean for horses, livestock auctions and kill brokers?  If the kill broker doesn’t have a six-month health record from the previous owner, I suspect it means either a) the horse will have to remain in a feedlot for six months — either here in the US or in Canada — before being transported to slaughter, or b) more horses will be shipped to Mexico for slaughter.  Mexico will also have to abide by the EU regulations for exported horse meat, but Mexico also has slaughter plants for domestic consumption, which are subject to Mexican regulations only.  Do the current kill brokers who currently keep horses for a matter of days or weeks before shipment to slaughter have the facilities and the cash flow to hang onto and care for horses for six months?  Doubtful.  For those in the northern half of the United States, that could mean a very long trip for horses headed to slaughter in Mexico.  Is Mexico prepared for a bigger influx of slaughter horses from the US?  Are the highway patrols prepared to enforce the rules about shipping horses long distances without food and water or in double-decker trailers?  Note that in some states it’s not illegal to transport horses in a double-decker trailer if they’re heading for a feedlot.

Here’s an important point to consider:  the new Canadian regulations pertain to horses presented for slaughter.  They do not specifically pertain to horses crossing the border into Canada.  Horses crossing the border into Canada must have health certificates and negative coggins, a certification that they’ve been in the US for the past 60 days, and have not passed through certain states with communicable disease problems (currently, Arizona, New Mexico and Texas) within the past 21 days.  A horse can enter Canada without documentation required for slaughter.  However, once a horse makes its way into Canada, if it doesn’t have a history starting with January 31, 2010 it can’t enter the slaughterhouse.  Presumably, that means it’s off to a feedlot in Canada until a six month health history has been accumulated.  That’s up to six months of food and care — and additional cost.   I’m not sure whether standing in a feedlot constitutes “quarantine” under the EU rules — I’m still researching that.

The Canadian list of banned substances is quite a bit longer now than it used to be (although it still doesn’t include Ivermectin and Fenbendazole, two commonly used wormers that should not be used with food animals).  Is a horse standing in a feedlot more or less likely to need medication?  Feedlot operators are going to be faced with more challenges associated with six-month (versus days/weeks) stays:  quarantine, communication of illnesses and treatment of illnesses and worming.  While it doesn’t seem like the new regulations will decrease the number of horses crossing the border, it seems like the cost of getting them to slaughter will almost surely increase over the short term. 

Last but not least, the new Canadian rules don’t appear to have many enforcement “teeth” in them.  Owners need only say that “to their knowledge” their horse has not been given any banned substances.  The time period covered is only six months at the moment.  The new rules do not seem to have any requirements for more stringent testing of horses with a seemingly-clean six-month record, to detect banned substances, although the EU rules require it.  Until the new EU rules were issued, I understand that Canadian horses used for food were only routinely tested for roundworms.  Without a significant amount of testing, it seems that there is still risk that horses unsafe for human consumption will be getting into the food chain.  I would think that a Thoroughbred horse from the US with a lip tattoo would be an immediate red flag for testing, wouldn’t you?  If a horse has been given a substance that requires a withdrawal period, it’s off to the feedlot.  If a horse has been given a banned substance, then what?  Has anyone considered the huge increase in horses going to rendering plants that might ensue?  What arrangements will be made for humane dispatch of those horses heading to the rendering plant?

It will be interesting to see what (if anything) changes at U.S. livestock auctions as a result of the new Canadian regulations.  Will livestock auction organizers begin to require owners to provide sufficient information necessary to complete a Canadian Equine Identification Documents?  Will livestock auction operators flag horses with race or show records, and will kill buyers stop buying them?  Will Canadian slaughterhouses stop doing business with US kill brokers because the cost of a six-month quarantine is too high and the percentage of rejected horses is too high? 

If you go back more than 10 years to the 2005 study of the economic impact of the horse industry in the US, 81% of horses were used for racing, showing and recreation.  If we accept that percentage as probably still valid, then we only need to consider whether the majority of those horses have been treated with at least one banned substance in their lifetime.  I looked over the list, and believe that 80% of the horses in my barn have been treated with a banned substance at some time in their lives.  I don’t consider my horses part of the food chain, so I generally don’t pay much attention to the warnings on labels that read “should not be used for animals intended for food.”  I’d be willing to bet that most other people who care for show and recreational horses don’t think about that either.  

Therefore, my completely unscientific conclusion is that the majority of horses in the US used for sport or pleasure are simply not safe for human consumption and should not be sent to slaughter.  This is true regardless of other considerations about whether consumption of horse meat is good or bad, or slaughter of horses is humane or not.  From a food safety standpoint, I think most of the horses in this country are unsuitable to be used for food.

And then there’s the final, painful question:  what will happen to all those US horses who have been given banned substances?  In the short term, it might mean that they stand in a feedlot for six months.  If they can be identified before they get on the kill broker’s trailer, that’s good, right?  But where will they go?  Will horse rescues, already reporting that they’re full and turning away horses, be asked to take on even more horses?   I think the answer to that question is yes, and we’re back to the age-old question of how to cope with unwanted horses.  A topic I think about every day…  and if you’re a horse owner, I hope you do too.

1 comment to New Canadian Horse Slaughter Regulations – Part II

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