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CCFA's written submission to Bill 50 hearings (revision of the OSPCA act), July 21, 2008, Queen's Park, Toronto, Ontario

To: Chair, Standing Committee on Justice Policy

From: Stephanie Brown, Director

Canadian Coalition for Farm Animals

Date: July 21, 2008

Subject: Comments on Bill 50 – An Act to amend the Ontario Society for the Prevention of Cruelty to Animals Act


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.

Recommendation:

The Canadian Coalition for Farm Animals advocates that farm animals – the largest constituency of animals in Ontario – not be exempted from Bill 50.


The Canadian Coalition for Farm Animals appreciates the opportunity to provide comments on Bill 50 today. We support the addition of specified penalties in Bill 50.

As an organization focussed on the treatment and well-being of farmed animals, we are concerned with Section 11.2 (6) (b), which exempts farm animals from Sections 11.2 (1) and (2):

The vast majority of animals in Ontario are those raised for food – more than 220 million in 2007. To exclude the largest animal constituency from the legislation undermines the Act and is prejudicial to farmed animals.

Section 22. (1) (b) states:

(The Lieutenant Governor in Council may make regulations) prescribing activities that constitute activities carried on in accordance with reasonable and generally accepted practices of agricultural animal care, management or husbandry for the purpose of clause 11.2 (6)

 

What will the regulations prescribe as “reasonable and generally accepted practices of agricultural animal care, management or husbandry?”

Canada does not have legislation prescribing how animals should be treated on farms. Instead, governments have deferred much of their authority to voluntary Codes of Practice (“the codes”) which are developed by industry-dominated committees. Industry chooses practices acceptable to itself, including intensive confinement systems which ignore the animals’ behavioural and physiological needs. The codes legitimize intensive confinement practices and justify the status quo as good animal care when it is not.

Regulations to protect animals on the farm need to be more than voluntary codes since the codes lack legal status in Ontario, and there is no offence for not complying with even their minimal standards.

The beef, dairy and pig codes were written between 15 - 18 years ago. Though times and attitudes change, the codes remain static.

The codes do not ensure the Five Freedoms, adopted by the Farm Animal Welfare Council in the United Kingdom:

  1. Freedom from thirst, hunger and malnutrition (e.g,.broiler breeders have food withheld)
  2. Freedom from discomfort (e.g., sows in gestation crates cannot turn around for four months)
  3. Freedom from pain, injury and disease (e.g., debeaking, castration, de-horning, branding without anaesthetic)
  4. Freedom to express normal behaviour (e.g., hens in battery cages cannot nest, perch or spread a wing)
  5. Freedom from fear and distress (e.g., veal calves in isolation in crates; ruminants transported 52 hours without water, food or rest)


Animals in crates and cages are forced to eat, sleep, urinate and defecate in the same spot.

The one piece of legislation in Ontario whose sole purpose is to prevent and alleviate cruelty and suffering of animals, denies that very basic right to farmed animals.

In Ontario and Canada, industries that exploit farm animals recognize the need to change current practices. Governments in the United States and Europe are beginning to legislate change in the treatment of farmed animals. A recent prestigious agricultural report in the United States recommends substantial changes to common animal production practices.

Recent examples of corporate, voter, and government initiatives to end intensive confinement systems – considered acceptable under Canada’s codes – include:


The issue of “reasonable and generally accepted standards” is not static, as the codes are. There is growing recognition of need for more humane treatment of animals raised for food -- away from intensive confinement, away from use of antibiotics and growth hormones, and recognition that farm animals should be protected from pain and suffering.

Farm animals in Ontario need and deserve the protection of Bill 50. As other jurisdictions vote to end cruel confinement systems for farmed animals, Bill 50 proposes an exemption of these animals.

Excluding farm animals from Bill 50 forfeits the opportunity to protect the largest category of animals in the province – more than 220 million in 2007.


Recommendation:

The Canadian Coalition for Farm Animals advocates that farm animals – the largest constituency of animals in Ontario – not be exempted from Bill 50.