The Canadian Food and Inspection Agency (CFIA) is doing the right thing by modernizing the rules for transporting livestock, says the Canadian Trucking Alliance (CTA).
However, CTA’s main concern is not the modernization of these rules but rather the exclusion of certain livestock truck transporters from key aspects of the proposed regulations. CTA recently outlined its concerns over proposed amendments to Part XII (Transport of Animals) to federal Health of Animals Regulations.
“The proposed amendments limit the reach of some of the regulations to “commercial carriers,” said Susan Ewart, Regional Vice President (SK), Canadian Trucking Alliance. “As written, this would exclude from key training and record-keeping provisions producers and processors who claim ownership of the animals or poultry during transportation and do not charge a fee for transportation services. Further, CTA is concerned this could result in a competitive imbalance between for-hire carriers and private carriers from both operational and enforcement perspectives.”
Some other issues CTA would like to see addressed in the upcoming regulation comment period include:
- Transport of Unfit and/or Compromised Animals: CTA agrees with efforts to prohibit loading unfit animals, as well as with the special provisions for moving compromised animals. Drivers would prefer not to be placed in a position where they are being asked to determine whether an animal being offered for transport is compromised or unfit. Any animal that is deemed to be compromised, but still fit to move with special provisions should be declared as such by the consignor. Moreover, mandatory signed documentation stating the consignor is aware of the animal’s compromised condition should accompany the animal. Further, provisions stipulating the actions a driver must take if an animal becomes compromised or unfit during transport could potentially result in unjust and unwarranted penalties being brought against the carrier and/or the driver. Such actions should only apply when a driver becomes knowledgeable about such changes in an animal’s condition.
- Transfer of Responsibility: The proposed regulations mandate the receiving party to be physically present on the animal’s arrival. CTA questions why a similar provision is not mandated at the beginning of the transportation process, particularly when the condition animals arrive in at the final destination is largely dependent on the condition they were in when they were loaded.
- Outcome-Based Regulatory Framework : CTA welcomes the move to an outcome-based regulatory framework. In particular, this approach is appropriate for the provisions under ‘Knowledge and Skills’, which exempt a carrier from training requirements if the necessary knowledge and skills have been verified. In addition, existing rigid rules regarding segregation of animals have been replaced with outcome-based provisions in the proposed amendments.
“In general, CTA supports efforts to strengthen the rules that govern the transportation of livestock in Canada, and understands and accepts that societal expectations regarding farmed animal welfare, which extends to transportation, is becoming more of a concern for Canadians,” said CTA’s policy analyst director, Lak Shoan. “We support further clarifying expectations for all parties involved in livestock transportation, including those that load and unload livestock as part of the transportation process.”
For a complete copy of the CTA submission please e-mail firstname.lastname@example.org