Cc: Andrew Saxton, M.P

      Honourable Ron Cantelon, BC Minister of Agriculture and Lands

      Rabbit Rescue Inc.

March 25, 2009: Response from Gerry Ritz, PC, MP, to concerns regarding Fraser Valley Auctions and to food rabbits not being included in the voluntary Codes of Practice farmers are encouraged to follow. 

Dear Ms. Gooch: 

Thank you for your email and letter expressing your concerns regarding the humane treatment of animals and the situation at Fraser Valley Auctions. 

I appreciate your concern for the welfare of animals. As a former horse breeder myself, I also believe that animals should be protected from unnecessary suffering, and I can assure you that most Canadian producers and industry members are strongly committed to treating animals with care. 

The Canadian Food Inspection Agency’s (CFIA) role is to enforce the regulations under the Health of Animals Act that govern the humane transportation of animals and to ensure that farm animals are humanely slaughtered in federally registered meat plants, as required under the Meat Inspection Act.  

The main responsibility for the welfare of animals on-farm rests with the provinces and territories. In British Columbia, the Society for the Prevention of Cruelty to Animals (SPCA) enforces the provincial laws that govern the humane treatment of animals. SPCA officers or police officers also investigate complaints under the federal Criminal Code.  

Animal cruelty is unacceptable under the Criminal Code, and penalties provide an important deterrent. I am pleased to tell you that on April 9, 2008, the Government of Canada was successful in ensuring that Bill S-203 passed. This bill amends the Criminal Code to significantly increase penalties to enhance sentencing options available to the courts and to send a strong message that the federal government does not tolerate animal cruelty. 

I wish to assure you that the CFIA has maintained a regular presence at Fraser Valley Auctions for the past several years. The CFIA attends auctions in an oversight capacity and notifies the British Columbia SPCA when concerns are raised about how animals are handled in the pens or in the ring. Incidents related to loading, unloading or transport come under the Health of Animals Regulations. The CFIA also takes time to educate and remind individuals delivering animals to auctions of their obligations to the well-being of their animals. 

Officials of the CFIA and of the British Columbia SPCA have met on more than one occasion to discuss the events at Fraser Valley Auctions, and they continue to collaborate concerning the humane treatment of animals. 

I note your comments about the Recommended Codes of Practice for the Care and Handling of Farm Animals. These codes have been developed as a collaborative effort of many stakeholders from Canadian industry, government and non-governmental organizations. The codes are now being coordinated and maintained by the National Farm Animal Care Council (NFACC). However, the initiation of code development and revision for a species remains the responsibility of each individual commodity group. The NFACC has established a protocol and guidelines for the development and revision of the codes, including that recommended practices should be based on sound science and be practical and manageable. 

You are correct in stating that the code of practice for food rabbits has not yet been developed. It is not possible to determine when one might be completed. For further information, you may wish to contact the following NFACC official:

Ms. Jackie Wepruk

Coordinator

National Farm Animal Care Council

PO Box 61324, RPO Brentwood

Calgary, Alberta  T2L 2K6

As I previously indicated, there are laws in place that set standards for the humane handling and slaughter of animals in federally registered abattoirs. The Meat Inspection Regulations ensure that rabbits and other animals are rendered unconscious as humanely as possible before slaughter.  

There is only one federally registered establishment that is slaughtering rabbits, and I assure you that it has been operating in compliance with humane standards. Some rabbit slaughter is done in British Columbia in provincial establishments. The Province has a long-standing memorandum of understanding designating the CFIA as the provider of inspection services in British Columbia, and you can be assured that rabbits are being slaughtered humanely at these provincial establishments. 

I trust that this information will be of assistance to you. Again, thank you for bringing your concerns to my attention. 

Comment: Please contact the National Farm Animal Care Council and be a voice for the rabbits. Online input form http://nfacc.ca/

Read more:

Meat Inspection Regulations Canada/Rabbits

Meat Inspection Regulations Canada CFIA: Poultry and Rabbit Species

Farm animal transportation death toll; CFIA vs Maple Lodge

Meat rabbits and some statistics; no laws to protect 

BC slaughterhouses; licensing; meat inspection regulations; Salt Spring Island abattoir; Pitt Meadows Meats E.coli case coverup

End the Cage Age - Make farming rabbits in cages illegal!

USDA Classifies Rabbits as Poultry; rabbit production in the EU; Codes needed; Australia. Whole Foods pilot project: Meet your "meat" rabbit

March 26, 2009 Carmina Gooch, Rabbit Advocacy Group of BC, sent the following letter:

To: Jackie Wepruk, Coordinator

National Farm Animal Care Council 

Re: Rabbits and the Codes of Practice

for the Care and Handling of Farm Animals

Dear Ms Wepruk: 

The Rabbit Advocacy Group of BC is writing with concerns regarding the absence of regulations specific to meat rabbits in the Codes of Practice for the Care and Handling of Farm Animals. 

There are no basic standards that would ensure the humane handling and treatment of these animals while they await slaughter. 

We are given to understand that the NFACC is the organization responsible for assisting with the Codes of Practice development process and that the Code has not yet been created. 

When might we expect that it will be completed?  The welfare of rabbits is of equal importance to that of other animals exploited for the food industry. 

We look forward to hearing from you regarding this issue. 

In addition, ongoing funding support for Canada’s Code of Practice development process is still needed. NFACC has updated and approved a new development process for Codes, but support to update or develop Codes of Practice for all farmed species has not been secured. NFACC has been working with the Agriculture and Agri-Food Canada to identify funding options, but no path forward has been identified yet.

Jackie Wepruk, NFACC Coordinator recently communicated to us that she is unaware of a Canadian rabbit association representing the interests for the entire industry nationally. (see above response)   read more:

From B.C.’s Prevention of Cruelty to Animals Act (PCA Act) RSBC 1996, Chapter 372  

NFACC revised codes for dairy cattle were completed in 2009. Codes currently under revision are beef cattle, equine, pigs, mink, ranched fox, and most recently sheep, the update initiated in Jan. 2011. 

The review and update of the Code of Practice for chickens, turkeys and breeders will begin in October. The National Farm Animal Care Council (NFACC) has been requested by the Turkey Farmers of Canada (TFC), Chicken Farmers of Canada (CFC), Canadian Hatching Egg Producers (CHEP) and Canadian Poultry and Egg Processors Council (CPEPC) to initiate the review.

Industry groups representing rabbits have made no effort to start the process of having codes for their species, speaking volumes about the integrity and trustworthiness of the producers. (The BCFACC was formed in 2009.) No minimal standards for animal welfare and no oversight. Perhaps it’s time for video surveillance systems and independent monitoring. 

More and more people are giving up unhealthy, cruelly produced food and moving toward a modern, compassionate, and healthy cruelty-free plant based diet, despite government and industry attempts to hinder the growing movement. Our tax dollars are being used to encourage consumption of animals and animal products.

Note: We purchased these two rabbits from the Fraser Valley Auctions in Langley in early 2011. Both were sick and pregnant. Sadly, this is not unusual.

Although amendments to the BC PCA Act became law on June 2, 2011, in reality there was little change. Industry/producers are protected under legislation whereas animals are not. The customary and acceptable “standards of care” are in fact a hell on earth – let’s not kid ourselves.   

The PCA Act Part 4 Defence 24.02 A person must not be convicted of an offence under the Act in relation to an animal in distress if:

(b) the person is an operator, the distress results from an activity that is carried out in accordance with the prescribed standards of care that apply to the regulated activity in which the operator is engaged, or  

(c) the distress results from an activity that is carried out in accordance with reasonable and generally accepted practices of animal management that apply to the activity in which the person is engaged, unless the person is an operator and those practices are inconsistent with prescribed standards.

October 15, 2014 We received a response to our concerns regarding the suspension of rabbits for slaughter here in BC and were advised that “there are currently only two provincial slaughter establishments in BC that slaughter rabbits and the suspension of those rabbits prior to stunning is not allowed. The BC Meat Inspection Program follows best practices and encourages high standards for animal welfare and humane stunning and slaughter methods on all species.” (and we’re expected to believe this?)

November 7, 2014 Carmina Gooch wrote to agriculture ministers and farm animal council managers regarding rabbit welfare concerns in the meat industry.   

November 27, 2014 update: In response to our concerns regarding welfare standards of farmed rabbits, Jackie Wepruk, GM of the NFACC noted that: A few provincial associations exist, most with a largely volunteer-base. A national rabbit association is not in place. Coordinating the development of a national Code of Practice is a significant effort. Dedicated resources are required to coordinate the industry and assure its involvement from start through to the successful completion of a Code. NFACC’s rigorous Code development process requires this. There is a desire from within the sector for a rabbit Code of Practice. However, time is needed to ensure the necessary organization of the industry and its ability to remain actively engaged throughout the process, as well as to secure the necessary industry resources that will ensure the development of a successful Code that furthers the welfare of rabbits across Canada. 

Agriculture Minister, Gerry Ritz, had also advised that the process would have to be “balanced against competing priorities.”

December 24, 2014 comment: Further to our questions and concerns regarding farmed rabbit welfare, Mr. Ritz advised that the Government of Canada is providing funding assistance of up to $5.4 million to the National Farm Animal Care Council to develop and update the Codes of Practice to ensure the welfare of farmed animals.