EQUINE PROTECTION NETWORK

Proposed Regulations for the
Commercial Transportation of Horses To Slaughter

The proposed regulations for the Commercial Transportation of Horses To Slaughter Act have been published in the Federal Register. The Federal Register is online. The public comment period is until July 19, 1999.

ADDRESSES: Please send an original and three copies of your comments to:
Docket No. 98–074–1,
Regulatory Analysis and Development, PPD, APHIS,
Suite 3C03, 4700 River Road Unit 118,
Riverdale, MD 20737–1238.

• State that your comments refer to Docket No. 98–074–1
• Comments MUST be received before July 19,1999.

It is _STRONGLY_ recommended that you also send copies of your comments to your US Senator & US Representatives in Washington, DC.
To locate your US Senator & US Represenative call: 202-224-3121.
Copies may also be sent to the American Horse Council,
1700 K Street NW, Suite 300, Washington, DC 20006

The proposed regulations are for the Commercial Transportation of Horses to Slaughter Act which passed in 1996. The Act stated that the,

"Secretary of Ag may issue guidelines to regulate the transportation of horses to slaughter..."

Many people mistakenly believed that when the law passed the horses were protected. Not so. The law simply stated that the Secretary of Ag had the authority to create guidelines. The proposed regulations are these guidelines. The words "safe" and "humane" do NOT exist in the law.

The original intent of this law was to ban the use of double deck cattle trailers, ban the shipment of pregnant mares and foals to slaughter, ban the shipment of sick & injured horses by having a veterinarian inspect the horses, require ceiling height of no less than 6'6", require secure footing & safe interiors, water, food & rest no less than every 12 hours, limit the number of horses on a trailer, segregate horses by size & sex.

The proposed regulations will allow the following;

1. Double deck cattle trailers will continue to be legal for another 5 years. These trailers can have ceiling heights as low as 5'7". Commercial horse trailers are no lower than 6'6", with most being 7' to 8' tall. Using a conservative number of 200 horses in a double deck a week, that is 10,400 horses a year, or 52,000 horses over the next 5 years that will continue to be forced to ride in trailers designed for cattle and hogs that do not allow the horses to stand upright and cause head, back & neck injuries.
   
   
2. It will be legal to ship horses 28 hours with no water, no food, & no rest. Equine industry transport standards are water every 4-6 hours depending on the weather. Equine husbandry practices recommend water no _less_ than every 12 hours. Horses are transported in boarded up trailers during the summer when outside temperatures are exceeding 90 degrees. With 40 - 45 horses in a trailer it is impossible for these horses to receive enough ventilation. Horse industry standard for the same size trailer is 8 to 15 horses.
   
   
3. Full term pregnant mares can be shipped to slaughter, as long as the owner/shipper, the very person who stands to benefit by shipping the mare & the person who stands to lose money if the mare is not shipped, does not believe the mare will foal during the trip. Equine veterinarians have stated that they cannot predict when a mare is going to foal.
   
   
4. The owner/shipper, the very person identified as the person(s) inflicting the inhumane treatment to slaughter horses have been put in charge of determining whether or not a horse is fit to ship instead of a veterinarian. Considering that the owner/shipper stands to lose money if the horse does not ship, & stands to profit if the horse does ship, this is an apparent conflict of interest.
   
   
5. Penalties will be civil, not criminal. In other words law enforcement cannot enforce. Enforcement will be at the slaughterhouse, not at auctions or feedlots prior to loading. The USDA is in charge of enforcing the regulations. The USDA does not enforce their regulations now at horse auctions.
   
   
6. Language is performance based instead of engineering based.
   Performance based language makes enforcement more difficult.

The proposed regulations fly in the face of every accepted horse transportation industry practice, horse management practice & horse husbandry practice. Horses bound for slaughter are still horses, they have not shrunk in size, their behavior has not changed, their need for water has not changed. They are still alive & need to be transported in vehicles designed to transport horses & using methods designed for horses.

New York State banned double deck trailers and instituted safety standards for horse trailers 18 years ago & has stepped up enforcement of their transport law, Sec 359-a. New York State continues to use its law to crack down on the cruel and inhumane transport of slaughterbound horses from Pennsylvania auctions through New York to Canadian slaughterhouses for human consumption overseas. The simplicity of New York State's law facilitates the prosecution and conviction for illegal shipment of horses, and New York State counties have seen revenue of $7700 in a 12 month period, with over $11,000 in unpaid fines on the books.

Related Stories