Guidelines for animal welfare Preventive Control Plans and self-audits for the slaughter of food animals

Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements are being phased in over the following 12 to 30 months. For more information, refer to the SFCR timelines.

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Introduction

Complete measures to mitigate animal welfare risks during slaughter activities include the preventive measures of a well written animal welfare Preventive Control Plan (PCP). These written preventive measures always will include the monitoring procedures, corrective action procedures to control recurring deviations, verification procedures, objective performance criteria and the procedures for a self-audit (unless a third- party audit is done instead) to check that the PCP is implemented and effective as intended and acceptable animal welfare standards are achieved.

The approach to developing a PCP is analogous to developing a HACCP intended to prevent and control food safety risks. Likewise, the outcome of an effective animal welfare PCP is to prevent and control animal welfare risks to the animals during any of the slaughter activities in the establishment, both within and outside of the facility, taking into account identified gaps and problem areas that may be specific or unique to that establishment.

The outcome of an audit program is to give a snapshot how well the animal welfare risks in the establishment are controlled by the licence holder's PCP in the context of internationally accepted standards and best practices. This may be a self-audit (first party audit) program or a third party audit by a qualified animal welfare auditor with a recognized certification in animal welfare auditing.

Definitions

For the purposes of this document, the following definitions apply:

Animal welfare Preventive Control Plan

An animal welfare Preventive Control Plan (PCP) is a written systemic approach to humane handling and slaughter which is documented, auditable and detailing preventive measures relating to animal welfare.

Animal welfare risks

In the case of animal welfare at the slaughter establishment, the identification of risks will be those that have the potential to impact the animal's welfare, such as the conditions that it is housed in, how it was transported from the farm to the slaughter establishment and unloaded there or the way in which it is handled and killed.

Corrective action procedures

Corrective action procedures in the context of the animal welfare PCP are procedures that will address any deviations from the expected outcome of humane handling and slaughter of food animals. In general, these are designed to prevent recurrence of a deviation; although immediate corrective action procedures may be required to mitigate the suffering of an individual food animal.

Measures

Measures in the context of the animal welfare PCP are preventive measure procedures or protocols that control the animal welfare risks in order to achieve an outcome of humane handling and slaughter of food animals

Monitoring Procedures

In the context of an animal welfare PCP, a monitoring procedure is an act of conducting a planned sequence of observations, tests or measurements to assess whether performance criteria are met or a preventive measure is effective.

Verification Procedures

In the context of the animal welfare PCP, verification procedures are quality control evaluations of the monitoring procedures, to determine whether they have been effectively implemented as intended and provide the expected outcomes of humane handling and slaughter.

Key elements of the animal welfare Preventive Control Plan

The animal welfare PCP includes the following elements at a minimum:

  • specific methods and procedures that will be implemented to identify the risks in the establishment, both within and outside of the facility, for any slaughter activity and achieve the outcome standards expected by management
  • names or position of the persons who are responsible for each slaughter activity
  • description of animal welfare risks
  • employee training, competence and supervision required to perform the slaughter activity
  • name or position of the persons who are responsible for monitoring, verification and self-audit, including evidence of their training and competencies
  • the employees who conduct the actual slaughter activity, the monitors and the verifiers are all different people in order to provide objective and meaningful results
  • procedures to record training and evidence of competency for a given slaughter activity, monitoring procedures, verification procedures and self-audit program
  • procedures to record non-compliances and corrective action procedures that will /have been taken as required immediately and those to prevent recurrences of the non-compliance
  • the frequency and method of checking slaughter areas both facility interior and exterior to the facility
  • checking equipment, including its maintenance
  • animal welfare contingency plans [Standard Operating Procedures (SOP)] that address predictable and unpredictable but possible events and emergencies that may have arisen during staging of the load, loading, transportation prior to reception of the animals, the time spent waiting to unload, unloading, handling while in lairage, preparation for and/or restraint for stunning, stunning, shackling, and bleeding.
    • For animals that are still in cages but within the establishment, this includes the time spent waiting while the trailers are parked but the crates/cages have not been yet unloaded, plus the time spent in the crates and cages after unloading from the trailer.
  • information and documents for any equipment used during slaughter activities that may carry an animal welfare risk, for example:
    • Initial validation of captive bolt equipment efficacy for all species, including nonconventional species of animals, such as farmed game, may be conducted on cadavers or commercially available test models, since testing new equipment on the live animal carries an increased animal welfare risk:
      • When testing on cadavers, split the head to verify if the brainstem is damaged sufficiently as a test to validate that the captive bolt length used and the angle of the shot are sufficient to reach the target to cause effective stunning.

The written preventive measures of the animal welfare PCP

The preventive measures include at a minimum:

  • The slaughter activity:
    • this can be any job such as animal receiving, handling, stunning, bleeding, maintaining and cleaning the equipment and facilities
    • the "doer" is the employee doing the job
    • include the What, Who and How as part of the slaughter activity description
    • for the slaughter activities of stunning, cutting and bleeding, the doer must also have the training and competency to check for monitoring indicators for consciousness and unconsciousness for each animal or groups of animals (for example, poultry) to avoid any suffering of the individual animal
  • Monitoring:
    • the monitor is not the doer
    • the monitor must know very well the slaughter activity done by the "doer"
    • the monitor checks and evaluates what is happening, what is done, the follow-up on findings, correcting deviations and implementing preventive measures
    • monitoring is carried out at specified frequencies to ensure that the doer is doing the job competently
    • the monitor records slaughter activities and findings in a monitoring record
  • Verification:
    • the verifier is not the monitor, nor the doer
    • verification is the analysis of all the records at specified frequencies and to ensure that monitoring is done, follow-ups are done, immediate corrective action procedures and preventive corrective action procedures are effective
    • the verifier checks what follow-ups are done by the monitor to make sure things are back to normal
  • Animal Welfare Audit:
    • when a self-audit is conducted by the licence holder, the procedures should incorporate recognized best practices and programs for auditing to give an objective and meaningful evaluation of the establishment animal welfare standards
    • the auditing is carried out at specified frequencies
    • if done by a third party auditor, the frequencies and training/certification are also specified

Monitoring animal welfare risks

Procedures for monitoring important animal welfare risks such as stunning can be based on monitoring for the undesired outcome. This is analogous to the detection for the presence or absence of diseases in animal health science research and can be extrapolated to slaughter activities that carry high animal welfare risks.

For example, in the case of stunning, the monitoring of the risk of consciousness or return to consciousness would be the undesired outcome.

This approach is outlined in the European Food Safety Authority (EFSA Journal, 2013Footnote 1) guidelines for monitoring stunning for the slaughter of bovinesFootnote 2, sheep and goatsFootnote 3, pigsFootnote 4 and poultryFootnote 5 in slaughter establishments. The recommendation is to use a combination of specific indicators to monitor the undesired outcome of consciousness (sensibility) for different stunning methods. These indicator signs are used as part of a 'toolbox' method that recommends practical and useful signs for monitoring during the most common stunning methods for food animals.

Monitoring and verification procedures may also be conducted using recognized audit tools and performance criteria.Footnote 7,Footnote 8,Footnote 9

Corrective actions to prevent recurring deviations

The licence holder will develop and implement effective corrective action procedures if non-compliances occur with the requirements of their written PCP or regulations governing humane treatment and slaughter of food animals. Corrective action procedures include preventative corrective actions for recurring animal welfare non-compliances and for isolated deviations.

Preventive corrective actions may be new preventive measures in the existing PCP or the installation of new equipment or the redesign of the facility through new construction/renovations to prevent recurring animal welfare deviations, for example:

  • if a deviation were found to be pre-stun shocks of birds at the electrical waterbath entrance, then the preventive corrective action procedure might be the construction of an entrance ramp to the waterbath to allow the birds to swing into the bath with their heads first rather than their wings first to avoid future pre-stun shocks
  • if the stunning failure rate is noticed to increase towards the end of the production shift for captive bolt stunning of bovines, then a preventive corrective action procedure may be to rotate this employee to another job half-way through the production shift to avoid this employee from becoming physically or mentally fatigued from stunning the bovines

Verification of the PCP

The verification procedures are part of an internal quality control program to evaluate and check that the animal welfare PCP is implemented as written and works well as intended, for example:

  • the verification procedures may be to conduct the same sampling numbers or more numbers as are being done for the monitoring procedures to verify that there are no gaps in the monitoring records or actual procedures

Self-audits

When conducted internally, the program should be conducted at the establishment using performance criteria which are animal based measuresFootnote 8, Footnote 11, in addition to resource or management based measures.

Examples of animal based measures include:

  • behaviour of the individual animal during receiving and unloading activities, such as excess vocalizing from pain or distress because of excessive electric prod use
  • behaviour of the animals during restraining such as excessive vocalizing from pain or distress during incorrect restraining techniques
  • falling or slipping for individual animals when being moved through the facility because of slippery flooring
  • stunning efficacy of individual animals with the desired outcome of immediate unconsciousness for each animal
  • slaughter without stunning of individual animals with the desired outcome after the ritual cut of rapid collapse, rolling of the eye to indicate rapid onset of unconsciousness (fainting behaviour)

Examples of resource or management based measuresFootnote 10, Footnote 11 include:

  • facility ramps, driveways, holding pens, gates and restraining devices are in good repair and free of protruding or sharp objects, gaps or any other damage that can potentially hurt or injury the animals
  • water is available and accessible for livestock in holding pens as required
  • restraining and stunning equipment, for example:
    • stunning equipment is designed for food animal species slaughtered
    • carbon dioxide delivery equipment are in good repair
    • restraining equipment is capable of comfortably accommodating the food animal being restrained
    • the right electrical stunner is selected that will produce immediate unconsciousness/ insensibility for the food animal being slaughtered
  • Employees are assigned specific slaughter activities and work shifts, for example:
    • employees are rotated to avoid fatigue, especially those conducting slaughter activities that carry significant animal welfare risks, such as handling, stunning, bleeding and post-cut management

Individuals performing self-audits must be knowledgeable and competent in the principles of animal welfare in order to carry out an audit that gives meaningful results:

  • animal welfare audits results should be carried out on a representative sample of animals that is statistically meaningfulFootnote 6, Footnote 8, Footnote 9
  • the frequency of self-audits in plants should take into account:
    • the outcome of previous checks (identified trends)
    • other factors that may affect the efficiency of any slaughter activities with the highest animal welfare risks, for example, an increased frequency of monitoring should be conducted when:
      • training new staff
      • when there have been equipment failures
      • when new equipment is installed

Animal welfare PCP records

The operator should retain records of monitoring, verification and regular self-audits/external audits, including corrective action procedures taken to address any deviations identified, as well as any new preventative measures, for at least two years.

Program modifications are made as required. The animal welfare written PCP should be reviewed yearly as part of the licence holder's reassessment of all establishment protocols and plans.

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