Transportation of Animals Program
Compromised Animals Policy
Table of Contents
- Compromised Animal
- Non-Ambulatory Animal
- Applicable Legislation
- Handling of Non-Ambulatory Livestock on Arrival at Federally Inspected Slaughter Plants
- Options for Dealing With Non-Ambulatory Animals at the Plant
- Ocular Squamous Cell Carcinoma (Cancer Eye)
- Hobbled Cattle
- Stressed Hogs
- Identifying a "Stressed Hog" That Is Unfit to Be Unloaded
- Guide to Assess Fitness for Transport
- Do Not Transport - Unfit for Transport
- Transport With Special Provisions - Compromised
- Special Provisions
- What Is the Meaning of "Nearest Suitable Place"?
- Lameness Descriptions Rendering Animals Compromised or Unfit for Transport
- Transport With Special Provisions - Compromised
- Do Not Load - Unfit for Transport
Compromised Animal: An animal with reduced capacity to withstand the stress of transportation, due to injury, fatigue, infirmity, poor health, distress, very young or old age, impending birth, or any other cause. Some compromised animals can be transported under certain conditions without being exposed to unjustified and unreasonable suffering. Others, such as non-ambulatory animals, animals with a body condition score indicating emaciation or weakness, or animals with severe lameness, would endure unjustified and unreasonable suffering during the transportation process and must not be transported except for veterinary treatment or diagnosis. This is true of any condition associated with pain that will be aggravated by transport.
The examples listed in the Guide to Assessing Fitness for Transport below are intended to provide further guidance. They do not comprise an exhaustive list of conditions that may be encountered. Inspectors who conduct inspections under the Transportation of Animals Program must know all of Part XII of the Health of Animals Regulations.
Loading and unloading a non-ambulatory animal with the intent of providing veterinary diagnosis or treatment does not expose the animal to unjustified and unreasonable suffering. In fact, veterinary diagnosis or treatment has an associated animal welfare benefit for either the transported animal or the herd of origin.
In this regard, the suffering that the animal will endure is not undue. The Regulations refer to "undue suffering," recognizing that some degree of suffering by all animals is inevitable. The qualifier "undue" prevents the word "suffering" from being taken literally. Therefore, the loading of a non-ambulatory animal can be carried out in accordance with the Health of Animals Regulations to provide veterinary diagnosis or treatment.
Non-Ambulatory Animal: As defined in section 2 of the Health of Animals Regulations, an animal which is "livestock," or an animal of the cervid, camelid, or ratite species, that is unable to stand without assistance or to move without being dragged or carried, regardless of size or age. Non-ambulatory animals are also called downers. This includes, but is not limited to, acutely split animals (i.e. having a ruptured pre-pubic tendon) and animals that require hobbles to assist in the healing of injuries or to prevent further injury.
Under the authority of the Meat Inspection Act, the Meat Inspection Regulations, 1990 prohibit the handling of a food animal in a manner that subjects the animal to avoidable distress or avoidable pain (see subsections 62 , 67). The Meat Hygiene Manual of Procedures provides further guidance. Subsection 67(6) of the Meat Inspection Regulations, 1990 requires that, if an operator or an inspector who is not an official veterinarian suspects, in the course of the ante-mortem examination or the ante-mortem inspection of a food animal, that the animal shows a deviation from normal behaviour or appearance, the animal shall be held and referred to an official veterinarian for a detailed inspection and instructions regarding its disposition.
Subsection 138(2) of the Health of Animals Regulations prohibits the transportation of an animal that, by reason of infirmity, illness, injury, fatigue, or any other cause, cannot be transported without undue suffering during the expected journey. Non-ambulatory livestock transportation for purposes other than veterinary treatment or diagnosis, or in accordance with subsection 138(4) of the Health of Animals Regulations, causes undue suffering and is therefore in contravention of subsection 138(2).
As required by subsection 138(4) of the Health of Animals Regulations, an animal that becomes non-ambulatory or otherwise unfit for transport while en route must be taken to the nearest suitable place where it can receive proper care and attention.
The Health of Animals Regulations apply to all animals transported to any destination, including all slaughter plants. This policy is intended to provide direction and clarification to federal inspectors.
Trucks arriving at a slaughter establishment with an unusually high number of injured or dead animals should be given priority for slaughter. The inspection, conducted by the Canadian Food Inspection Agency (CFIA) staff stationed at the plant or the district office, should focus on collecting the facts that contributed to the high rate of injury or death. As appropriate, refer to the Enforcement and Compliance Policy for further steps.
At the time of arrival at a federally registered processing plant, any non-ambulatory animal will be held in the truck. An inspector or company staff should immediately inform the responsible CFIA veterinarian of the animal's arrival. Barn personnel should be directed not to open the animal compartment until the veterinarian arrives, unless it becomes necessary to do so for animal welfare purposes, such as unloading ambulatory animals or attending to a non-ambulatory animal. This permits the veterinarian to observe the conditions under which the non-ambulatory animal was transported. It also prevents those animals that want to crawl off from doing so, or from being encouraged to do so.
After completing the animal's physical examination, the CFIA veterinarian completes Form CFIA/ACIA 1438 – Ante-Mortem Veterinary Inspection Report, which should also note relevant factors, such as the loading density of the animals while on the vehicle. The veterinarian monitors the unloading of ambulatory animals around the non-ambulatory individual and the extent to which employees are allowed to assist an animal to rise. An effort should be made to ascertain the reason the animal became non-ambulatory.
The CFIA veterinarian should also document any observations that indicate probable non-compliance with the Health of Animals Regulations, such as inadequate bedding, overcrowding, or the existence of fresh wounds. Photographs should be taken of the animal on the vehicle if non-compliance is suspected. This inspection constitutes a humane transportation inspection and should be recorded and reported as such.
It is strongly advised that all personnel at the plant who are involved in the handling of downer or crippled animals receive proper training in the handling of infirm or injured animals. It is necessary that CFIA inspection personnel have the CFIA's Humane Transportation Training, Level 1. For plant employees, a suitable industry training course provides the necessary background.
Options for Dealing With Non-Ambulatory Animals at the Plant
Failure to meet any of the conditions outlined below would subject animals to injury or undue suffering, which is not in compliance with the Health of Animals Regulations, Part XII, or with Part III of the Meat Inspection Regulations, 1990.
Following ante-mortem inspection of the animal by the CFIA veterinarian, it will be at the veterinarian's discretion to decide on the disposition of the animal, based on humane considerations and on the presence of adequate facilities and competent personnel to protect the animal from additional suffering.
Other animals may be unloaded from a compartment that contains a non-ambulatory animal. Animals are not to be unloaded from other compartments through a compartment that contains a downer animal, unless no alternative exists and the animal is adequately protected under the supervision of a CFIA inspector.
Option 1 - Euthanize on Truck
The animal may be humanely killed on the truck provided that either of the following is true:
- a CFIA veterinary ante-mortem inspection is performed; or
- neither the carcass nor any part thereof will enter the human food chain.
The animal must be humanely killed on the truck unless the conditions outlined for Option 2, below, are in place. The CFIA veterinarian must be notified by the following day. This option is available even in the absence of the CFIA, provided that the carcass is taken to the inedible products area of the establishment.
Option 2 - Stun on Truck
Option 2 depends on the availability of CFIA inspection. It is acceptable, following CFIA veterinary ante-mortem inspection, to carry out either of the following two options:
Stun and bleed the animal out on the truck in a sanitary manner
The following exceptional situations can be best resolved through this option:
- bleeding a small number of injured livestock on the truck at a destination plant, following a livestock vehicle accident; and
- dealing with a non-ambulatory animal in a poorly accessible part of the vehicle, where an attempt to move the stunned animal would likely result in excessive delay progressing from stunning to bleeding at the sticking area of the plant.
- Stun the animal on the truck and unload the unconscious live animal to the bleeding area
The stunning method must be irreversible. The recommended time interval between stunning and bleeding is less than one minute. This may be impracticable in the given situation, but all preparations to move the animal to the bleeding area as swiftly as possible must have been made prior to stunning. The animal and its parts must be identified until a carcass disposition is made.
For all options, if indicated by the case definition for suspect or surveillance cases, specimens are to be collected for rabies and bovine spongiform encephalopathy (BSE) in accordance with the Protocol for the Collection, Fixation and Submission of BSE Specimens at Abattoirs Under Inspection by the CFIA. In the event of a suspect case of BSE or rabies, Option 1 does not apply in the absence of a CFIA veterinarian.
From the time of arrival at the plant, the CFIA veterinarian and the inspector are both responsible for collecting information and evidence in the event of subsequent enforcement action. If appropriate, the CFIA will conduct a follow-up investigation to decide whether enforcement action is necessary, in accordance with the CFIA's Enforcement and Compliance Policy.
Unloading a live, non-stunned non-ambulatory animal from a conveyance, or causing such an animal to be unloaded, is a contravention of the Health of Animals Regulations.
Unloading a live, non-stunned non-ambulatory animal in the absence of CFIA inspection personnel (e.g. outside of normal working hours) is unacceptable. Appropriate enforcement action must be taken against whoever unloaded such an animal or caused it to be unloaded.
Squamous cell carcinoma (SCC) is a serious animal welfare concern, as it is associated with extreme pain. Lesions are characterized by how extensive they are (from minimal tissue involvement through to extensive facial and/or skull involvement). In addition, they can be characterized by their condition. The neoplastic tissue can be infected, necrotic, parasitized (maggot infested), friable, and/or bleeding.
As SCC is a painful condition, animals with any indication of SCC should be treated or culled to avoid progression of the disease beyond the initial stages.
Education of producers, buyers, and transporters is expected to lead to better decisions with respect to early identification and treatment, euthanasia or transport to slaughter, as appropriate. It is unethical to send such animals to slaughter as a means of disposal.
Animals in which a SCC lesion affects the eye and wherein the eye is still intact and has vision (known as stage 1 SCC) should be treated promptly or should proceed directly to slaughter. These animals can be transported under normal transport conditions.
Animals in which the SCC lesion has progressed beyond this point – for example, the lesion has obliterated the eye, the animal can see only from its unaffected eye, the lesion is similar to an open wound, the lesion is highly vascular/friable/necrotic, it has extended outside the orbit region or it involves other osseous structures (known as stage 2 and 3 SCC) – should be promptly treated or euthanized on-farm. Transportation is not recommended.
Those who insist on transporting these animals, despite advice to the contrary, must, at a minimum, transport with special provisions such as loading in the rear compartment, segregating or placing with similarly compromised or companion animals, providing extra room, and taking the animals directly to nearest suitable place where they can receive care, or be humanely shaughtered or euthanized.
If the condition has progressed to the point that other body systems are affected, these animals are unfit for transport.
Incidents of animals with severe SCC lesions arriving at slaughter establishments should be reported to the appropriate animal welfare authorities. Allowing the condition to progress to advanced stages without appropriate veterinary care qualifies as neglect.
Please also see the Meat Hygiene Manual of Procedures for more information.
Hobbles are used to prevent cows from kicking during milking and as a means to assist in the healing and recovery of injured animals (e.g. with a ruptured pre-pubic tendon or "split") and to prevent further injury. When hobbles are used for handler safety reasons, they are left on the animal for fear of the handler being injured when an attempt is made at removal. Hobbling can be a beneficial adjunct to therapy for injured cattle.
The Health of Animals Regulations define a non-ambulatory animal as an animal of the bovine, caprine, cervid, camelid, equine, ovine, porcine, or ratite species that is unable to stand without assistance or to move without being dragged or carried. The Regulations prohibit the loading of a non-ambulatory animal for purposes other than receipt of veterinary treatment or diagnosis. This includes, but is not restricted to, acutely split animals. The Regulations also state "no person shall load or cause to be loaded on any railway car, motor vehicle, aircraft or vessel and no one shall transport or cause to be transported an animal (a) that by reason of infirmity, illness, injury, fatigue or any other cause cannot be transported without undue suffering during the expected journey."
Injured cattle that require hobbles must not be transported, as undue pain and suffering of hobbled cattle are likely to occur during loading, transportation, and unloading.
In cases where hobbles have been placed on an animal for handler safety reasons, they should ideally be removed before the animal is loaded for transport. The presence of hobbles significantly interferes with an animal's ability to properly balance itself during transport. At a minimum, transport of such cattle requires special provisions that include, but are not limited to, transporting the animal to the nearest suitable place, which includes a veterinary hospital or a nearby slaughter facility. Auctions are not considered suitable places for any compromised animal. Other special provisions include, but are not limited to, extra bedding, loading in the rear compartment of a low trailer, separation from other animals, placing in a pen with a familiar companion animal, or other measures as appropriate. In this case, there should be an individual assessment that considers all relevant factors associated with the shipment to determine whether the animal is fit for transport, and if so, whether the transport conditions are suitable for the animal.
That an animal is hobbled does not always necessarily render it unfit for transport, provided that it is not acutely split and can stand without assistance and move without being dragged or carried. However, a hobbled animal is always compromised, and transportation must include special provisions as above.
The transportation of stressed hogs poses serious animal welfare concerns. As a result of various factors, such as weather, transportation, temperature, and rough handling, hogs can easily become stressed. Stressed hogs may exhibit any combination of the following symptoms:
- difficulty breathing or open-mouth breathing, panting, or gasping (dyspnea, tachypnea);
- blotchy skin (irregular skin blanching and erythema);
- high body temperature (hyperthermia) > 103 degrees Fahrenheit;
- reluctance to move (with no other visible abnormalities);
- inability to rise;
- sudden death (with no other visible abnormalities, other than open-mouth breathing, dyspnea, tachypnea); and/or
"Reluctance to move" can be described as the behaviour of a hog that does not keep up with its herd mates, that will not move when asked or moves very slowly and with great difficulty, and that is very stiff. These stressed hogs will often go down if prodded or forced to move.
Identifying a "Stressed Hog" That Is Unfit to Be Unloaded
A hog that exhibits all of the following signs is unfit (whether it is ambulatory or not) to be unloaded without first being humanely stunned or killed:
- patchy skin discolouration; and
- laboured breathing.
Subsection 138(2) of the Health of Animals Regulations prohibits the transportation and the loading and unloading of non-ambulatory animals. No person must load or cause to be loaded or transport or cause to be transported an animal that is non-ambulatory, except for the purposes of veterinary treatment or diagnosis. Unloading a non-ambulatory animal before it has been stunned, or causing such an animal to be unloaded, is unacceptable and is a contravention of the Health of Animals Regulations.
Subsection 139(2) of the Health of Animals Regulations prohibits the transportation and the loading and unloading of animals in a way that is likely to cause injury or undue suffering.
Unloading of stressed ambulatory hogs can result in a worsened condition and even death. Stressed hogs, either ambulatory or non-ambulatory, that are trembling, have patchy skin discolouration and have laboured breathing must not be unloaded in a conscious state.
The use of the hog sled to unload unstunned, non-ambulatory animals (including non-ambulatory stressed hogs) is prohibited. If a stressed ambulatory or non-ambulatory hog arrives at a slaughter plant or assembly yard, the animal must be protected from being trampled by other animals in the shipment. This may be achieved by halting the unloading process or by rerouting the other animals in the shipment.
A stressed hog (ambulatory or non-ambulatory) that is trembling and has patchy skin discolouration and laboured breathing is unlikely to recover. Options for dealing with such an animal include the following:
- Euthanize the animal immediately where it is found and hold for veterinary inspection prior to disposal of the carcass as inedible.
- If a CFIA veterinarian or inspector is immediately available and performs CFIA antemortem inspection and authorization for slaughter, stun the animal where it is found and have it moved immediately to be bled and hung for evisceration.
Some stressed hogs will recover if given sufficient time. Others will continue to deteriorate, eventually dying from cardiac arrest. If recovery of the hog is believed to be possible (the animal is not trembling, does not have patchy skin discolouration and does not have laboured breathing), provisions must be taken to ensure the animal is protected from other animals, and the waiting period cannot be so unreasonably long as to cause undue stress (in contravention of the Health of Animals Regulations and the Meat Inspection Regulations, 1990).
It is important to ensure that stressed hogs are handled humanely at all times.
Do Not Transport - Unfit for Transport
Do not transport an animal of which any of the following is true:
- the animal is unable to stand without assistance or to move without being dragged or carried;*
- the animal, after splitting, cannot walk, or suffers severe pain when walking, or requires hobbles to stand or to prevent further injury (i.e. non-ambulatory animal);*
- the animal cannot rise without assistance and is reluctant to walk, and exhibits halted movement;*
- the animal cannot be transported without undue suffering because of lameness (Health of Animals Regulations 138[a]);*
- it has a fractured limb;
- it has a fracture to the pelvis;
- it has a rupture of the pre-pubic tendon (splitting);
- it has other fractures that considerably hamper mobility or are likely to cause severe pain when the animal is manipulated for loading or when it is being transported;
- its body condition score indicates emaciation and weakness;
- it is suffering from dehydration;
- it is suffering from exhaustion;
- it is a stressed hog;
- it is in shock or dying;
- it has a suspected or confirmed nervous system disorder;
- it has a fever;
- it has uterine prolapse; and/or
- it has a hernia that meets one or more of the following criteria:
- impedes movement (includes conditions in which the hind legs of the animal touches the hernia when the animal is walking),
- is painful on palpation,
- touches the ground when the animal is standing in its natural position, and/or
- includes an open skin wound, ulceration, or obvious infection.
The above restrictions do not apply to animals that are destined for veterinary treatment or diagnosis. (It is illegal to load or unload a non-ambulatory animal in Canada, unless the animal is being transported with special provisions for veterinary treatment or diagnosis. This change took effect in June 2005.)
Transport With Special Provisions - Compromised
Transport an animal with special provisions if any of the following is true:
- it has an acute penis injuries;
- it has acute frostbite;
- it is bloated (if not weak or already down);
- it has laboured breathing;
- it has blindness in both eyes;
- it has an open wound (depending on the severity of the wound, the animal may be unfit);
- it is an amputee;
- it has not fully healed after an operation, such as dehorning or castration;
- it has given birth in the preceding 48 hours;
- it has rectal or vaginal prolapse;
- it is lame;*
- it is hobbled to prevent kicking;
- it is in heavy lactation (animals in heavy lactation requiring milking every 12 hours, or they will become unfit for transport); or
- it has squamous cell carcinoma, Stage 2 or 3.
Transport only to the nearest suitable place (See below in section, What Is the Meaning of "Nearest Suitable Place"?). A veterinarian may be required to assess these animals prior to loading. (It is illegal to load or unload a non-ambulatory animal in Canada, unless the animal is being transported with special provisions for veterinary treatment or diagnosis. This change took effect in June 2005.)
The following three special provisions must be met when transporting a compromised animal:
- A compromised animal must be transported locally and directly to the nearest suitable place where it can receive care and attention, or be humanely shaughtered or euthanized.
- A compromised animal must be the last animal loaded and the first animal unloaded.
- A compromised animal must be segregated from all other animals, or it may be penned with one familiar companion animal.
Note: To prevent undue suffering, other special provisions, such as additional bedding, may be required, depending on the condition of the compromised animal.
Always ask a veterinarian if you are unsure about the appropriate special provisions, when moving a compromised animal.
What Is the Meaning of "Nearest Suitable Place"?
Compromised animals that are fit for transport should not go through auction markets or assembly yards. If compromised animals are to be sent to slaughter, they must not travel long distances to the slaughter facility, even if the only slaughter facility is far away. If local slaughter facilities are unavailable, animals should either be treated or be humanely euthanized.
If an animal becomes compromised during the journey, consider the nearest suitable place (that is, a nearby veterinary hospital, farm, auction market or assembly yard, slaughter plant) where the animal can receive care or be euthanized.
Use these descriptions to determine whether an animal requires special provisions during transportation or whether it is unfit for transport.
Transport with Special Provisions - Compromised
Transport with special provisions if the following is true:
- the animal has imperfect locomotion, a slight limp; the lame leg may not be immediately identifiable.
Even a slight lameness is a cindition that can deteriorate very quickly, especially when the animal must negotiate ramps during the loading and unloading process, justifying the need to avoid auction markets and assembly yards.
This animal is also at risk of becoming non-ambulatory during transport and can only be transported with special provisions to the nearest suitable place where it can be humanely slaughtered (local slaughter), or care for.
Do Not Load - Unfit for Transport
An animal is unfit for transport (except for veterinary treatment or diagnosis, using specialized equipment and in accordance with provincial regulations on the advice of a veterinarian) if any of the following is true.
- It cannot rise without assistance and is reluctant to walk, and exhibits halted movement. This animal is non-ambulatory. Treatment, euthanasia, or emergency on-farm slaughter is necessary.
- It is unable to rise or to remain standing without assistance. This animal is non-ambulatory. Treatment, euthanasia, or emergency on-farm slaughter is necessary.
- It cannot be transported without undue suffering because of lameness (Health of Animal Regulations 138[a]), even if the animal can rise or remain standing without assistance, because the animal demonstrates one of the following:
- obvious arched back and head bob;
- obvious limp with uneven weight bearing, and the inability to bear any weight on one leg is immediately identified (unable to use a foot to walk);*
*In rare instances, where an animal has a deformity or has an amputated limb that has fully healed, and the animal is not suffering due to the lameness, it can be transported to local slaughter or care with special provisions, as the deformity or healed amputated limb would render the animal compromised.
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