Open Letter to the Canadian Food Inspection Agency | Horse Canada
As we can see, conditions in Canada are the same as in the U.S.: Denial and trivialization is serious problems involving unacceptable cruelty to the horses and unacceptable food safety issues for consumers. No wonder the European Union is planning to require the U.S., Canada, and Mexico all to implement a traceability system comparable to the passport system in use in the EU by July 31, 2013 or the horses from these countries will no longer be accepted by the EU for export for human consumption.
Open Letter to the Canadian Food Inspection Agency
Canadian Thoroughbred March 15, 2012
An Open Letter to the Canadian Food Inspection Agency
March 13, 2012
Dr. Martin Appelt
National Manager
Meat Programs Division
Canadian Food Inspection Agency
1400 Merivale Road
Ottawa, ON K1A 0Y9
Dear Dr. Appelt:
In view of Dr. Brian Evans’ prolonged leave of absence, we are sending this package for your review. Enclosed please find full, unedited video footage of our investigative report “Pasture to Plate – The True Cost of Canada’s Horsemeat Industry” at Les Viandes de la Petite-Nation Inc. on July 13 and 14, 2011.
(Links to the Pasture to Plate web page: http://www.defendhorsescanada.org/lpn.html and the full 88-page report: http://canadianhorsedefencecoalition.files.wordpress.com/2011/12/pasture-to-plate.pdf.)
The Canadian Horse Defence Coalition notes that the CFIA has not at any time requested full footage of the 2011 investigation but has made numerous statements to the public based on posted information only. We trust that viewing the footage in its entirety as well as the memory stick containing photographs of EID documents (matched up to horses slaughtered at Les Viandes de la Petite-Nation) will dispel many of the doubts expressed and misinterpretations made by the agency, including:
“You have expressed concerns about the safety of horsemeat with respect to possible drug residues and referenced photos of Equine Identification Documents (EIDs) that are purported to be incomplete, inaccurate or falsified. All equine owners intending to sell animals directly or indirectly to Canadian meat processors must provide an EID that reports all vaccines, medications or occurrences of illness within six months of slaughter. The photographs in question have been determined to be taken at an auction in the United States. There is no indication that these documents were presented to any Canadian slaughter plant.”
“The EU has accepted the EID as an alternative to its passport system because both systems achieve a similar outcome….EIDs are checked daily by CFIA veterinarians and filed by operators at each federally registered establishment slaughtering equine….Omission or falsification of information on EIDs of horses presented for slaughter is an offence.”
“There are significant limitations to the use of video footage in the absence of eye witness testimony as the basis for enforcement or prosecution purposes.”
“This [the inability of the recently released undercover video footage to be used for regulatory enforcement purposes] can be further compounded when there is a significant time lag between the shooting of the video and its presentation to the CFIA and when the video has been edited.
“Recognized subject matter experts and international humane standards call for assessment of several critical features to affirm the effectiveness of the stun procedure that include the eye, the tongue, and the nose, which can only be determined from the front of the animal. As the video was taken from behind, it is not possible to conclusively use the video to make these assessments.”
“With respect to the large Belgian that is seen to have received multiple stuns, while its state of consciousness is unclear, nevertheless this is one area of operations being assessed.”
The CHDC would like to respond to the above points. The allegation that the EIDs presented as evidence was “determined to have been taken at an auction in the United States” is totally unfounded. Please review the photographs of the EID forms and compare them to the tattoo numbers of horses killed at the plant. Our report, Pasture to Plate: The True Cost of Canada’s Horsemeat Industry (copy enclosed), unmistakably illustrates this connection. Has our report, which has been posted on-line since release of the investigation, even been read by the CFIA? There can be no dispute that the documents photographed at Les Viandes de la Petite-Nation arrived along with the horses that were slaughtered. This then begs the question, why isn’t the regulation that dictates: “Omission or falsification of information on EIDs of horses presented for slaughter is an offence” being enforced? It is very evident when reviewing the EIDs that a pattern emerges and it is very clear to see that some EIDs have obviously been “pre-written” across the top with “Drug-free six months”, and the appropriate boxes checked to agree with this information. Why did the CFIA inspectors and slaughter plant operators not flag this for concern? What remedial actions has the CFIA taken against auctions and owners that have submitted incomplete, incorrect or falsified EIDs? In addition, what actions has the CFIA taken to ensure Canadian and American horses sold at auctions have EIDs that are filled in completely, correctly and truthfully?
Why is the CFIA expending so much energy on denial, rather than enforcing legislation and regulations that already exist and simply need to be utilized?
Regarding drug residues in horsemeat, has the CFIA taken into consideration studies such as a recent one conducted by the Wild for Life Foundation that showed 70% of the annual thoroughbred foal crop in the United States are dying in slaughterhouses each year
(http://www.wildforlifefoundation.org/Case_Study_U.S._Thoroughbreds_Slaughtered_2002-2010-WFLF.pdf)
Many of these horses are shipped to Canada for slaughter. Bred for the racing industry, they have been administered drugs such as phenylbutazone, which, as you know, is listed on your website for drugs not permitted for use in equines slaughtered for food, and banned from the food chain. The CFIA may wish to deny the connection, but this will not erase what the public already knows – that the likelihood of prohibited drugs being inadvertently consumed by people in Quebec and overseas is very high. By the CFIA’s own admission, two horsemeat samples have tested positive for phenylbutazone in Canada since 2010. As the most sensitive target for this drug is kidney [Metabolism Excretion, Pharmacokinetics and Tissue Residues of Phenylbutazone in the Horse, Lees, P., Taylor, J.B., Maitho, T.E., Millar, J.D., Higgins, A.J., 1987. Cornell Vet. 77, 192–21: http://www.ncbi.nlm.nih.gov/pubmed/3568689, and not muscle as claimed by the CFIA, one can only wonder how many more positive samples would have been found if the target tissue were the correct one. Further, in an e-mail to CHDC, the CFIA stated that only 143 samples taken from 93,812 horses in 2009 were tested for phenylbutazone - a woefully inadequate testing sample considering that most horses at some point in their lives have been administered this drug.
With regard to the statement about video footage versus eyewitness testimony, we seriously wonder how this statement would play out in court. Video is an objective accurate account of an event; eyewitness testimonies have often been found to be flawed due to human error or bias. Is the CFIA saying that video images tell lies? The public can view the stun footage online, including longer clips of just some of the ineffective stuns that we released the day this letter was mailed, captured at Les Viandes de la Petite-Nation in July 2011, and decide for themselves whether an eyewitness statement would have been more accurate than real-time footage. It is truly appalling that the CFIA has chosen to trivialize evidence and to shirk its responsibilities toward suffering animals and the general public that relies on the agency to be transparent and truthful.
The CFIA states that there was a “significant time lag between the shooting of the video and its presentation to the CFIA”. The time lag of less than five months occurred because it was our duty to have the evidence thoroughly assessed by independent animal welfare professionals before handing it over to an agency that has proven itself beholden to industry. We have learned this from the three prior horse slaughterhouse cruelty cases we have brought forward since 2008, to the disturbing documents we received in response to a freedom of information request on the CFIA's botched handling of the Natural Valley Farms/Natural Meat Company cruelty case. Truly the CFIA has become the fox that guards the henhouse. The mandate of the CFIA is to ensure food safety. The mandate of those involved in animal protection is exactly that—to safeguard the well being of animals. The CFIA’s poor track record in the past concerning slaughterhouse investigations did nothing to assure us that this most recent slaughterhouse footage would be handled fairly. As expected, the agency has once again demonstrated, via a continuing stream of shockingly poor and groundless excuses, that animal welfare is not only not a concern for the agency but that it appears to be the agency's role to protect industry at all costs - especially those costs borne by the animals under its “care”.
Certainly it is true that a number of checkpoints on the head of an animal are used to determine whether stunning has been effective. However, whinnying, rearing, mouthing (visible when horses moved their heads to one side) should not be ignored and were often evident on the videotape. The sheer numbers of re-stun attempts were also indicative of horses not rendered insensible after one shot, as was the shooter "replying" to unstunned horses' whinnying. Also, the shooter's statement "Aye - you're not dead" is clearly indicative of a still-conscious horse despite numerous attempts. The shooter was clearly visible from the front, showing his repeated attempts with the captive bolt pistol. We would like the CFIA to explain, if the inspector has the authority to stop the line, why he did not do so, given that this particular shooter was clearly lacking in training? We further ask the CFIA what retribution this shooter and/or Les Viandes de la Petite-Nation, as well as the CFIA inspector, received as a result of these obvious acts of incompetence. Were these acts treated as infractions, and have any prosecutions followed? To deny the importance of these other parameters in determining sensibility is illogical and proves to the public that the CFIA is simply covering up cruelty.
Dr. Nicholas Dodman, anesthesiologist and animal behaviourist at Tufts University stated the following regarding the large Belgian whose level of consciousness the CFIA is questioning: [After five shots] “This large horse still appears to be conscious and is shot again in the forehead and even that doesn’t do it as it heaves and tries to rise again…The large size of this horse plus imprecise CBG placement probably led to this totally unacceptable and inhumane result.”
Dr. Dodman’s expert opinion on practices at Les Viandes de la Petite-Nation concludes with: “…my final conclusion, after reviewing 150-plus horse slaughters in this series of videos, is that the process was terrifying for most of the horses and, in many cases, horribly inhumane. The inhumane treatment of horses at Les Viandes de la Petite Nation must be stopped immediately.”
We would also like to address our concerns regarding the design of the knock box that was raised in our report. It is plainly evident that there is no provision made, besides a flimsy plastic curtain, for horses to avoid viewing the bleed-out/butchering room. Many horses looked inside past the curtain (that was sometimes left open) and this understandably elevated their fear levels. Also evident was the fact that larger draft breeds did not fit into the small dimensions of the knock box, causing many of them to hit their heads on the overhead stanchion. It was also these large draft types that more often required multiple shots to render them unconscious. In addition, the shooter had to reach up to these larger horses, causing him to shoot at the wrong angle, which is supposed to be from the top down, not reaching up high over his head to try to obtain the right angle. We noted as well that there was no evidence of rubber matting to secure their footing. The knock box floor was not hosed down regularly to clear slippery blood, urine and manure. Finally, the decreased elevation into the stun box caused many of the horses to stumble upon entering it.
We have learned from Dr. Brian Evans that a rifle will now be the weapon of choice at Les Viandes de la Petite-Nation. This decision is baffling to us as our past evidence from Bouvry Exports and Viandes Richelieu (2010) clearly illustrated blatant animal suffering when shooters were faced with moving targets, specifically the thrashing heads of terrified horses. We also recall that observers are not permitted to be in the shooting area. Who, therefore, does the monitoring, and how will oversight be achieved?
We expect to receive a detailed response within 30 days explaining how the agency will respond to the violations of the Meat Inspection Act (specifically 62. (1), 63. (2), 64, 65, 78, 79 (a) and 80); the OIE Standards of Slaughter (Chapter 7.5); the American Meat Institute Slaughter Audit standards; and the fraudulent EID activity. Specifically, we require answers to the following areas of concern:
High percentage of inaccurate stuns (40+% over two days of recording)
Use of “pithing” of horse which is known to render an animal immobile but not unconscious when stabbed for bleed-out
Length of suffering inflicted on horses repeatedly shot (up to 3 1/2 minutes for horse 33 on day 1)
Terror-filled environment
Mishandling of a “downed” animal (the downer horse shown during the walk-through who was not penned alone or euthanized)
Fraudulent EID activity
Lack of CFIA inspector presence
We also require an explanation for the agency’s choice of preference for testing muscle tissue rather than kidney for phenylbutazone. What scientific study is the CFIA relying upon when choosing muscle as the target for testing?
And, finally, Dr. Evans states in his earlier letter: “As a result of investigations and enhanced inspection activities, a number of actions have been taken, including training and certification delivered…et al.” We would like to see documentation of all corrective actions the CFIA has introduced, including monetary penalties, suspensions and/or revocation of operating licences, and/or legal charges brought against either persons or companies at any and all of the four slaughter plants operating currently in Canada.
It is not too late for the denial to stop and for truth and pursuit of justice to take its place.
Sinikka Crosland, Executive Director
Canadian Horse Defence Coalition
sinikka@defendhorsescanada.org
http://www.defendhorsescanada.org/
Update ~ I just got the bright idea of putting the board on my sidebar so it would always be visible. What do you think?
This is my
Horse Slaughter Board from Clipboard. The board is fully interactive. Click on it and a light-box will open and you can interact with the board just as if you were on the Clipboard site.
Be sure to check back because I will be adding to this board frequently.
Hope you enjoy it!
Related articles
Horse Slaughter: The Money Trail | Habitat for Horses
Even if the slaughter of American horses for gourmands overseas to savor means nothing to you, even if you never even heard of the issue, please read this! Even though it is a bit of a long read, it should be required reading for every American citizen. If this shocking description of how professional lobbyists distort our political processes for their own gain doesn't terrify you, it should. It should also make you furious. Our democratic process his been hijacked by a bunch of white collar criminals, and the will of the people has become totally irrelevant. Judge for yourself.
Horse Slaughter: The Money Trail
From left to right: ex-US Senator and AQHA lobbyist Conrad Burns, Reps. Bob Goodlatte and Jack Kingston, Senators Roy Blunt and Herb Kohl, ex-US Senator Larry Craig, and horse meat lobbyist “Chuck” Stenholm. In all fairness, horse slaughter lobbyist Sue Wallis has gained in her own right a seat in the Hall of Shame despite not being a federal legislator. lobbyists
In the last part of this series, we will look at the money trail. In doing so, we will detail the identity, motivation and the not-so-clear connections that continue to put horse slaughter up as “a necessary evil.”
The horse slaughter lobby is a set of fronts and organizations (in some cases comprised of just one or a few individuals) that make a monetary profit out of defending the existence of horse slaughtering, either directly or indirectly, or that use it as an excuse to further a concrete political agenda, which in almost every case implies an economical profit, be it merely from lobbying or by certain industrial strategies related to cutting down production costs.
The object that drives the horse slaughter lobby is money. It has never been about equine welfare, humanity, professionalism or reliability. Like in most political issues, those defending horse slaughtering are in it for the money or for the prospects of monetary earnings in a variety of forms, from obtaining campaign donations to the renewal of Public Relations contracts or the obtainment of power to shape legislation to their own advantage.
Over the years, the horse slaughter lobby proved to be a formidable force, successfully blocking any attempt at ending the needless butchering of American horses despite the overwhelming opposition and repulsion the practice draws from regular Americans. Its strength and resources are substantially greater than what could be initially expected, given that the horse meat business represents only a tiny fraction (about 0.3% at best) of the total revenue of the overall horse industry. Readers may be tempted to conclude the Belgian-owned horse meat corporations are responsible of the compounding and strength of the horse slaughter lobby, but this does not seem to be the case. Although the horse meat industry is generally regarded as a multimillion dollar business, these corporations are rather quite small in comparison to other sectors like manufacturing car seats or a pizza franchise.
Although the foreign-owned horse slaughter corporations were initially involved in lobbying efforts to shield their activity from litigation and legislative efforts, they are no longer active in US politics. Since the closure of the three former US plants and their strategic relocation across the borders, the Belgian horse meat companies have shown little to no interest in moving back to the United States despite having opportunities and money to do so. Why? And, if the foreign-owned horse meat industry is no longer behind legislative efforts on horse slaughter then, who funds the horse slaughter lobby? For what purpose? To answer such questions we need to understand the background of the horse slaughter industry in America.
They became involved in the US because the basic infrastructure was already in place, prices were low and exportation was easy. With globalization and improved infrastructure around the world (particularly in Mexico and South America) and the cheapening and optimization of air and sea freight, that initial edge has been made irrelevant. The same quality product, without drug residues, could be sourced from other countries at a much lower cost and without fighting tight regulations and opposition by the public.
For example, when Velda NV abandoned the Natural Valley Farms plant in Saskatchewan after having its license suspended, instead of looking for a new plant to continue killing American stock they simply moved all operations to an already existing plant they had in Australia (Metro Velda Pty. Ltd.).
Similarly, Chevideco operates plants in Argentina, Brazil and Romania (apart from its Mexican one) and recently, while attending the meeting organized last March in Missouri’s Mountain Groove by Wallis’ Unified Equine LLC to solicit money for building a horse slaughter plant in the town (theoretically for Chevideco to kill horses), the President and General Manager of the Belgian company, Michael Beukelaar and Olivier Kemseke, were adamant in stating that they will invest no money or assets whatsoever in building the plant, being interested in a turn-key lease-only operation they can drop at any time at no cost should any inconvenience arise. Such a stance is an intelligent one since the Belgian horse meat companies are well aware the US government will not make any effort to adapt its regulations and legislation to make them compatible with EU drug residue and traceability standards and, should the European Commission ever decide to take action to bar poisonous American horse meat from entering the food chain, they could absorb the impact of such ban by simply walking away.
In other words, the foreign horse meat corporations were in the US because they were benefiting from low prices resulting from a throw-away culture some Americans have acquired toward horses. If these companies are provided an economical advantage elsewhere, they will go there. The fact the meat would not be “genuine American flavor” is not really an issue; they can always put up a cowboy or a wild horse sticker in the polystyrene tray. Once it is understood the Belgian horse meat corporations have little or no interest in coming back to the US, it is evident why they don’t seem to actively participate in local American politics.
Who does fund the horse slaughter lobby then? To answer that we need to follow the money.
Who really benefits from horse slaughter in America? The killer buyers? They do benefit from horse slaughter, indeed they seem to do quite well, although they are not the power behind the horse slaughter lobby, just the workers doing the dirty work. Instead, we are looking for people of social and economical status, capable of getting a hold of politicians and controlling them. Let’s keep following the money trail.
The answer to the above question comes after examining data collected by USDA at one of the US-based plants regarding the breed of slaughter bound horses. According to such data, roughly 70% of horses slaughtered are quarter horses, followed by 21% thoroughbreds and other breeds. Since quarter horses have a strong, muscular conformation, are relatively heavyweight and numerous (meaning lower prices) they are indeed preferred by the horse meat corporations, which therefore maximize the ratio of “raw matter” obtained per dollar spent purchasing the animal. However, the fact that quarter horses are slaughtered in numbers greater than any other breed is not just a mere coincidence. In fact, almost any piece of pro-slaughter propaganda, misinformation and horse-butchering eulogy published in the past ten years can be traced back to the American Quarter Horse Association (AQHA), despite the efforts of the Amarillo-based breed registry to conceal their origin by developing a network of think-tanks and phony “non-profit” organizations.
Bingo! We’ve just found one of the main forces behind the horse slaughter lobby. But, why would a breed registry advocate the brutal butchering of the very reason of its existence? And how is it possible for a single organization of that apparently irrelevant nature to amass such an incredible amount of political power? The answer is rather easy: money, under a couple layers of politics and ideology.
AQHA is by far the most important breed registry in the world, with over 3 million horses registered. Over the years, AQHA has grown into becoming a pure for-profit corporate complex, with their top officers being people of prestige in rural America politics. Like many political entities, it is more concerned about its self-preservation than to the duties or mission that brought it to life in the first place. It no longer carries out the function of a breed registry, i.e. assuring horses registered are of pure breed, maintaining standards and prevent fraud. Instead, AQHA has become a money-making machine.
The logic behind this money-making scheme is quite straight-forward: Boost foal registrations at all costs in order to increase revenues. AQHA obtains most of its funding (at least on paper) through registration fees. By promoting indiscriminate breeding they increase registration numbers and thus the amount collected in fees, which are revenues later divided between the organization’s managing board and its network of fronts.
During the last 20 years, AQHA has been promoting the indiscriminate, systematic, irresponsible over-breeding of horses in order to achieve its revenue goals. It wasn’t all that long ago when officials of AQHA and its subservient, satellite registries like APHA, NCHA and a few others were blowing their horns about huge facilities where they were conducting industrialized horse cloning in order to preserve a champion’s legacy. The numbers speak out for themselves: According to AQHA, in 2010, despite the economical instability, high unemployment and elevated fuel prices (further hurting the live horse industry), over 83,000 new horses were registered with the organization. Two years before, in 2008, about 140,000 animals were registered. During the years of the housing spree and the cheap credit fest the numbers were even higher.
Sadly, no one thought of the critical flaws in the push for mass production.Horses are not commodities; they live many years and eventually the exponentially growing number of foals would hamper new registrations. The solution devised by AQHA officials, ruled therefore to be “final,” is also quite simple: make room for more. This is where slaughter comes in. Horse slaughtering provides AQHA the means to maintain a steady flow of registrations by providing an easy, convenient outlet to get rid of the excess foals bred every year as a result of its over-breeding policy. Under their concept, the slaughtering of older horses provides room for new ones from which more revenue is extracted in the form of registration fees. In addition, horse slaughter enables AQHA pro breeders (especially those in and near the organization’s top echelon) to get winner horses without much of an effort; obtaining a champion is just a question of arithmetical probability and churning babies like crazy. Those that fail to perform as expected, don’t have the desired color, markings, character or that simply are poorly trained or get injured are taken to the slaughter auction and tossed in a killer truck. Problem solved.
Horse slaughter rewards these mass breeders by providing cash for their “byproduct” horses, further encouraging the practice (regarded by AQHA as its “secondary market for horses,” to quote AQHA failed backyard breeder and Sue Wallis’ favorite follower, Dave Duquette) to the point many breeding operations obtain more money from selling for slaughter than from sales of horses for traditional purposes. Many AQHA breeders currently breed primarily to sell horses at kill auction, with the traditional activities of selective breeding and training of horses for riding, racing or ranch work as purely secondary or even anecdotal. They bred hundreds of mares and sell the offspring to the killers, raking an average of $500-600 per head. If some turn out to have good traits and prospects to be “champions”, they can sell them for $5000 or more or keep them for internal use until they got injured beyond recovery or the owners get tired of them. Their breeding strategies involve nothing more than simply turn out a stallion with a hundred mares in a very large pasture and wait till the foals grow up; keep the best two and cull the rest, tossing them like garbage in the next kill auction.
As sad as it is, AQHA horses are nothing than disposable commodities. In this sense, AQHA has effectively turned the noble bond between horse and rider into a standardized meat producing operation in which horse breeding is no different than raising beef cattle for McDonalds.
To a lesser extent this also applies to a group of individuals within the thoroughbred racing industry, with the notable difference being that the industry acknowledged horse slaughter is damaging its image and has taken some steps in the right direction, such as supporting the passage of a federal ban on horse slaughter or devising non-slaughter policies at racetracks. However, despite such good intentions, many thoroughbreds are still slaughtered as a consequence of some trainers adopting AQHA’s throwaway practices and managing to get around the tracks’ no-slaughter policies by means of a series of deals allowing them to ship directly to the killers right off the track stalls, in the face of the passiveness of racing authorities and the Jockey Club.
So understanding that the AQHA’s directors and their friends are padding their pockets with blood money still doesn’t explain how this rather small bunch of folks can mobilize such a strong political force nationwide. For that answer, we dig a little deeper.
Since 1960, agribusiness corporations, notably the meat industry, have been fighting any piece of legislation or activity that either tries to regulate it or require them to adopt higher standards in their production mechanisms. In their sights are any laws aimed at the humane treatment of animals, pollution management or banning the use of certain chemical compounds, since these impact either spending money on infrastructure or abandon practices maximizing their profits and lowering their production costs. Similarly they have been trying to silence the exposure by concerned individuals of practices involving animal cruelty.
In general, agribusiness confronts anything that remotely questions the legal, ethical, medical, scientific or social grounds not only of its practices, agribusiness, particularly the meat industry, reacts aggressively to both stronger regulations and anything that is remotely related to the humane treatment of animals or environmental protection. From livestock feedlot laws and urban waste management to horse slaughter, agribusiness always vocally opposes any piece of legislation, behavior or concept that supposes a step forward in the right direction, effectively deploying a zero tolerance policy that has become its defining signature.
The rationale behind such zero tolerance policy to preserve its economical interests and power position is to deny any ideas generally identified as “animal welfare” or “environmentalism” from gaining a foothold in the minds of both policy makers and society. It does so by employing vast amounts of resources in direct political action and the media.
Our modern, information-saturated society is quite susceptible to fear, so it is not surprising that agribusiness resorts to fear as its main tactic. At the forefront of the “fear” argument is the "slippery slope" justification. This tactic consists on scaring both policy makers and society by making them believe that, if legislation proposed for a very specific issue is passed, those supporting the law will go in for more and, like a slippery slope, the country will fall in an spiral of concessions which will eventually ban all forms of agriculture. This argument may be shaped to any form and adapted to the needs of any specific issue.
This is where AQHA’s unwanted horse myth came from: If horse slaughter is banned, all the “unwanted horses” will not have anywhere to go and thus will be abandoned, creating further problems for the government and the public alike. Not far behind is the argument that if horse slaughter is banned, the “animal rights activists” will then go after cattle, swine, chickens and all forms of meat.
These slippery slope arguments are bizarre and ridiculous, yet agribusiness keeps using it as the base of its lobbying efforts, despite the fact animal welfare is an overstated threat for its own interests. What does this have to do with horse slaughter, which is not a national meat industry like beef, pork or poultry, and why is the issue being represented by the agribusiness lobby since it plays such a tiny role? We’re almost there…
Far more important than the obvious falsehood, cheapness and bizarreness of the agribusiness lobby slippery slope argument is that agribusiness unquestionably fights fiercely anything put before it. Even more relevant is that agribusiness has enough resources to fund the necessary actions to keep AQHA’s slaughter pipeline open but also to feed all the phony fronts, lobbyists and assorted political accomplices living off horse killing lobbying activities. When taking both factors together, it doesn’t take much to figure out agribusiness will pick AQHA’s horse slaughter issue as if it were its own and not only fight it all the way for AQHA and friends but also pay for all associated costs; the deal couldn’t be better for AQHA while the Belgian horse slaughter companies get a free ride through the entire American political system at the expense of the US meat industry.
So American agribusiness is footing the bill of the horse slaughter lobby because of their zero tolerance policy revolving on the slippery slope but… why would they pay for lobbying issues that have nothing to do with them and which don’t pose a real threat, since horses are not part of the American meat industry, and the interests of the horse industry have little to do with those of the factory farms?
This is where the “good ol’ boy network” comes in (for those unfamiliar with the term it refers to the form of cronyism predominant in rural America, particularly in Southwestern states). It turns out that many AQHA top officials also hold important positions in agribusiness organizations, in lobbying entities defending agribusiness or simply have some important acquaintance in such entities. The also have positions in government and corporations that don’t belong necessarily to the agribusiness sector; sometimes they are also important ranchers or hold public office in state and local government units. Without any doubt, the horse slaughter lobby has used such positions to their own advantage, gaining the favor of agribusiness and using its machinery for their own gain at the expense of the horse industry. This also applies to all other satellite organizations of AQHA that follow the directives of the Amarillo-based corporation, including American Paint Horse Association, National Cutting Horse Association, Professional Cowboys Rodeo Association and American Horse Council. However, even accounting for the effects of the good ol’ boy network, this group seems to be still too small to pitch on its own an entire industry sector nationwide in a confrontation against the majority of the American population (80% according to recent polls), opposing the slaughter of horses for dinners abroad. There must be a co-factor for such AQHA’s cronyism to be all that effective.
Agribusiness ended up believing its own lies, slipped down its own greasy slope, bumped its head on the floor and ended up taking its rhetoric for real – that those concerned about the endangered, over-exploited environment or about the unethical, amoral brutality our throwaway society dispenses to animals have a hidden agenda to sweep them from existence. They perceive the so-called “animal welfare” or “environmentalism” as such a grave threat that defensive action is no longer sufficient, it is necessary to strike first before “animal rights” can react and thus effectively sweep them from the political and social scene. In its delusions, agribusiness thinks it must wage war. Such psychotic behavior partially explains the unprecedented stream of retrograde and totally bogus anti-animal legislation introduced since 2008, of which the numerous pro-slaughter state bills are an example, arising from a major build-up in lobbying spending by agribusiness.
Agribusiness’ detachment from reality regarding the horse slaughter issue is so big that some individuals within the meat industry, notably those within the influence circle of Sue Wallis and her horse meat cult, have fantasized the possibility of not just competing with the well-established Belgian horse meat cartel for European sales and eventually taking over their market, but also creating a domestic market for horse meat, thus becoming the new kings of agribusiness.
In retrospect, the continuous indoctrination of those surrounding the meat industry, including the closely associated horse industry, have many believing that animal welfare its indeed their enemy, and that they must band with agribusiness to defeat it. They account for most of the 20% of individuals in the US that support horse slaughter, even though most admit they would not eat horse meat and would not knowingly sell horses for slaughter, all while saying that they consider slaughter to be a form of euthanasia.
Perhaps you’re now saying, this can’t be real. Even if a few Western beef bigwigs have gone nuts and believe there is a conspiracy against them, most of these corporations are big companies that have lots of auditors and experts on their payroll, so they can’t fall so easily for this and spend millions just to keep happy some AQHA guy that knows someone who knows the CEO’s sister. Indeed, it isn’t all that easy. The situation described above can only be understood if we add another factor that turns this rather complex mixture of greed, money and ideology into the entity we identify as the horse slaughter lobby. What can this be?
On one hand we have AQHA and those who directly profit from horse slaughter. They have an evident interest in keeping horse slaughter going for their own gain. however, this rather small group of individuals doesn’t have the resources to move all the political machinery to achieve its objectives. On the other hand, we have an agribusiness at war against “animal welfare”. Such agribusiness is, in itself, a gold mine for a class of consummate white-collar racketeers that know how to exploit the vulnerabilities of this type of entity, seeking for help to succeed in the cavernous world of professional politics, and this leads us to the last component of this concoction of interests: lobbyists, professional lobbyists, those who are hired to pimp your cause and procure you the favors of politicians of easy virtue (who at some point of their careers were or will become lobbyists).
We are not talking about the PR or marketing guys employed at a company to represent it or deal with the media, that’s run-of-the-mill staff. We are talking about a true industry with its very own agenda that might very well be detrimental to the customers they represent, acting as an exclusive intermediary between entities seeking to make a point in legislatures for some reason and politicians that hold the key to what such entities want. In other words, lobbyists are middlemen that require you to hire them if you want to have access to politicians and eventually scoring a success in shaping legislation in your favor.
Initially, one could be tempted to think professional lobbyists only grant access, then it is up to the politicians to listen up and take note of your issue, but unfortunately things are usually more complicated. These professional lobby firms are composed of political insiders that worked at, formed part or will eventually form part of both legislatures and executive branches across the nation and hold a monopoly over a product almost nobody else has – personal acquaintances with decision makers. The reverse is also true: lobbyists have acquaintances in industry which can fund a politician’s race or even boost his career if the “right decisions” are taken. Politicians become lobbyists and lobbyists become politicians, in a sort of a legislative mafia. Over the years, this reciprocity between politicians and lobbyists has increased to the point that it is already a necessary condition to hire these professional lobby firms for politicians to act in your favor - that is, hiring a professional lobby grants you an automatic win.
And, of course, horse slaughter is no exception. For instance, Charles Stenholm was a former U.S. Representative for Texas’ 17th Congressional District (Abilene). Allegedly a rich cotton farmer, he was nurtured to power by Texas agribusiness, where he got in contact with AQHA’s elite. When his pal Tom Delay back stabbed him and redistricted his area, he went to work for lobby firm Olsson Frank Weeda Terman Matz PC to represent agriculture industry customers. Later, he was also hired by the scared Belgian horse meat corporations and masterminded a plan (that is the backbone of the horse slaughter lobby today) to use his other clients of the American agribusiness sector to lobby for horse slaughter for his own gain. Once favors to agribusiness and his AQHA pals were returned, he made a gambit expecting the Obama administration would pick him for Secretary of Agriculture and thus cross the revolving door again. His plan failed when Obama chose instead former Iowa Governor Tom Vilsack. Another notable example is far-right Senator Conrad Burns who, after losing his seat on the aftermath of his implication in the Tom Delay – Jack Abramoff scandal, went to work as a lobbyist for the AQHA.
Granted that lobbyists and politicians are virtually the same thing and that they hold a monopoly, it doesn’t take much to figure how this can be exploited by them in a variety of ways. As an industry, professional lobbying seeks to ever increase its own profits plus its self-replication and, like any company, it looks for to expand its horizons and create new market venues for its products. This is of special importance in the particular case of horse slaughter.
We mentioned before the Burns-Delay-Abramoff scandal. Such political corruption scandal revolved on a series of actions taken by politicians acting in concert with Abramoff to harm a target entity (notably gambling interests) or group of individuals in order to force them to take political action, which required the hiring of Abramoff and his associates in order to be effective, with Abramoff presenting himself as their “savior”. This effectively creates, through a racket-resembling scheme, a false demand for lobbying services which resulted in a stream of revenues for the parties involved. The result of such false lobbying effort was, in practice, irrelevant once the money was cashed in, but usually victims were lured into keep the lobbying effort, using the same tactics of a typical advance-fee scam. The same happens with the horse slaughter lobby, using American agribusiness as the target victim of the scheme.
Professional horse slaughter lobbyists, which have as customers agribusiness interests for other issues not related to horse slaughter, easily convinced their customers that anti-slaughter legislation is a threat and, by playing on their fears and offering them false information, engineered an artificial demand for their lobbying services which otherwise would not be necessary. That results in monetary profits for such lobby firms in a similar way Abramoff, Burns and their associates orchestrated a series of hits on gambling interests to force them into hiring Abramoff's lobby firm.
The situation becomes even direr if we take into account many presumed agricultural producer associations, such as the Farm Bureaus, are actually de facto PACs (Political Action Committees) with their own hidden agenda, revolving around the employment of lobby firms associated with their managing boards. Perhaps the best example of such a phenomenon is the AQHA itself. Apart from the fact that many of its top breeders and officials profit directly from slaughtering horses, some of its upper echelon also figured out there was a lot of money to be made out of agribusiness by covertly turning the AQHA into another PAC and tethering their operations to those of one or more professional lobby firms (such OFW). Their success in this regard is more than evident, as demonstrated by the stream of shady pro-slaughter fronts spawned out of the AQHA and OFW PC since 2005, all consistently feeding on agribusiness funding. This scheme applies to some degree to most players of the horse slaughter lobby, like the American Veterinary Medical Association (AVMA), which is a de facto PAC for OFW's own interests at the National Cattleman’s Beef Association. Something similar occurs with its equine branch, the American Association of Equine Practitioners (AAEP) which is an AQHA PAC inside the AVMA PAC.
Without any doubt, professional lobbyists are masterfully exploiting the vulnerabilities of the American agribusiness which, trapped in a web of fake interests and ideological lies, ended up funding a network of lobbying entities by using horse slaughter as an excuse for their own existence. Even if horse slaughter is eventually banned, the lobbyists would continue pushing for the repeal of the ban as long as there is money to milk from their agribusiness cash cow. This is the only way to explain how an entire industry that is unrelated and does not obtain any profit from horse slaughtering is so determined to defend the interests of the tiny fraction of individuals that really do, and continue to assist foreign competitors which are not even interested in coming back to the US. This is also the only way to explain in its entirety the ever-increasing amount of absolutely bogus anti-animal and pro-slaughter legislation introduced every year.
We commented before how AQHA's business logic had two critical flaws, the first one being that they need to kill their stock of horses to keep the flow of foal registrations going. The second is that killing horses looks bad. The AQHA had to come up with a way to sugar coat the issue and make it acceptable to the public. To do so, AQHA and its lobbyists at OFW had to convince the general public of the following premises:
No matter how you look at it, horse slaughter is good, for you, for us and even for horses. Following such a premise, the AQHA and its pro-slaughter fronts claim that horse slaughter is actually a “secondary market” for horses and that horse slaughter is good for horse owners because it helps maintain a bottom price for horses. Ironically, economics supposedly dictate that increasing the offer of something causes a drop on its value so the AQHA, by artificially increasing the number of horses bred each year, is precisely contributing to reduce their market value, hurting horse farms that bred for real purposes instead for bulk meat supply. Another example is their claim about slaughter being good for horses since otherwise they would be abandoned and would slowly die of starvation.
Another line in their lobby remarks is that horse slaughter is not slaughter but rather euthanasia and is thus acceptable to our society in a similar fashion euthanasia is acceptable to kill abandoned dogs and cats. Although euthanasia (from Greek eu, good, and thanatos, death) actually means ending a life to relieve pain and suffering when the subject is injured or sick beyond recovery, the AQHA, OFW and all their associated fronts have spun the term to refer to all kinds of death, regardless how painful, slow, brutal or unnecessary it might be. To back up such bogus claim, they resort to made-up “science” and thus asked their AVMA buddies to develop a report on “acceptable methods of humane euthanasia” which was coincidentally released when the first versions of the American Horse Slaughter Prevention Act were in consideration. The report is actually a collection of killing methods, from poisoning to brain microwaving which lauds captive bolt stunning as an “acceptable euthanasia method” as long as the head is restrained prior to impact and immediately followed by exsanguination, conditions that in any case are rarely (if ever) met in a slaughterhouse due to the chain production nature of the operation. Since slaughter is actually “euthanasia”, according to their logic, it is “good” and it can therefore be used to dispose of “excess” horses that are “unwanted” in the same way dogs are killed at the city pound without anybody raising an eyebrow. The fact that horse slaughter is as close to real euthanasia as being stabbed with a bayonet is to a peaceful death is omitted by covering the issue with a white coat to make it look “scientific” because the AVMA, the “veterinarians”, say so, so it must be true. According to the AQHA, slaughter is correctly called “processing.”
The entire process of painting the AQHA’s stance on horse slaughter into an acceptable process, with the aid of lobbyist and PR folks can be seen in an interview of the former AQHA President, Peter Cofrancesco III.
The trail of blood money, from the political machinery within the beltway to the lobby promoters to the national and state organization to the fake non-profits to the breed associations lead straight to the doorstep of the AQHA. The workers are the roughly 60 killer-buyers that do the dirty work while the others rake in the benefits. The money from the actual slaughter process is about as much as would be made by a large used car lot, but the ever increasing circle of involvement up the trail of money involves millions upon millions of dollars.
If you ever wondered why the slaughter industry, involving little more than 1% of the total number of American horses, has created such a political monster – now you know.
4 25 August 2012 — Jerry Finch
HSI/Canada Renews Calls for Prohibition on Horse Slaughter as Banned Substances Found in Canadian Horse Meat : Humane Society International
August 9, 2012
HSI/Canada Renews Calls for Prohibition on Horse Slaughter as Banned Substances Found in Canadian Horse Meat
Humane Society International/Canada
Horses slaughtered for meat in Canada are generally not raised for human consumption.
MONTREAL— Following confirmation of prohibited substances in Canadian horse meat, Humane Society International/Canada is renewing calls for a federal prohibition on the slaughter, sale, transport and export of horses for human consumption. Belgian authorities recently notified the European Commission about the reported presence of two unauthorized substances, clenbuterol and phenylbutazone, in horse meat that was imported into the European Union from Canada. Horses slaughtered for meat in Canada are generally not raised for human consumption and are commonly administered substances that are banned in food-producing animals.
Additionally, the United States Food and Drug Administration recently released a warning letter that revealed the presence of the same two banned substances in an American horse sold to a Canadian slaughter establishment. The American establishment cited in this warning letter provided false information in the Equine Information Document, which Canadian authorities rely upon to determine whether American horses exported to Canada have been administered substances not permitted for use in horses in the last 180 days prior to purchase of the animal. Specifically, this establishment “filled out and signed the producer’s name” and failed to ask the horse’s producer about its medical treatment history. Like Canadian horses, American horses are not raised for human consumption and are frequently administered substances banned for use in food animals.
“Slaughtering horses for human consumption is inherently inhumane and the recent discovery of prohibited substances in Canadian horse meat proves it may also pose a human health risk,” said Ewa Demianowicz, campaigner for Humane Society International/Canada. “Clenbuterol and phenylbutazone can be toxic to humans and have been banned from our food supply for that reason. Clearly, the horse meat protocols imposed by the Canadian Food Inspection Agency are inadequate and fail to ensure food safety.”
Humane Society International/Canada urges the Canadian government to take immediate action by enacting Bill C-322, which would amend the Health of Animals Act and the Meat Inspection Act, prohibiting the import, export and inter-provincial transport of horses for slaughter for human consumption.
The two prohibited substances were found in chilled and frozen horse meat that was subsequently distributed to Belgium, France, Germany, Italy, Luxembourg and the Netherlands. EU member countries have strict food safety policies, which should prevent domestic horses that been administered with substances prohibited in food-producing animals from ever entering the food chain. In comparison, current CFIA standards are insufficient and could lead to human health threats for those consuming horse meat, the majority of which is exported.
FACTS:
In 2011, more than 90,000 horses were slaughtered in Canada.
Horses are an extreme example of a flight animal. The panic and instinctive desire to escape causes them to thrash their heads frantically in the kill chute, making it difficult to effectively stun them prior to slaughter. As a result, many horses receive several blows before they are rendered unconscious.
Horses can be transported for up to 36 hours without food, water or rest in Canada. Horses are often crammed in trailers (sometimes double-deckers) designed for shorter animals, and travel in uncomfortable positions over very long distances.
Because horses are generally not bred as food animals, they are often administered substances that are prohibited in our food supply.
In 2011, MP Alex Atamanenko introduced Bill C-322, an act to amend the Health of Animals Act and the Meat Inspection Act to end the import and export (and transfer between provinces) of horses for slaughter for human consumption.
Posted Aug 17, 2012 by lauraallen
USDA/FSIS Cannot Meet the Legal Requirements for the Return of Horse Slaughter to the U.S.
Dear Secretary of Agriculture Tom Vilsack:
The Food Safety Inspection Service (FSIS) Administrator, Alfred Almanza, has been quoted as saying that the agency is moving quickly to accommodate two pending applications to open horse slaughter plants in the U.S. Though as I understand since then, the applicant in New Mexico has withdrawn the application, and the Missouri applicant is beset with legal problems and was apparently not even the owner of the property proposed for the horse slaughter facility and cannot acquire any ownership interest.
Regardless, a horse slaughter proponent is circulating a "petition" to urge FSIS to move more quickly in approving applications and make inspectors available for horse slaughter for human consumption. The USDA has a number of legal obligations when it comes to slaughtering equines for human consumption; USDA cannot meet any of these obligations and for this and economic, environmental and other health and safety reasons, should not allow horse slaughter.
Substantial Taxpayer Costs with No Economic Benefit
As the U.S. struggles to climb out of the most devastating economic recession since the Great Depression, it is puzzling why FSIS would take funds from an already depleted budget to use for a program to inspect horses to be slaughtered for human consumption. Surely, the threats to food safety and humane treatment of animals are already significant with a reduced budget. Why would any funds be used for a program that results in no economic benefit to the U.S. and instead threatens the health and safety of our local communities and equines?
Prior to the closure of the 3 horse slaughter plants in 2007, FSIS spent approximately $5,000,000 annually for inspectors, basically subsidizing the three foreign-owned (Belgian and French) horse slaughterhouses. Americans don't eat equines so there were no sales of horsemeat domestically and thus no sales tax revenues from slaughter. Horse slaughter facilities pay virtually no income taxes. One facility operating in Texas prior to 2007 paid $5 in federal income tax one year on $12 million dollars in sales. In the preceding 5 years the federal income tax was .3% or 1/3 of 1% of gross revenues or sales. A forensic analysis of the tax returns revealed that the company avoided U.S. income taxes by selling the horsemeat at a loss to an entity it owned in another country and then that entity distributed the product overseas at substantial profit. With no sales or distribution in the U.S. and no tax revenue, there is simply no benefit to the U.S. economy from horse slaughter.
The property tax revenue to Kaufman, Texas where a horse slaughter facility operated until 2007 was generally less than $2,000 per year, a mere pittance when compared to the city's costs for pursuing the facility's continual violations of its wastewater permit and in working to address violations of regulations of Texas Dept. of Health and the Commission on Environmental Quality. The city's legal fees just to address issues related to the horse slaughter plant exceeded its entire budget for legal fees in one year. The city was even fined by the TCEQ for the plant's failure to comply with backflow regulations that meant horse blood and waste backed up into sinks, toilets and tubs. When the plant finally closed, the city was left with nearly $100,000 in unpaid fines for wastewater permit violations.
The situation was no different at the horse slaughter plant in Ft. Worth and the other in DeKalb, Illinois. In DeKalb, the horse slaughter facility had waste permits that allowed contamination levels for waste water that were eight times higher than usual. Yet, the facility was out of compliance hundreds of times. It was not a matter of having old facilities. The owner, Cavel International, built a state-of-the-art pre-treatment system that became operational in 2004. The facility remained out of compliance with its permit regularly until it finally closed in 2007. The blood and waste from slaughtered horses oozed from the state of the art tanks. There were also hundreds of FSIS violations.
The same was true of Canadian Natural Valley Farms where a 2008 investigation revealed the state of the art waste pre-treatment facility overflowed as well with blood and waste, and large amounts of waste and blood were dumped into nearby rivers. When the state of the art facility was shut down, the community was left with environmental contamination and a bankrupt company that claimed $42 million in losses.
None of this includes the plummeting property values, loss of new business, increased crime rates and a general stench and pall that hung over the communities. All courtesy of the horse slaughter plant. This is what President Obama's USDA wants for American communities?
If horse slaughterhouses are allowed to re-open, they would again be subsidized by American taxpayers. Estimates are that the U.S. government would spend at least $3,000,000-5,000,000 annually to subsidize private horse slaughter facilities.
On top of that, the USDA could give foreign owners of U.S. horse slaughter facilities, such as Bouvry, the Canadian company that has explored the possibility of opening a horse slaughter plant near Stanwood, Washington, or the Belgian company, Chevideco, which claims it may contribute to the building of a horse slaughter house in Oregon or Missouri, a subsidized loan of $750,000 through the RUS World Utilities Services.
Mr. Vilsack, it is outrageous that the American taxpayer should support wealthy investors in a business that profits from animal cruelty, benefits only foreign interests and wrecks the U.S. communities where the facilities are located. This money would surely be much better spent on American interests. It would seem more appropriate for USDA to focus on the live horse industry worth $112.1 billion of gross domestic product.
Few Low Wage Jobs
The argument that significant jobs would be created is specious. Horse slaughter plants operating until 2007 never created more than 178 low wage jobs -and many of these were held by illegal aliens. When horse slaughter plants operated in the U.S., this meant workers and their families overran local resources like the hospitals and government services. It meant low income housing and a decline in the overall standard of living.
Slaughter Contributes to Numbers of Horses in Need
Slaughter proponents have widely claimed that slaughter is somehow an alternative for "unwanted" horses. Nothing could be further from the truth. Slaughter actually creates a salvage or secondary market that enables overbreeding and poor breeding practices. Slaughter and a poor economy have resulted in horses in need. Slaughter is driven by a demand for horsemeat in some foreign countries; it is not a "service" for unwanted horses and that is why, as one of your department's own studies confirms, most horses, 92.3%, are healthy when they are sent to slaughter. Kill buyers are interested in buying the healthiest horses for horsemeat that is sold as a delicacy in some foreign countries.
The rise in numbers of horses in need and drop in horse prices is a result of the worst recession in memory. In fact, if slaughter controlled numbers of horses in need, there would be none as slaughter is still available and horses are sent to slaughter in the same numbers as before the 2007 closings of the slaughterhouses that were located in the U.S. It is the availability of slaughter that actually increases the numbers of excess horses and other equines on the market. Banning slaughter would reduce the number of excess horses and other equines.
Also, slaughter accounts for only about 3 cents for every $100 of the equine industry. It makes no sense for anyone to suggest a limited salvage market could influence prices in the entire horse industry.
The Live Horse Industry
Again, it is the live horse industry that USDA should support. Most horses end up at slaughter because they are purchased by kill buyers. Many horses could have easily been purchased by someone else other options include adoption programs, placing them as pasture mates/babysitters to a younger horse, donating them for use in horse therapy, or placing them in a retirement home.
Humane Euthanasia is Available and Affordable
Also, about 900,000 horses are humanely euthanized in the U.S. each year. The infrastructure could easily absorb those sent to slaughter. The average cost of humane euthanasia including the farm call and either burial, rendering or placement in a landfill can be as little as $50 depending on the method used, and at most $400.
Humane Methods of Slaughter Act Unenforceable for Equines
The USDA is responsible for enforcement of the Humane Methods of Slaughter Act, 7 USC Sec. 1902(a)("HMSA"). USDA/FSIS failed miserably at this when horse slaughter was legal. That is because the slaughter of horses and other equines simply cannot be made humane: Dr. Lester Friedlander, DVM & former Chief USDA Inspector, told Congress in 2008 that the captive bolt used to slaughter horses is simply not effective. Horses and other equines, in particular, are very sensitive about anything coming towards their heads and cannot be restrained as required for effective stunning. Dr. Friedlander stated, "These animals regain consciousness 30 seconds after being struck, they are fully aware they are being vivisected." The Government Accountability Office ("GAO") in 2004, GAO-04-247; and dozens of veterinarians and other witnesses have confirmed that ineffective stunning is common and animals are conscious during slaughter. It is simply not possible for USDA/FSIS to make equine slaughter humane and it is a myth to pretend otherwise. Also, the GAO in 3 subsequent reports in 2008, GAO-08-686T; and 2010, GAO-10-203 and GAO-10-487T, has continued to find disparities and inconsistencies in FSIS enforcement of HMSA, an abysmal record of tolerating cruelty at slaughter facilities.
Having to provide sufficient FSIS inspectors even to try to enforce HMSA means even more cost to the taxpayer. For a job that cannot be done when it comes to equines.
Commercial Transportation of Equines to Slaughter Act Unenforceable
GAO has also confirmed that USDA/APHIS has not - and cannot - enforce transport regulations for equines sent to slaughter. 9 CFR Sections 88.1-88.6. Changing a few words here and there in the regulations will not make transport of equines to slaughter humane. USDA/APHIS allows the kill buyers and haulers to fill out and provide the documentation - which is routinely missing, incomplete or inaccurate - relied on for enforcement. It is impossible to enforce regulations when the information to determine violations is supplied solely by the kill buyers and haulers, the very people USDA/APHIS is supposed to be regulating.
A 2010 Office of Inspector General report confirmed APHIS lacks the resources and controls to enforce regulations for humane transport of equines to slaughter. Not only is the information relied on for enforcement supplied by the kill buyers and haulers, APHIS continues to approve of new shipments to slaughter by kill buyers or haulers that have outstanding unpaid fines for violations of humane regulations. The current regulations do not give APHIS the authority to refuse approval.
OIG also found there is no adequate system for tracking the information, such as it is, that is supplied by the kill buyers and haulers about the horses. It is very difficult to track what happens to the horses, meaning enforcement is virtually non-existent. Also, APHIS often does not receive any information from kill buyers or haulers. OIG noted in 2011 that for the past year or more, APHIS had not received the required paperwork, owner/shipper certificates, from kill buyers or haulers for any horses sent from Texas to Mexico.
On top of that, APHIS only has two agents to try to enforce these regulations. Your agency is hamstrung by its own regulations and cannot assure humane transport of equines to slaughter. There is every reason to think your agency could not even begin to assure humane transport of horses within the U.S. to newly opened slaughter facilities.
Food Safety
The Food and Drug Administration ("FDA") does not regulate equines as food animals. Americans don't eat horses and other equines. American horses are not raised, fed and medicated within the FDA guidelines established for food animals, making them unfit and unsafe for human consumption. Equines are given all manner of drugs, steroids, de-wormers and ointments throughout their lives. Equines are not tracked and typically may have several owners. There is no way to know when they are sold for slaughter what these animals have ingested over their lives.
The danger of American horsemeat to consumers was confirmed in a study, "Association of Phenylbutazone (Bute) Usage with Horses Bought for Slaughter" that was published in Food and Chemical Toxicology and authored by Dr. Ann Marini, Department of Neurology, Uniformed University of the Health Sciences; Nicolas Dodman, DVM, Tufts University, and Dr. Nicolas Blondeau, The Institute of Molecular and Cellular Pharmacology.
A kill buyer has no idea of the veterinary or drug history of a horse or other equine taken to slaughter, and many of the most dangerous drugs have no or a very long withdrawal period. A typical drug given routinely to equines like aspirin, phenylbutazone or Bute, is a carcinogen and can also cause aplastic anemia in humans. It has no withdrawal period. The FDA bans bute in all food producing animals because of this serious danger to human health. The FDA and USDA would prohibit Americans from consuming horses because of this danger. Yet, neither the FDA nor the USDA prohibits the export of American horses for slaughter for human consumption. It is a grave risk to public health to continue to allow the export of American horses for slaughter for human consumption in other countries.
The European Union has recognized this and has initiated steps to try to stop the import into the EU of meat from American horses that may be contaminated. Kill buyers have been found to falsify veterinary and drug reports to avoid the restrictions. There is no enforcement at the borders, meaning the US continues to dump contaminated and deadly horsemeat on Europe and other countries. A petition has been filed with the USDA to stop the slaughter of many U.S. horses for this reason.
Conclusion
Mr. Vilsack, in view of all of this, why would the Obama administration allow, let alone facilitate as a priority, the opening of horse slaughter facilities in the U.S.? I would urge the administration to reconsider this and instead work with horse owners, animal welfare organizations, the 80% of Americans who want horse slaughter banned, and end this grisly practice once and for all. Equines are in danger and equine welfare is threatened as long as slaughter remains available.
Horse Slaughter: The Truth Revealed | Habitat for Horses
Horse Slaughter: The Truth Revealed – History
The following is a series of copyrighted articles on the history, process, legislation and people playing a role in horse slaughter in the United States. This is a collaborative effort among a lot of people who have volunteered their time and effort to push back the curtain of propaganda and to bring the truth forward.
Jerry Finch, Habitat for Horses
Revealing the Truth
Most Americans are unaware that their horses are being slaughtered by the thousands so the meat can feed the palates of overseas diners in countries like Belgium, France, Italy and Japan.
Show horses, racehorses, foals born as a byproduct of the Premarin© industry (a female hormone replacement drug), wild horses, camp horses, carriage horses, rodeo horses, and family horses all fall prey to this detestable international industry.
Despite claims to the contrary, most of the slaughtered horses are in good-to-excellent health, yet they are inhumanely killed and their meat shipped overseas to satisfy the demands of foreigners for “American Horse Steaks.”
A scientific poll conducted in California showed that 70% of those polled support a ban on horse slaughter. Non-scientific polls show up to 90% in favor of banning horse slaughter. Amazingly, 60% of those polled were not aware of the horse slaughter industry. More recent nationwide polls indicate that at least 80% of the American public is opposed to horse slaughter.
Nearly 20 years ago, there were up to 14 horse slaughter plants operating in the United States. The number was gradually reduced due to diminishing foreign demand for horse meat starting in the early 1990s.
Today, due to a mixture of federal USDA inspection appropriation cuts (now rescinded) and state legislation and court rulings, there are no horse slaughter plants currently operating in the US.
However, last year alone (2011), 133,241 American horses were shipped across country borders to be slaughtered.
The same foreign companies that operated in the US also own plants in Mexico and Canada, where they can continue brutally killing horses with nearly total impunity; and with each passing month, the death toll keeps climbing.
Although working classes around the globe have been badly hit by an economic crisis, this recession has not been enough to quench the lust for horsemeat among the well-to-do in countries where it is considered a haute cuisine staple. Sadly, horsemeat consumption is on the rise because once again it is trendy. The flesh is surrounded by a halo of mythical properties and hype, promoted by horsemeat purveyors who are not mentioning the health risks to ignorant, unsuspecting individuals who eat it.
Habitat for Horses has played a part in several attempts to stop this needless destruction of our horses and will continue to do so until horse slaughter ends, both in and from the US. We invite you, as a member, to work within the legal system to put an end to slaughter. We also invite you to learn, in the following paragraphs, the background and true facts surrounding this unnecessary evil.
read much more in part 1 of the sordid and sickening history of horse slaughter in the US: The Origins of Horse Slaughter in the US
"From my earliest memories, I have loved horses with a longing beyond words." ~ Robert Vavra
