CCFA testimony on Ontario Bill 204 -- Animal Health Act, 2009
November 25, 2009

Following is the text of a deputation by Stephanie Brown, Director, Canadian
Coalition for Farm Animals, to the Chair and Members Standing Committee
on the Legislative Assembly, on November 25, 2009:

Subject:   Comments on Bill 204 – Animal Health Act, 2009

The Canadian Coalition for Farm Animals is dedicated to promoting
the welfare of animals raised for food in Canada, through public education,
legislative change and consumer choice.       


Amend The Animal Health Act to provide OMAFRA an enabling framework to:

The Canadian Coalition for Farm Animals appreciates the opportunity to speak today, and is on the record in support of the intent of the act:  safe food, and human and animal health in Ontario.

One of the purposes of Bill 204 is Section 1 (c) – the regulation of activities related to animals that may affect animal health or human health, or both.

Animal health is tied to animal welfare

As the government’s June 18, 2009, discussion paper for this legislation noted, “The handling of farm animals and the condition of their environment can have a direct impact on the health of the animals.”    (

Poor welfare results in stress, making animals more prone to infectious disease.  It is no coincidence so many factory-farmed animals in Ontario are fed low-dose antibiotics as a matter of course.  The drugs keep the animals alive.

It was anticipated Bill 204 would address the tie between animal health and animal welfare.  But no, animal welfare is not a priority in the act.  It is ignored completely. 

The animal health - animal welfare link is recognized in numerous jurisdictions. 

Chief veterinary officers from around the world – members of the World Animal Health Organization (OIE) – recognize the connection.  The veterinarians have incorporated animal welfare as a priority in the strategic plan of the international organization, adopting animal welfare standards as part of their program. (

The European Union recognizes animal welfare as part of animal health.  Their strategy is motivated by both public health concerns and animal welfare concerns.  Internationally, there is a move toward legislated on-farm welfare standards.

The European Union, some European nations, and some state governments in the U.S. are legislating the treatment of animals on farms, and phasing out intensive confinement systems common on Ontario farms.  At the same time, international food retailers are establishing welfare standards to ensure consumer confidence.

Animal industry groups in Ontario do not want the Animal Health Act to include on-farm standards because, they say, the voluntary codes of practice and the OSPCA Act suffice.  In fact, the OSPCA Act covers only basics like provision of food, water and shelter.  The act exempts on-farm practices, including intensive confinement housing and animal handling methods.

To be clear:   industry is not honest when it claims the OSPCA Act covers on-farm practices.  It does not.

There is no legislation in Ontario to ensure animal welfare on the farm. 

The voluntary codes of practice do not suffice either.  The province of Ontario is responsible for on-farm practices, yet federal and provincial governments have deferred much of their authority to the codes, which are developed by industry-dominated committees. The codes are not audited, and there is no offence for not complying with their minimal standards.

The beef and pig codes were written 18 and 16 years ago, respectively.  Though attitudes change and new scientific information becomes available, the codes remain static.  The codes legitimize outdated practices, justifying the status quo as good animal care when it is not.

Bill 204 recognizes a provincial traceability system [Section 33] as necessary to facilitate trade.  Should an animal health crisis arise and a product cannot be identified and traced, it would be a trade deterrent.  The same must be said about animal welfare, which is destined to become a trade issue with nations with high animal welfare standards.

The province should exercise its authority to monitor animal health and welfare on farms.

Regulations should be more than voluntary codes which lack legal status in the province.  Ontario should show solid leadership in the treatment of farmed animals by regulating on-farm standards in the Animal Health Act.

The Livestock Community Sales Act is repealed [Section 12, (1), (i) and (ii)] with introduction of the Animal Health Act.  The new act should regulate conditions at assembly yards and sales facilities, including provision of euthanasia when animals are sick or injured.

In addition, the act should be amended to provide an enabling framework to provide for non-disease emergencies such as barn fires, border closures or bankruptcies of major farms.

Provision of such regulations would further the goals of the Health of Animals Act for food safety, and human and animal health.


Amend The Animal Health Act to provide OMAFRA an enabling framework to:

Thank you.