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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
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