Rabbit Advocacy Animal Matters


Fall 2006: Animal Welfare, Codes of Practice, & Third-Party Audits

April 17, 2009 

From: Carmina Gooch
To: Office of the Auditor General
Re: Rabbit and Poultry Legislation 

Dear Sirs/Mesdames:

Canadians for the Ethical Treatment of Farm Animals (CETFA) recent report Broken Wings: The Breakdown of Animal Protection in the Transportation and Slaughter of Meat Poultry in Canada documents current practices in the meat poultry industry in Canada, providing photographic and video evidence captured in British Columbia, Alberta, Saskatchewan, Manitoba, Ontario and Quebec. The report is based on some 44 investigations conducted between the years 2007 and 2009. It shows rampant, systemic welfare violations in regard to on-farm practices, transportation and slaughter.

Two short videos have been made using the most compelling footage:

1. Five minute summary of violations at Granny's Poultry Cooperative in Blumenort, Manitoba
2. Five minute summary of violations at Lilydale in Abbotsford, British Columbia

The footage is shocking and shows abuses that range from aggressive loading of transport trailers to turkeys having their legs ripped off on the live-hanging metal shackles.  Farm animals are suffering and endure inhumane treatment, which is totally unacceptable in today’s times.  We need stronger legislation, more inspections, and enforcement of standards, with charges laid and imposed whenever deliberate cruelty or cruelty through negligence is discovered.

With regard to rabbits, there is no Code of Practice for the Care and Handling of Rabbits in Canada.  My understanding is that the National Farm Animal Care Council (NFACC) has not heard from the national commodity group in developing a code for rabbits, and furthermore, is unaware of the existence of a Canadian rabbit association representing the interest of these animals.  Surely, this is a matter that needs to be rectified. 

We ask that you kindly conduct a performance review on the Canadian Food Inspection Agency (CFIA), that the poultry industry update its Recommended Codes of Practice (as the Dairy Producers have), that Codes of Practice be established for rabbits, and that the poultry "slaughterhouses" move to controlled-atmosphere killing.

While we would like to see society adopt a plant-based diet, the reality is that our consumption and use of living, sentient beings isn’t about to end in the near future.

We are concerned about the welfare of animals and look forward to hearing from you regarding this important issue.


Carmina Gooch, President
Rabbit Advocacy Group of BC
North Vancouver, BC

April 27, 2009 

Dear Ms. Gooch, 

Thank you for your email of 17 April 2009, which you sent on behalf of Canadians for the Ethical Treatment of Farm Animals, requesting a performance review of the Canadian Food Inspection Agency with respect to the handling of meat poultry and rabbits. In it, you also asked that the poultry industry update its recommended codes of practice and that such codes be established for the rabbit processing industry, and that poultry slaughterhouses move to controlled-atmosphere killing. 

I regret to inform you that the Office of the Auditor General of Canada has no mandate to influence the practices of private industry, therefore we cannot help you in that regard. I have, however, taken the liberty of forwarding the information you provided to our team responsible for audits of the Canadian Food Inspection Agency. Please note, though, that are not committing to audit any specific issues that you have raised. 


Margot Booth
Manager, External Communications
Office of the Auditor General of Canada

Comment: A number of groups, as well as the general public, are calling on the Auditor General to conduct a performance review of the CFIA.  Among the groups are the Canadian Federation of Humane Societies, the Canadian Horse Defence Coalition, and the Canadian Coalition for Farm Animals.  Under Canada's Health of Animals Act, cattle, sheep, and goats may be transported 52 hours without water, food, or rest.  For poultry, horses, and pigs it is 36 hours without water, food, or rest.  The maximum time for all species in the U.S. is 28 hours.  Animals suffer greatly during long-distance transport under deplorably inhumane conditions, with many dying before reaching the slaughterplant. Current regulations are sorely out of date and largely unenforced, leaving the animals used for food virtually unprotected.  Proposed amendments from the fall of 2006 have yet to be brought into the full consultation process, which is totally unacceptable.  There have been no changes since the mid-1990's!  Please demand that the government act NOW!  Contact rabbitadbc@shaw.ca for more info. 

CFHS Questions Government’s Role in Food Safety and Animal Welfare

OTTAWA, Sept. 3 — The Canadian Federation of Humane Societies (CFHS) is calling on Canada’s Auditor General to conduct an independent performance audit of the federal government’s capacity to ensure the humane treatment of farm animals during transport and slaughter as well as to oversee national animal welfare policies. The health and welfare of animals and the safety and security of our food are issues of public good that must be overseen and taken seriously by the government.

The federal government’s recent acknowledgement of its gradual shift towards industry’s self-policing of food safety in slaughterhouses over the past year is alarming. “It is very clearly a conflict of interest to have a slaughterhouse employee tasked with monitoring his own employer”, stated Shelagh MacDonald, Program Director of the CFHS. “This is a bad case of the fox guarding the hen house.”

This shirking of government responsibility comes as no surprise to the CFHS, which has been frustrated for years by the government’s lack of concern for animal welfare. The Canadian Food Inspection Agency (CFIA) is responsible for overseeing the welfare of animals during transport and at slaughterplants. Their own statistics of inspections show that, out of 160,000 truckloads, nearly 20,000 pigs and cattle are found dead or emaciated in trucks arriving at slaughterplants in a year. The figure for poultry is a staggering 2 million. Yet just over 100 penalties were issued.

The problem clearly originates at the policy level. Agriculture and Agri-Food Canada’s policy framework for the next five years makes no mention of animal care or welfare whatsoever. “While other countries are making animal welfare a priority, Canada lags behind with its ‘status quo’ approach”, claimed Ms. MacDonald. “Public safety, reliable access to safe food and the humane treatment of animals are in serious peril in our country”.

October 2013 update: Responsibility for the CFIA was transferred to Health Canada from Agriculture and Agri-Food Canada this month. While the food safety part of the CFIA is moving to Health Canada, the animal and plant health responsibilities are staying with Agriculture and Agri-Food Canada.

October 10, 2013 CFIA Move Creates New Conflicts, Says U of M Food Safety Expert

January 9, 2014 source: Goodale blames Feds for CFIA failures

Read more: Canada phasing out antibiotic use in livestock, worldwide concerns; rampant misuse; Health Canada; whistleblowers

May 5, 2009 

From: Carmina Gooch
To: Honourable Gerry Ritz, CFIA
Cc: Honourable Wayne Easter, Mr. Alex Atamanenko
Re: Proposed amendments to Transportation of Animals Regulations 

Honourable Gerry Ritz: 

I am well aware of the tremendous suffering and high mortality rate of farm animals during transport and ask that the proposed changes to the regulations be implemented now.  Why the delay?  There have been no amendments in over thirty years. Canada's transport time limits are among the longest in the industrialized world and are not consistent with the scientific findings on animal welfare.   

Under Canada's Health of Animals Act, pigs, horses and poultry can be transported up to 36 hours without food, water and being unloaded to rest. Cattle, sheep and goats can be transported up to 52 hours.  In Europe, most species are not permitted to be transported more than 8 hours.

In 2002, the European Commission's Scientific Committee on Animal Health and Welfare reported that the longer the journey, the greater the risk for animal suffering, and susceptibility to infection and disease.  Numerous other studies corroborate these findings.  With regard to meat rabbits and stress, the plasma cortisol levels demonstrate a five-fold increase after a journey longer than 6 hours, and body weight losses are three times higher for rabbits transported for 7 hours compared to just one hour.  (Canali et al 2000; Luzi et al, 1992)  The Food and Agriculture Organization of the United Nations describes long distance transport as "ideally suited for spreading disease," because of overcrowding of animals of different flocks or herds in inadequately ventilated vehicles.   

Animals are regularly transported from farms in Canada to the USA, and rabbits hauled from Manitoba to California, for example, are not required to be rendered unconscious prior to bleeding/slaughter under antiquated US law.  A regulation stopping animals from being transported to jurisdictions where they would not be handled and slaughtered in accordance with the Canadian Meat Inspection Regulations would prevent their inhumane slaughter.  

As yet, a Code of Practice for food rabbits in Canada has not been developed, a matter that needs to be emended.  In addition, the voluntary, recommended Codes of Practice, offer little or no "protection" to animals, leaving them wide open to abuse.  With no enforcement the violators go unpunished. It makes no sense to have the industry police itself.   

Millions of sick, pregnant, injured and otherwise "unfit" or dead animals are arriving at abattoirs across Canada annually.  According to Canadian Food Inspection Agency statistics for the years 2001-2005, roughly 3 million animals die in transit to slaughter at registered establishments, and more than 11 million are declared unacceptable for human consumption.  

I ask that new and updated humane Transportation of Animals Regulations be implemented without further delay, and that frequent inspections and enforcement of said regulations be carried out. 


Carmina Gooch, President
Rabbit Advocacy Group of BC
North Vancouver
By mail and e-mail. 

July 15, 2009 Partial reply from Gerry Ritz, Minister of Agriculture and Agri-Food  

Thank you for your email regarding the transportation of animals in Canada. I trust that my March 24, 2009, reply to your earlier letter about the humane raising and slaughtering of rabbits and the situation at Fraser Valley Auctions was useful to you. 

Most producers and transporters are strongly committed to treating animals with care. In the few instances where abuses or non-compliance are identified during transportation or at a federal establishment, the Canadian Food Inspection Agency (CFIA) investigates and takes appropriate action. Anyone witnessing such unacceptable behaviour should report their observations to the CFIA as soon as possible. 

The Government of Canada is currently reviewing the Health of Animals Regulations specifically relating to modernizing the humane transport regulations. To this end, any changes to the Health of Animals Regulations will recognize the most recent advances in animal welfare and science and will address the new technology and industry practices that did not exist when the humane transportation portion of the Regulations was first drafted. We are hoping to proceed with the amendments in the coming months.

In June 2010 Carmina Gooch again wrote to the Auditor General of Canada on the issue of farm animal reform. In part, the reply read that under the legislation governing their work, the merits of government policy are not evaluated. Its role is to tell Parliament how well decisions are being implemented. Audit reports become public after they have been tabled by the House of Commons. 

Please keep writing on this important issue. Animals in Canada are still regarded as property under the law and are virtually unprotected from abuses and cruelty. Only those “owned” by someone have any sort of protection. If an animal is wild, stray, or used “for lawful purposes,” such as being raised for food, anti-cruelty laws rarely apply. To make matters worse, “willful” intent must be proven, allowing perpetrators of atrocities toward animals to escape any significant punishment.

Read more on the transport conditions for farmed animals

Putting animal welfare on Ag Canada’s radar

March 2011 Agriculture and Agri-Food Canada has published a five-year agricultural policy discussion paper, titled Growing Forward 2 (GF2) and is inviting Canadians to comment on the paper. The paper is an overview of agricultural sector and market trends, and covers industry objectives for federal, provincial and territorial governments. The welfare of animals raised for human consumption are treated abysmally and government has done little to address the issue. Industry has far too much power and is instrumental in influencing policy. Commodity groups/producers should not be setting standards for animal care. What passes for acceptable standards is nothing short of legalized cruelty. Intense confinement practices must be banned. These animals are denied even the basic 5 Freedoms: 1. Freedom from hunger and thirst 2. Freedom from discomfort 3. Freedom from pain, injury or disease 4. Freedom from distress 5. Freedom to express behaviours that promote well-being. Reforms are urgently required. Whether you are vegan, vegetarian, or a consumer of animal flesh or products, it is in your interest to see best management practices are put into place and enforced. Comments are due by April 30.  GF2 questionnaire: http://agr.sondages-surveys.ca/surveys/Sergey/consultation/?l=en  Ag Canada says there will be future opportunities to provide input.


Read more: Defra 'stripped' of its prosecution function – CFIA also in conflict, New Zealand, too; food safety moves to Health Canada, animal duties stay with Ag Canada; CFIA failures

Feb. 2014 There is still no industry-wide assessment system in place to verify that Code of Practice requirements are being adhered to on farms.

Canadians Killed More Than 750 Million Animals For Food in 2015; in 2018 over 819 land animals slaughtered by Canadian meat industry; 2019 previous record smashed!

Ottawa to allow slaughterhouses to process already dead animals; meat packing plants; calls to ban non-stun slaughter practices in Canada, 2017 federal slaughter regs to be replaced by Safe Food regs

Read: Laws for Farm Animals - BC SPCA

Visit our Animal Law page for more !!

Brooks Animal Law Digest - US & Canada offers in-depth and up-to-date coverage on today's most important animal law and policy to interested parties in the field