January 7, 2008
Dr. Timothy Cordes
Senior Staff Veterinarian
Regulatory Analysis and Development
PPD, APHIS, Station 3A-03.8
4700 River Road Unit 118
Riverdale, Maryland 20737-1238
Re: Docket No. APHIS-2006-0168
Dear Dr. Cordes:
The American Horse Council (AHC) appreciates the opportunity to submit these comments on the U.S. Department of Agriculture’s (USDA) proposal to amend the regulations governing the commercial transportation of equines for slaughter. The proposed changes would extend the regulatory protections provided by the Commercial Transport of Equines to Slaughter Act (the Act) to horses bound for slaughter but delivered first to an assembly point, feedlot, or stockyard.
The AHC supports the proposed changes.
American Horse Council
The AHC is a Washington-based association that represents the horse industry before Congress and the federal regulatory agencies. The AHC includes over 160 equine organizations representing all horse breeds and virtually every facet of the horse industry, including horse owners, breeders, veterinarians, race tracks, horse shows, trainers, rodeos, farriers, breed registries, horsemen's associations, state horse councils and commercial suppliers.
Background
The AHC was one of the principal organizations involved in passing the Commercial Transport of Horses to Slaughter Act. The AHC was also involved in working with USDA in drafting the rules adopted under the Act to regulate the transport of equines for slaughter in December, 2001. These rules subjected commercial transporters of horses for slaughter to federal regulation for the first time.
The rules require that shippers certify the fitness of these horses to travel and provide them with water, food, and rest for 6 hours prior to being loaded for transport. Once loaded the horses cannot be shipped for longer than 28 hours without being off-loaded for 6 hours and given the chance to rest, eat and drink. While in transport, horses must be checked at least every 6 hours to ensure that no horse has fallen or otherwise become physically distressed in route.
Trucks used to transport horses to processing facilities must allow for the segregation of stallions and aggressive horses from others, provide enough room for the well-being of the horses during transport and be equipped with doors and ramps that allow safe loading and unloading.
The rules prohibited the use of double-deck trailers to commercially transport horses to slaughter after December 7, 2006.
Proposed Changes
The rule proposal notes that the Commercial Transport of Equines to Slaughter Act applies to “equines for slaughter,” which are broadly defined in the law as “any member of the Equidae family being transferred to a slaughter facility, including an assembly point, feedlot, or stockyard.” But the current rules apply only to the transport of equines directly to the slaughter plant, not to the transport of equines that are moved at to an assembly point, feedlot or stockyard during the shipping process.
USDA suggests that this a gap in the protections of the Act. The AHC agrees. As the current regulations are written, equines sold as slaughter horses may be transported to an assembly point, feedlot, or stockyard without any of the protections afforded by the regulations. The proposed rule change would fill that gap.
The proposed change would broaden the protections of the Act by re-defining “equine for slaughter” to include any equine “being transferred to a slaughter facility, including an assembly point, feedlot, or stockyard.” In effect, the proposed changes would move-up the point at which the regulations apply in the process of moving horses from sales, farms, and other points to a slaughter facility. The proposed change would provide equines delivered to intermediate points en route to slaughter with the same protections regarding food, water, hour limits, and the prohibition on double-decker trucks, as those horses moved directly to plants. The AHC supports these changes to protect these horses.
The AHC appreciates this opportunity to support these needed changes to the current regulations.
Sincerely,
James J. Hickey, Jr. President
1616 H Street NW 7th Floor . Washington DC 20006 . 202-296-4031 . Fax 202-296-1970
Email: AHC@horsecouncil.org . Web Address: www.horsecouncil.org