Canada’s Codes of Practice for the care and handling of farm animals are guidelines that are developed by the National Farm Animal Care Council (NFACC) and funded by the federal government. NFACC is made up of representatives from farmers, government and animal welfare organizations. The codes consist of ‘requirements’ and ‘recommendations’, and are intended to be used as guides for how farmers treat their animals. ‘Requirements’ may be enforceable under federal or provincial legislation. However, because of the nature of animal farming, there is no mechanism for their preventative enforcement.
There are 15 codes, for different animal groups. They are reviewed and revised periodically. The Code of Practice for Pullets and Laying Hens has been under review, and is now online for public comment until August 29th.
VHS feels there are several problems with the draft code, including not mandating the phase-out of all cages, continuing to permit ‘debeaking’ of hens, and permitting cruel battery cages to be used until 2036.
You can see the draft code here.
Comments will only be accepted via an online form available here.
However, if you know of someone who has no access to the internet, please encourage them to send their comments to:
NFACC, P.O. Box 5061, Lacombe, AB T4L 1W7.
Below, you can view some of VHS’s comments on the Draft Code for Laying Hens, as submitted online on August 2, 2016.
- Housing systems for layers – Section 2
- The draft code does not mandate the phase out of all cages, instead permitting the use of ‘enriched’ caging in the mandated types of housing systems – section 2.3. This makes no sense when the retail food industry is obviously committed to meeting the cage-free demands of consumers. A poll conducted by NRG Research Group in May of 2016 (commissioned by Mercy for Animals) found that,
- 76% of Canadian surveyed said No to the question, “Is it acceptable to keep egg-laying hens in cages nearly their entire lives?” and
- 79% of Canadians surveyed said Yes, the National Farm Animal Care Council (NFACC) should recommend that egg producers in Canada use cage-free systems.
To consumers, a cage is a cage.
- “Enriched” cages should be prohibited in the code for the following reasons:
- “Enriched” cages severely restrict key behaviours like running, full wing-flapping and flying and do not permit unrestrained perching and dustbathing. Even in an enriched cage system that meets the code requirements, many of the welfare problems inherent in battery cages remain.
- Although the draft code contains extensive requirements and recommended practices regarding “enriched” cages, there is no system in place to ensure that either can be enforced on-farm. In Europe, where this system has been in use for several years, investigators are finding the conditions for hens in these cages to be little better than they were in battery cages – anxious hens with beaks severely trimmed, bodies badly feather-pecked, perches too low, too many hens crammed in, lives spent on wire floors or dirty perches, inadequate nesting and foraging opportunities.
- “Enriched” cage systems have been criticized by poultry scientists such as Dr. Ian Duncan, who publicly stated that at first he had high hopes that enriched cages would address welfare issues, but he has since been disappointed. Among other criticisms, he said the perches were too low and the opportunities for dust-bathing were not successful.
- Space allowance – Section 2.3.2.
- In the draft code, space allowances per bird differ based on the housing system. All minimum space requirements, regardless of housing system, should be the same as Aviary requirements (1,900.0 square cm.) (A hen in a battery cage, ‘enriched’ cage or free-run/free-range system should have the same space).
- A scientific review was done to synthesize the results of research relating to animal welfare issues for use by the Code Development Committee (CDC) in drafting the codes of practice. In every instance, the scientific report recommends more space than the draft code provides. At a minimum the codes should reflect the scientific review.
- Final deadline for transitioning to Enriched Housing Systems – Section 2.3.6
In the draft code, conventional battery cages will be allowed until 2036, even though the codes state, “The industry commits to a minimum of 85% of hens to be transitioned from existing conventional cage systems to alternative housing systems that meet the requirements of this Code within 15 years (2031), and will aim to transition 100% within the same time frame. If any hens remain in conventional cages after 15 years, greater space allowance that represents as much as a 34% increase in space must be provided.”
- Industry is ‘aiming’ to transition 100% by 2031, so the codes should not permit battery cage use after that date.
- The Canadian retail food industry has clearly indicated its intention to purchase only cage-free shell eggs by, at the latest, 2025 with some (A&W Canada) as early as 2018. This follows the lead of the US retail food industry. The Code Development Committee should mandate an earlier transition completion date. Twenty years is too long to confine hens in cruel battery cages.
- Beak Trimming – Section 188.8.131.52
“Beak trimming” or debeaking is a practice whereby up to one-half of the beak is cut off by a hot blade or laser. It can cause short and/or long-term pain. It’s performed to deal with cannibalism or birds pecking each other, caused by overcrowding. Although battery cages were ostensibly designed to deal with this by limiting the number of birds in a group (typically 4-8 in each battery cage), birds kept in battery cages are still debeaked. Typically, beak-trimming is done at hatcheries, when the chicks are born, and which is covered by another code. However, the Draft Code deals with debeaking on-farm which may be used to control cannibalism in birds that haven’t been debeaked or those whose beaks have grown back.
Because this inevitably results in short-term pain and can result in long-term pain, the VHS would like the codes to address this in terms other than by accepting that it’s the only way to control feather-pecking. There are many ways this can be addressed, such as breeding a less nervous, less-aggressive bird. While the ‘requirements’ state that it must be done prior to 10 days of age, by competent persons, and only in emergency situations after that age with the oversight of a veterinarian, yet again the enforcement of the requirements comes into question.
Mutilations should not be used to deal with management problems.
- Handling and Catching – Section 6.3
By the time they stop laying, hens have weak bones and when handled, there’s a high risk of painful bone fractures. The manner in which they’re handled when being caught for transport and slaughter influences how much the birds will suffer. The most humane way is to allow birds to remain in an upright position while being removed from cages (rather than being pulled out upside down by the legs) and put into wheeled carts that can be directly loaded onto vehicles in place of crates. The Codes should:
- mandate a phase-out of crates, and
- have an immediate requirement that hens not be handled by the legs and/or wings but be kept in an upright position at all times.
- any personnel involved in catching should be required to be certified as having received training in how to do so in the most humane manner.
- Shackle carts, named because the birds will be hung upside down, which is painful and stressful, should be immediately prohibited.
- Decision Making around (on-farm) Euthanasia – Section 7.3
- Recommended that on-farm personnel understand and follow protocols on when birds must be euthanized, as outlined in the on-farm euthanasia plan – should be required.
- Methods of Euthanasia – Section 7.4
- Draft states that euthanasia methods that affect the brain first are preferred. This should be mandated. Each farm should not be charged with choosing their own euthanasia method – it should be required that it be done as humanely as possible.
On-Farm Depopulation – Section 7.5
- Draft states that “Destroying an entire flock may employ euthanasia techniques, but not all methods used for on-farm depopulation meet the criteria for euthanasia. Despite this, the methods employed for destroying large numbers of birds need to be as humane as possible given the situation. Methods used for on-farm depopulation planned at end of lay should meet a higher welfare standard than methods used in emergency situations.” This implies that a lower welfare standard is acceptable.
- Required vs recommended
- Requirements – these refer to either a regulatory requirement or an industry-imposed expectation outlining acceptable and unacceptable practices and are fundamental obligations relating to the care of animals. Those who fail to implement Requirements may be compelled by industry associations to undertake corrective measures, or risk a loss of market options. Requirements also may be enforceable under federal and provincial regulation.
- Recommended Practices – Code Recommended Practices may complement a Code’s Requirements, promote producer education and can encourage adoption of practices for continuous improvement in animal welfare outcomes. Recommended Practices are those which are generally expected to enhance animal welfare outcomes.
In almost every section of the code, there are Recommended Practices that should be Requirements. For instance:
Section 3.2 – Temperature: Recommended Practices include;
- Record minimum and maximum inside temperatures daily
- measure the temperature at bird level
- monitor for signs of cold or heat stress, particularly when ambient temperatures are extreme.
This point, however, may be moot, as there is no system by which the Requirements can be enforced. If an on-farm situation deteriorates to the point that the Requirements are used as enforceable under federal and provincial legislation, the situation will have already deteriorated with an outcome most likely extremely detrimental to the health and welfare of the birds involved. In other words, problems are only corrected after they’ve occurred, as opposed to being prevented before they occur.
The codes should mandate a third-party animal welfare auditing system, as occurs in organic egg production. In our experience, the public already expects that’s the case, when in reality, the only oversight is by industry itself to determine compliance with quota.