Call on American Veterinary Medical Aassociation to Oppose Horse Slaughter

Please take just a moment to tell the AVMA that horse slaughter is NOT "humane euthanasia"! Ask them to include all necessary information in their guidelines including this testimony by Dr. Lester Friedlander, DVM & former Chief USDA Inspector, who told Congress in 2008, "The captive bolt [used to slaughter horses] is not a proper instrument for the slaughter of equids, these animals regain consciousness 30 seconds after being struck, they are fully aware they are being vivisected," and GAO reports.

The captive-bolt is NOT suitable for horses!

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 Call on AVMA to Oppose Horse Slaughter

The American Veterinary Medical Association (AVMA) is accepting comments until September 1, 2011 about proposed updates to its Policy on Euthanasia. The AVMA euphemistically describes the grizzly and outmoded practice of horse slaughter as "humane euthanasia" meaning a humane, good death. In its 2007 Policy on Euthanasia and the proposed updates, AVMA endorses use of gunshot or the penetrating captive bolt gun to kill horses. In its 2007 Policy, AVMA states that "[a]dequate restraint is important to ensure proper placement of the captive bolt....When an animal can be appropriately restrained, the penetrating captive bolt is preferred to a gunshot." This caveat about using "adequate" or "appropriate" restraint is echoed on one page of the 2011 proposed guidelines: "Both [gunshot and the captive bolt gun] should only be used by well-trained personnel who are regularly monitored to ensure proficiency, and firearms must be well-maintained. Appropriate restraint is required for application of the penetrating captive bolt".  In the discussion of equids specifically, the captive bolt gun is declared only conditionally acceptable unless all criteria for its use are met. In an article linked to the proposed guidelines, there is a warning that "good restraint" is required "so that the device may be held in close contact with the skull" when fired.   But on another page in the same proposed guidelines for use of the penetrating captive bolt gun, AVMA declares it not conditionally acceptable, but acceptable as a method of killing horses. The only disadvantages cited here are that the use of the "captive bolt can be aesthetically displeasing" and "[d]eath may not occur if equipment is not maintained and used properly."   The proposed updates nowhere mention Dr. Lester Friedlander, DVM & former Chief USDA Inspector, who told Congress in 2008, "The captive bolt [used to slaughter horses] is not a proper instrument for the slaughter of equids, these animals regain consciousness 30 seconds after being struck, they are fully aware they are being vivisected." Nor does the proposed AVMA guidelines mention the Food Safety Inspection Service(FSIS) has been grossly ineffective in protecting horses from cruelty during slaughter. In 2004 the Government Accountability Office (GAO) found the most frequent violation noted by inspectors in slaughter houses was ineffective stunning, meaning "in many cases ...a conscious animal reach[ed] slaughter" in violation of Humane Methods of Slaughter Act, 7 USCS § 1902(a); 9 C.F. R. §313.15, 9 C.F.R. §313.50(c). See GAO-04-247, GAO-08-686T. GAO also noted there had been no effort made to stop the ineffective stunning and the records kept by inspectors were so poor, it was impossible to tell even by 2008 that there had been any improvement. In 2008, USDA's Office of Inspector General reported that FSIS management controls over preslaughter activities should be strengthened to minimize the possibility of egregious cruelty.   By 2010 GAO was adamant "[a]ctions are needed to strengthen enforcement" of the Humane Methods of Slaughter Act. GAO noted despite years of reports and highly publicized incidents of abuse at slaughterhouses, FSIS enforcement remains grossly inconsistent and in many places, non-existent. GAO 10-203 In effect, in recommending the penetrating captive bolt, AVMA does not consider that slaughter of horses occurs in a brutally cruel environment, not a carefully controlled laboratory setting. Or maybe they do. As John Holland has explained, "In its 2000 report on methods of Euthanasia, the AVMA stated that the captive bolt gun should not be used on equines unless head restraint could be assured. This is because of the relatively narrow forehead of equines, their head shyness and the fact that the brain is set back further than in cattle for which the gun is intended. It is difficult for an operator to assure proper placement of the gun. "No slaughter house ever found a practical way to restrain the heads of the horses, so by the AVMA's very definition, the process was not acceptable. The result was a very large number of ineffective stuns. These misplaced blows undoubtedly caused severe pain until a stunning or fatal blow was delivered. " What is particularly disturbing is in its 2007 Policy on Euthanasia, AVMA simply omits any mention that horses' heads should be immobilized during use of the captive bolt gun. The report simply refers to "adequate" or "appropriate" restraint. The type of restraint is not described. The fact is there was no effort made at the slaughter houses to restrain horses' heads during slaughter; nor is there any way to do so. There was no effort made to place the captive bolt carefully against the horse's forehead to ensure an instant death. Workers at horse slaughterhouses in the U.S. were generally untrained, paid low wages and in many instances undocumented. (In Canada inspectors were ordered to stay off the kill floor during slaughter out of fear for their safety; the government feared the violent workers on the kill floor.) There is also the issue of danger to the public health. As the Veterinarians for Equine Welfare explain, "[VEW] strongly object[s] to the AVMA ... position in favor of horse slaughter for human consumption. For the AVMA... to condone the human consumption of meat derived from equines that have not been raised or medicated in a manner consistent with food safety regulations is, in our opinion, unethical, disingenuous, and dangerous." A recent European Union Food and Veterinary Office investigation into the horse slaughter plants in Mexico revealed numerous serious violations including drug residues in the meat. For more on the food safety issue created by horse slaughter......

WHAT YOU CAN DO

The AVMA is accepting comments until September 1, 2011 on the 2011 draft of the Euthanasia guidelines. Email comments to animalwelfare@avma.org Urge AVMA to do the following: (1) reject that the penetrating captive bolt or gunshot can be done humanely and safely in a slaughter house setting, (2) find that horse slaughter is inhumane and (3) call on Congress to ban the slaughter of horses.

         __________________________

More on AVMA's pro-horse slaughter stance and rebuttal by Equine Welfare Alliance co-founder, John Holland  Veterinarians for Equine Welfare White Paper Opposing Horse slaughter More rebuttal to AVMA's pro-slaughter stance

Read more at www.animallawcoalition.com

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The Humane Slaughter Act of 1958

USE OF THE 'PENETRATING CAPTIVE BOLT' AS A MEANS OF RENDERING EQUINES INSENSIBLE FOR SLAUGHTER VIOLATES ‘THE HUMANE SLAUGHTER ACT OF 1958’

I.          The Humane Slaughter Act of 1958

The Humane Slaughter Act ("HSA"), was first enacted in 1958, and amended in 1978 and 2002.  HSA requires slaughterhouses to render livestock unconscious before they are killed.  On May 13, 2002, President George W. Bush signed into law the "Farm Security and Rural Investment Act of 2002" (Public Law 107-171), which includes a Resolution that the Humane Methods of Slaughter Act of 1958 should be fully enforced to prevent the needless suffering of animals.  It also calls upon the Secretary of Agriculture to track violations "and report the results and relevant trends annually to Congress."  In January 2004 the General Accounting Office investigated violations of the ‘Humane Methods of Slaughter Act’ which amended the Federal Meat Inspection Act and extended the policy nationwide by requiring that all federally inspected slaughter establishments adopt humane handling and slaughter methods.  The results of the GAO investigation can be found at http://www.gao.gov/new.items/d04247.pdf.

PRIMARY CITATION: 7 USC 1901 – 1907

7 U.S.C.A. § 1901 Findings and Declaration of Policy

The Congress finds that the use of humane methods in the slaughter of livestock prevents needless suffering; results in safer and better working conditions for persons engaged in the slaughtering industry; brings about improvement of products and economies in slaughtering operations; and produces other benefits for producers, processors, and consumers which tend to expedite an orderly flow of livestock and livestock products in interstate and foreign commerce. It is therefore declared to be the policy of the United States that the slaughtering of livestock and the handling of livestock in connection with slaughter shall be carried out only by humane methods.

7 U.S.C.A. § 1902 Humane Methods

No method of slaughtering or handling in connection with slaughtering shall be deemed to comply with the public policy of the United States unless it is humane. Either of the following two methods of slaughtering and handling is hereby found to be humane:

(a) in the case of cattle, calves, horses, mules, sheep, swine, and other livestock, all animals are rendered insensible to pain by a single blow or gunshot or an electrical, chemical or other means that is rapid and effective, before being shackled, hoisted, thrown, cast, or cut; or

(b)  by slaughtering in accordance with the ritual requirements of the Jewish faith or any other religious faith that prescribes a method of slaughter whereby the animal suffers loss of consciousness by anemia of the brain caused by the simultaneous and instantaneous severance of the carotid arteries with a sharp instrument and handling in connection with such slaughtering.

II.        Captive Bolt/Exsanguination:  Method of Achieving Insensibility Used in the United States

The penetrating captive bolt followed by immediate exsanguination (bleeding out) has been the preferred method of achieving insensibility of equines in American slaughterhouses since the early 1980’s. The mode of action of a penetrating captive bolt gun is concussion and trauma to the brain. This requires that it be held firmly against the surface of the head over the intended site. Because placement and positioning of the projectile is critical, some degree of restraint is required for proper use of this device.

While the destruction of brain tissue with the penetrating captive bolt may be sufficient to result in death, operators are strongly advised to ensure death by exsanguination.

(Source:  http://lacs.vetmed.ufl.edu/HumaneEuthanasia/Ex.htm)

It is important to note that in the foreign owned equine slaughterhouses operating in the United States, no form of restraint is used when the equine is in the kill chute or ‘knock box’ waiting for the penetrating captive bolt to be applied.  In some instances, it takes several attempts to effectively apply the penetrating captive bolt the equine, if this is achieved at all.  The use of the penetrating captive bolt is in violation of 7 U.S.C.A. § 1902 (a) of the Humane Slaughter Act as this methodology requires more than one blow and is inefficient at rendering equines immediately insensible.

(Sources: (i) Dr. Lester Friedlander, DVM and former Chief USDA Inspector, and (ii) Humane Farming Association video documentation at http://www.manesandtailsorganization.org/media.html)  

Use of the captive bolt causes extreme pain.

In a study conducted at Hanover University, EEG and ECG recordings were taken on all animals to measure the condition of the brain and heart during the course of slaughter and stunning.  EEG readings showed that although the animals were apparently unconscious soon after stunning with the penetrating captive bolt, they were experiencing severe pain immediately after stunning.

(Source: http://www.themodernreligion.com/misc/an/an_slaughter.htm)

Horses regain consciousness approximately 30 seconds after the captive bolt is applied.

Due to the inherent differences in skull structures of bovines and equines, each species reacts to the captive bolt differently.  The brain of an equine is further back in the skull compared to a bovine.  The equines regain consciousness and are not insensible to pain shortly after they are shackled and hoisted.  Therefore, they are very much aware of being butchered alive.

(Source:  Dr. Lester Friedlander, DVM and former Chief USDA Inspector.)

III.             No Other Methods of Equine Slaughter Comply with the HSA of 1958

(1)       Electrocution – has been defined as 'cruel' by the American Horse Show Association in response to owners who have electrocuted their horses for insurance money. Federal Courts have upheld the Association's contention that electrocution is cruel. Therefore, it cannot be used as a method of humane slaughter for equines.

(2)               Drug Overdose – this method saturates the tissues and leaves residues thereby making the meat inedible.

(3)               Carbon Monoxide – this method saturates the tissues and leaves residues thereby making the meat inedible.

(4)               .22 Caliber Gun Shot – This particular firearm is inappropriate for equines due to the thickness of the skull structure of an equine.  Using the .22 caliber rifle does not achieve instantaneous insensibility of equines.  Larger caliber firearms such as a 9mm or .357 are required to efficiently penetrate the skull and cause the massive brain destruction necessary to achieve instantaneous insensibility. (Source:  Procedures for Humane Euthanasia of Sick, Injured and/or Debilitated Livestock - http://lacs.vetmed.ufl.edu/HumaneEuthanasia/gun.htm).  Additionally, the horse cannot be restrained and this method is dangerous to workers.

IV.       The American Veterinary Medical Association and the American Association of Equine Practitioners Positions Regarding Equine Slaughter

Both the American Veterinary Medical Association and the American Association of Equine Practitioners deem the use of the penetrating captive bolt ‘acceptable.’ The American Veterinary Medical Association 2000 Report of the AVMA Panel on Euthanasia evaluated Euthanasia according to this criterion:

(1)       ability to induce loss of consciousness and death without causing pain, distress, anxiety, or apprehension;

(2)       time required to induce loss of consciousness;

(3)       reliability;

(4)       safety of personnel;

(5)       irreversibility;

(6)            compatibility with requirement and purpose;

(7)       emotional effect on observers or operators;

(8)            compatibility with subsequent evaluation, examination, or use of tissue;

(9)       drug availability and human abuse potential;

(10)     compatibility with species, age, and health status;

(11)         ability to maintain equipment in proper working order; and

(12)         safety for predators/scavengers should the carcass be consumed.

The use of the penetrating captive bolt gun does not meet the AVMA Panel's criteria regarding "loss of consciousness and death without causing pain, distress, anxiety, or apprehension."  Unlike bovines (which the penetrating captive bolt was designed for) equines possess different skull structures, are flight animals, and attempt to flee the 'knock box' or 'kill chute.' That being the case, it takes numerous attempts before the animal is properly stunned, if this is achieved at all.

From documentation provided by the Humane Society of the United States and the Humane Farming Association it is clear that these equines are feeling pain due to the number of attempts taken to stun them, and are extremely distressed, anxious, and apprehensive.

This invalidates criteria 1, 2, 3, 6, and 10 of the AVMA's criterion for 'humane euthanasia.'

The AVMA position regarding the use of the penetrating captive bolt is in violation of 7 U.S.C.A. § 1902 (a) of the Humane Slaughter Act as this methodology requires more than one blow and is inefficient at rendering equines insensible.

CONCLUSION

The use of the penetrating captive bolt is in violation of the Humane Slaughter Act generally, and 7 U.S.C.A. § 1902 (a) specifically.  Any other method of slaughter as applied to equines is in violation of the Humane Slaughter Act of 1958 generally, and 7 U.S.C.A. § 1902 (a) specifically.

© 2005 Ellen-Cathryn Nash for Manes & Tails Organization with contributions from Vivian Farrell of the Int'l Fund for Horses & Dr. Lester Friedlander, DVM

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