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Speak Up For Chickens and Turkeys During the Poultry Code of Practice Comment Period

Animal Justice October 11, 2015

This month, the Canadian agriculture industry released a draft of its revised code of practice for chickens and turkeys. The public is invited to comment on this draft for consideration before the final is published next year.

This code of practice matters. Chickens are by far the largest population of animals under human care—we killed more than 640 million of them in 2014—and their degree of suffering is arguably the worst of any factory farmed animal.

Yet, the government does not regulate on-farm conditions in Canada, choosing instead to fund and endorse the codes of practice. These codes of practice are the closest to on-farm regulations that we have.

The draft code of practice is badly deficient. It leaves out or scarcely addresses the most important animal welfare concerns. The interests, profits, and convenience of producers have evidently been the paramount concern.

Most alarmingly, the draft code totally fails to address genetic selection for rapid growth, which renders animals in systemic, chronic pain. The rapid growth of broiler chickens leads to lameness, heart failure, and compromised immunity. If you can take the time to leave just one comment, please comment on the need for runaway genetic selection to be curtailed.

Chickens and turkeys need our voices. Please participate in the public comment period before it closes. Below are some broad areas of concern worth mentioning, broken down by section to make commenting easier, although there are many sections to critique.

You can also view our full letter to the code development committee, which contains much more detail and citations, here.

“2.5 Physical Alterations and Bird Identification”

The draft code permits cutting off beaks, toes, spurs, combs, and snoods. Such amputations should be banned in favour of better management practices, including environmental enrichments, appropriate stocking density, and suitable and sufficient food. If amputations are permitted, painkillers should be required, and so should the use of the best available technology.

“3.4 Lighting”

Standard practice is to raise chickens with many hours of artificial light each day to keep the animals awake and eating, but keep the light intensity dim to prevent the animals from exerting too much energy. This near-constant dim lighting is associated with numerous welfare problems.

The draft code requires only four hours of dark per day. This is insufficient. In the European Union, at least six hours is required by law, although this too would be insufficient. As noted by NFACC’s Scientific Committee, mortality increases with each hour of light above 12 hours. Additionally, the lighting intensity required by the draft code is far too low; that is, the lights would be too dim.

“3.5 Stocking Densities”

The draft code allows chickens to be crowded to a density of up to 38 kg/m2 , which—assuming an average broiler size of approximately 2 kg—amounts to approximately 19 birds per square metre. The European Commission’s respected Scientific Committee on Animal Health and Animal Welfare (SCAHAW) recommends stocking densities of 25 kg/m2 or lower.

“4.2 Controlled Feeding and Watering for Broiler Breeders”

In order to prevent them from dropping dead, broiler chickens reared to reproductive age must be kept in a state of near-starvation. Feed restriction in broiler breeders causes stress, frustration, boredom, and chronic hunger.

The draft code acknowledges that “restricted feeding programs result in chronic hunger,” but rather than addressing this serious issue, it chalks up the “negative impact on bird welfare” as “unavoidable.”

This is unacceptable. It should be required, and it should be considered urgent, that at bare minimum birds are genetically capable of living to reproductive age without needing to be subjected to “extreme food restriction.”

“5.2 Disease Prevention”

The draft code does not require facilities to be cleaned between flocks. Leaving the excrement-covered litter in facilities is, unsurprisingly, associated with poor air quality. Specifically, air contains more dust, bacteria, fungal spores, and ammonia. Dirty litter and air causes eye, lung, and skin problems.

For reasons of animal welfare and food safety, producers should be required to clean out dirty facilities between flocks.

“7.3. Catching, Loading, and Unloading Procedures”

When chickens and turkeys reach slaughter weight, they are rounded up and packed into crates by unskilled workers. Workers carry three or four animals per hand, upside down, and throw them into transport crates. Rough handling is the norm. The confused, terrified birds experience extreme stress, and are frequently physically harmed with bruises, broken bones, dislocated joints, and other injuries.

In light of the dire welfare consequences associated with the manual catching techniques that are common practice in Canada, it is insufficient that the draft code essentially only requires “minimizing stress and injury” during catching. Specific guidelines and a structure that does not incentivize brutal handling habits should be set out and deemed required.

“Concluding Comments”

The draft code doesn’t address genetic selection for rapid growth. This is a paramount welfare concern. Not only does it lead to lameness, heart failure and compromised immunity, but breeding birds must necessarily be starved to stay alive.

Cages are not used to house broiler chickens in Canada because cages have historically caused breast blisters, which consumers find unattractive. However, cages are used in other parts of the world where it is more economically feasible for a variety of reasons, including changing cage technology. Canadian producers should be prohibited from adopting cage systems for broiler chickens.

So-called “required” practices are vague, vesting ultimate decision-making in the hands of producers. Phrases like “appropriate diet” and “appropriate environmental conditions” fail to communicate evidence-based best practice and guide behaviour. The code of practice should set out specific, measurable standards to promote producer accountability.

The draft code doesn’t address the rampant use of antibiotics in the poultry industry. Antibiotics should not be allowed for growth promotion or at sub-therapeutic levels. Instead of using antibiotics, producers should address the root of the problem: confining thousands of genetically immuno-compromised animals into crowded, filthy warehouses.

Image: Jo-Anne McArthur

Animal Justice

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Canadian Food Labels Guide

Animal Justice December 23, 2014


Food labels are intended to enable consumers to make informed food choices. Unfortunately, food labels in Canada are largely unregulated and can be misleading. Thus, the use of food labels such as “cage free”, “organic”, “free range”, “grass fed”, “natural”, and so on, may not mean what you think they mean. This guide sets out what food labels do—and don’t—mean for animal welfare.

 

 

 

 

Food Labels*

Cage free”: means hens are not confined to battery cages. However, they don’t have access to the outdoors, and there are no assurances about what they are fed or what kinds of medications they are given.[1] Further, these claims are unverified and uncertified, meaning that no independent inspection or verification ensures that producers using these labels are in fact raising their animals in the method indicated.[2]

Certified local sustainable”: means that eggs and poultry products come from cage-free chickens. Producers will only be certified once inspected to ensure their chickens are kept in free-range or free-run conditions and that they are given a minimum amount of space allowance that is far higher than the industry norm.[3]

Certified organic”: means the animal was raised according to the standards of an organic certifying body and verified by an independent inspector (for example, “SPCA Certified”, “BC Certified Organic”, “Canada Organic”, “Quality Assurance International” and “USDA Organic”).[4] Certified organic means eggs and poultry products come from cage-free chickens. Producers will only be certified once inspected to ensure their chickens are kept in free-range or free-run conditions and that they are given a minimum amount of space allowance that is far higher than the industry norm.[5] Additionally, only products with organic content that is greater than or equal to 95% may be labeled or advertised as “organic” or bear the organic logo.[6]

 Farm fresh”: implies that eggs were distributed directly from the farm to the store. The label is only to be used if a grader grades their own eggs in a registered on-farm operation and ships them directly to the store.[7] No standards for animal welfare.

Free range”: means that hens are kept in open barns, uncaged, with access to the outdoors. “Access to the outdoors” means that hens see the light of day (depending on the weather) and their feet actually come in contact with the earth.[8] However, hens in these systems may still be kept in very crowded conditions inside the barn. Also, there is no independent inspection or verification to ensure that producers using these labels are in fact raising their animals in the method indicated.[9]

Free run”: hens are kept in open barns, uncaged. However, hens in these systems may still be kept in very crowded conditions inside the barn. Also, there is no independent inspection or verification to ensure that producers using these labels are in fact raising their animals in the method indicated.[10]

Fresh”: when used for eggs, the label is only permitted if it appears as part of a statement (like “all eggs are fresh”), or in order to distinguish them from other physical forms of eggs such as powdered, because the Canadian Food Inspection Agency (CFIA) believes that all eggs are fresh.[11] For meat and poultry, “fresh” means the animal has not been treated by any means, other than by refrigeration, vacuum packaging or modified atmosphere packaging to ensure their preservation. However, “fresh sausage” made with frozen meat may be described as “fresh”.[12] No standards for animal welfare.

Grain-fed” or Vegetable grain-fed”: means animals were fed a grain diet, where the macro feed ingredients, added as sources of energy and protein, were made up solely of grains and grain by-products with no ingredients of animal origin. Minerals and vitamins as well as non-nutritive feed additives such as medications, biologics, pellet binders, enzyme supplements, anti-caking agents, flavouring agents, etc., may be added regardless of origin. So, additives such as Vitamin D3 derived from the lanolin of sheep wool and vitamins and minerals which are encapsulated in gelatin of animal origin may be added without disqualifying the final product from making the claims “grain fed” or “vegetable grain fed”.[13] No standards for animal welfare.

Grass fed”: means that an animal was fed a grass diet. The use of this label is unverified, meaning that producers who use these labels on their products have not been inspected or verified to make sure they are raising their animals in the method indicated, unless they are also certified under a program that includes that method in its requirements.[14] No standards for animal welfare.

Genetically modified” or “genetically engineered”: applies to food that consists of organisms that have undergone genetic engineering and to food derived from these organisms. Genetically modified foods in Canada do not need to be labeled as such, although there is a voluntary system in place. Similarly, a producer may label a product as “not genetically engineered” provided such claims are truthful, not misleading or deceptive, and not likely to create an erroneous impression of a food’s character, value, composition, merit or safety, and in compliance with all other requirements set out under the Canadian Food and Drug Administration (FDA), the CPLA (Consumer Packaging and Labelling Act) and other applicable legislation.[15]

Halal”: when a food is certified as Halal, it means that the animal was slaughtered in a certain way: “A sharp blade and skill in slaughtering is required to minimize pain and unnecessary suffering for the animal. This is accomplished by a quick cut to sever the veins and arteries of the neck of the animal, without cutting the nervous system or spinal cord. The massive bleeding makes the animal unconscious in seconds. Leaving the spinal cord intact allowing for convulsions that result from the contraction of the muscles in response to the lack of oxygen in the brain cells. This will allow for the maximum drainage of blood, carrying away in part the waste and micro-organisms, thereby improving the meat’s taste, shelf-life and healthiness”.[16]

Humane certified” (e.g. “BC SPCA certified” + “Winnipeg humane society certified”): means that the animal was raised according to the standards of a humane society or SPCA, and verified by an independent inspector. In Canada, “Winnipeg Humane Society Certified” and “BC SPCA Certified” are the two existing Canadian certifiers.[17] “Humane certified” eggs and poultry products come from cage-free chickens. Producers will only be certified once inspected to ensure their chickens are kept in free-range or free-run conditions and that they are given a minimum amount of space allowance that is far higher than the industry norm.[18]

Kosher”: describes foods and practices that are specifically permitted by Jewish dietary laws. Some animals or animal products may not be eaten at all, but those that can be must be processed in accordance with the requirements of the Kashruth.[19] Pigs, rabbits, shellfish and insects are not kosher. Meat from permitted animals may only be consumed if the animal is slaughtered in a specified manner by a trained butcher or shochet.[20] In addition, milk and meat products must never be mixed. Most cheeses must be prepared either in whole or in part by Jewish people. The labels “Jewish-style food” or “Jewish cuisine” are not necessarily considered to create the impression that the food is kosher.[21]

Natural”: a food or ingredient of food that is represented as natural is expected not to contain, or to ever have contained, an added vitamin, mineral, nutrient, artificial flavouring agent or food additive; not to have any constituent or fraction thereof removed or significantly changed, except the removal of water; and not to have been submitted to processes that have significantly altered their original physical, chemical or biological state.[22] For eggs, the label “natural” is only permitted if it appears as part of a statement (like, “all eggs are natural”) because the CFIA believes all eggs are natural.[23] No standards for animal welfare.

No hormones” or “Hormone-free”: cannot be used on labels for eggs because the use of hormones is not permitted in poultry in Canada; a “no hormones” claim can only be made as part of a statement like “use of hormones is not permitted in poultry in Canada”. Also, the label should not be used on meat, poultry or fish products because to do so would be misleading given that they all contain naturally occurring hormones.[24]

Omega 3”: has nothing to do with the care and welfare of the chickens. It simply means that the feed given to the chickens was enriched with omega 3. Does not mean the feed was organic or antibiotic-free.

Organic aquaculture”: refers to seaweeds, aquatic plants or animals cultivated in a controlled or managed environment (e.g. fish farms). Organic claims should meet Canadian General Standards Board’s “National Standard of Canada for Organic Aquaculture”, which outlines principles for organic aquaculture production and specifies minimum criteria that should be met to use “organic”, however, this is a voluntary national standard: a producer or processor may ask an independent certifying body to certify the product and may then label the product as organic, but may not bear the “Canada Organic” logo.[25]

Pasture raised”: producers who use these labels on their products have not been inspected to make sure they’re raising their animals in the method indicated, unless they are also certified under a program that includes that method in its requirements.[26]

“Raised without the use of antibiotics”: the animal or fish must not have received antibiotics from birth to harvest. In addition, no antibiotics can be administered to the mother of the animal in question in any manner which would result in antibiotic residue in the animal. Vitamins and minerals given to the animal may only be given at the level of physiological action for dietary supplement, not for antimicrobial effect.[27]

Raised without the use of hormones”: no hormones shall be administered in any way (including through the mother) to the animal that forms the food product carrying the claim “raised without the use of hormones” on the label or advertisement.[28]

Vegetarian feed”: once again, this label has nothing to do with the care and welfare of the animal. It simply means they were fed vegetarian feed.

 

Summary

Many food labels sound meaningful, but in fact have little or nothing to with animal welfare. Additionally, very few claims are regulated, standardized, or subject to compliance mechanisms. In the absence of strong government regulations, consumers should read food labels with a skeptical eye and remember that many terms are nothing more than marketing.

*These food labels apply to animals and animal products grown or produced in Canada.

 


Written by Sarah Ure – BA, JD – Articling Student for Animal Justice Canada

This blog and the contents herein are for informational purposes only and do not constitute legal advice. Readers are advised to seek legal counsel prior to acting on any matters discussed herein. The opinions expressed are those of the author.


Citations

[1] Lindsay Coulter, Choose eggs from happy chickens, online: David Suzuki Foundation <http://www.davidsuzuki.org/blogs/queen-of-green/2011/03/choose-eggs-from-happy-chickens/>.

[2] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies <http://cfhs.ca/farm/humane_labelling/>.

[3] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies <http://cfhs.ca/farm/humane_labelling/>.

[4] Humane Choices, online: Canadian Coalition for Farm Animals <http://www.humanefood.ca/humane.html>.

[5] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies <http://cfhs.ca/farm/humane_labelling/>.

[6] Canadian Food Inspection Agency, Organic Claims, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/organic-claims/eng/1389725994094/1389726052482?chap=3>.

[7] Canadian Food Inspection Agency, Requirements for Shell Egg Products, “Other Claims – Shell Egg”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/shelled-egg-products/eng/1392837654394/1392837698515?chap=13>.

[8] Lindsay Coulter, Choose eggs from happy chickens, online: David Suzuki Foundation <http://www.davidsuzuki.org/blogs/queen-of-green/2011/03/choose-eggs-from-happy-chickens/>.

[9] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies <http://cfhs.ca/farm/humane_labelling/>.

[10] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies:<http://cfhs.ca/farm/humane_labelling/>.

[11] Canadian Food Inspection Agency, Requirements for Shell Egg Products, “Other Claims – Shell Egg”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/shelled-egg-products/eng/1392837654394/1392837698515?chap=13>.

[12] Canadian Food Inspection Agency, Labelling Requirements for Meat and Poultry Products, “Voluntary Claims and Statements”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/meat-and-poultry-products/eng/1393979114983/1393979162475?chap=21>.

[13] Canadian Food Inspection Agency, Method of Production Claims, “Additional Information”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=9#s3c9>.

[14] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies <http://cfhs.ca/farm/humane_labelling/>.; Lindsay Coulter, Choose eggs from happy chickens, online: David Suzuki Foundation <http://www.davidsuzuki.org/blogs/queen-of-green/2011/03/choose-eggs-from-happy-chickens/>.

[15] Canadian Food Inspection Agency, Method of Production Claims, “Novel Foods, Including Novel Foods that are Products of Genetic Modification, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=3>.

[16] Hala, Haram, Zabiha, online: ISNA Halal Certification Agency <http://www.isnahalal.ca/info.html>.

[17] Humane Choices, online: Canadian Coalition for Farm Animals <http://www.humanefood.ca/humane.html>.

[18] Animals on the Farm, “Farm Animal Welfare Certification”, online: Canadian Federation of Humane Societies <http://cfhs.ca/farm/humane_labelling/>.

[19] What is Kosher, online: Kashruth Council of Canada, Kosher Certification Agency <http://www.cor.ca/view/54/what_is_kosher.html>.

[20] What is Kosher, online: Kashruth Council of Canada, Kosher Certification Agency <http://www.cor.ca/view/54/what_is_kosher.html>.

[21] Canadian Food Inspection Agency, Method of Production Claims, “Kosher”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=4>.

[22] Canadian Food Inspection Agency, Method of Production Claims, “Nature, Natural”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=2>.

[23] Canadian Food Inspection Agency, Labelling Requirements for Shell Egg Products, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/shelled-egg-products/eng/1392837654394/1392837698515?chap=0#c13>.

[24] Canadian Food Inspection Agency, Method of Production Claims, “Additional Information”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=9#s3c9>.

[25] Canadian Food Inspection Agency, Organic Claims, “Organic Aquaculture”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/organic-claims/eng/1389725994094/1389726052482?chap=8>.

[26] Lindsay Coulter, Choose eggs from happy chickens, online: David Suzuki Foundation <http://www.davidsuzuki.org/blogs/queen-of-green/2011/03/choose-eggs-from-happy-chickens/>.

[27] Canadian Food Inspection Agency, Method of Production Claims, “Additional Information”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=9#s3c9>.

[28] Canadian Food Inspection Agency, Method of Production Claims, “Additional Information”, online: Government of Canada <http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/method-of-production-claims/eng/1389379565794/1389380926083?chap=9#s3c9>.

[29] Lindsay Coulter, Choose eggs from happy chickens, online: David Suzuki Foundation <http://www.davidsuzuki.org/blogs/queen-of-green/2011/03/choose-eggs-from-happy-chickens/>.

Animal Justice

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AJCLF Launches Charter of Rights and Freedoms for Animals

Animal Justice November 18, 2014

Sign the CharterAnimal Justice Canada Legislative Fund (AJCLF) today launched a new national campaign to have basic rights for animals enshrined into Canadian law through the Animal Charter of Rights and Freedoms. The Animal Charter would ensure animals are treated as sentient beings instead of mere property, would guarantee the rights and freedoms that make life worth living, and give all animals a chance to have their interests represented in court.

“This is an idea whose time has come. We know that animals experience pain and joy just like we do, and now it’s time for our laws to catch up to society,” said Nick Wright, Executive Director. “Animals deserve rights and freedoms, and they deserve to have their voices heard in courts throughout the country, much like corporations and trusts already do. Animal Justice is calling on Canadian lawmakers to enact the Animal Charter and help improve the lives of millions of animals.”

Although opinion polls consistently show that Canadians care deeply about animal welfare, the law affords inadequate protection to animals. From our pet dogs, to captive orcas, to pigs kept on factory farms, legal protections for animals are often weak, and animals don’t have the right to see their interests represented in court. The Animal Charter would bridge the large gap between Canadians’ expectations of how animals should be treated and the reality of what they are currently forced to lawfully endure.

The Animal Charter is premised on the recognition that animals experience suffering and pleasure in a way that is not biologically distinguishable from that of humans; that discrimination on the basis of arbitrary characteristics—like species—is a violation of equity, natural justice and the rule of law; and that our legal system must not exclude the most vulnerable members of society.

The Animal Charter can be viewed and signed at AnimalJustice.ca/Charter.

Animal Justice Canada Legislative Fund is a federally incorporated not-for-profit dedicated to advocating for the humane treatment of animals.

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