An Open Letter to the Canadian Food Inspection Agency

March 13, 2012

Dr. Martin Appelt
National Manager
Meat Programs Division
Canadian Food Inspection Agency
1400 Merivale Road
Ottawa, ON  K1A 0Y9

Dear Dr. Appelt:

In view of Dr. Brian Evans’ prolonged leave of absence, we are sending this package for your review. Enclosed please find full, unedited video footage of our investigative report “Pasture to Plate – The True Cost of Canada’s Horsemeat Industry” at Les Viandes de la Petite-Nation Inc. on July 13 and 14, 2011.

(Links to the Pasture to Plate web page: and the full 88-page report: 

The Canadian Horse Defence Coalition notes that the CFIA has not at any time requested full footage of the 2011 investigation but has made numerous statements to the public based on posted information only. We trust that viewing the footage in its entirety as well as the memory stick containing photographs of EID documents (matched up to horses slaughtered at Les Viandes de la Petite-Nation) will dispel many of the doubts expressed and misinterpretations made by the agency, including:

  • “You have expressed concerns about the safety of horsemeat with respect to possible drug residues and referenced photos of Equine Identification Documents (EIDs) that are purported to be incomplete, inaccurate or falsified. All equine owners intending to sell animals directly or indirectly to Canadian meat processors must provide an EID that reports all vaccines, medications or occurrences of illness within six months of slaughter. The photographs in question have been determined to be taken at an auction in the United States. There is no indication that these documents were presented to any Canadian slaughter plant.”
  • “The EU has accepted the EID as an alternative to its passport system because both systems achieve a similar outcome….EIDs are checked daily by CFIA veterinarians and filed by operators at each federally registered establishment slaughtering equine….Omission or falsification of information on EIDs of horses presented for slaughter is an offence.”
  • “There are significant limitations to the use of video footage in the absence of eye witness testimony as the basis for enforcement or prosecution purposes.”
  • “This [the inability of the recently released undercover video footage to be used for regulatory enforcement purposes] can be further compounded when there is a significant time lag between the shooting of the video and its presentation to the CFIA and when the video has been edited.
  • “Recognized subject matter experts and international humane standards call for assessment of several critical features to affirm the effectiveness of the stun procedure that include the eye, the tongue, and the nose, which can only be determined from the front of the animal. As the video was taken from behind, it is not possible to conclusively use the video to make these assessments.”
  • “With respect to the large Belgian that is seen to have received multiple stuns, while its state of consciousness is unclear, nevertheless this is one area of operations being assessed.”

The CHDC would like to respond to the above points. The allegation that the EIDs presented as evidence was “determined to have been taken at an auction in the United States” is totally unfounded. Please review the photographs of the EID forms and compare them to the tattoo numbers of horses killed at the plant. Our report, Pasture to Plate: The True Cost of Canada’s Horsemeat Industry (copy enclosed), unmistakably illustrates this connection. Has our report, which has been posted on-line since release of the investigation, even been read by the CFIA? There can be no dispute that the documents photographed at Les Viandes de la Petite-Nation arrived along with the horses that were slaughtered. This then begs the question, why isn’t the regulation that dictates: “Omission or falsification of information on EIDs of horses presented for slaughter is an offence” being enforced? It is very evident when reviewing the EIDs that a pattern emerges and it is very clear to see that some EIDs have obviously been “pre-written” across the top with “Drug-free six months”, and the appropriate boxes checked to agree with this information.  Why did the CFIA inspectors and slaughter plant operators not flag this for concern? What remedial actions has the CFIA taken against auctions and owners that have submitted incomplete, incorrect or falsified EIDs?  In addition, what actions has the CFIA taken to ensure Canadian and American horses sold at auctions have EIDs that are filled in completely, correctly and truthfully? 

Why is the CFIA expending so much energy on denial, rather than enforcing legislation and regulations that already exist and simply need to be utilized? 

Regarding drug residues in horsemeat, has the CFIA taken into consideration studies such as a recent one conducted by the Wild for Life Foundation that showed 70% of the annual thoroughbred foal crop in the United States are dying in slaughterhouses each year


Many of these horses are shipped to Canada for slaughter. Bred for the racing industry, they have been administered drugs such as phenylbutazone, which, as you know, is listed on your website for drugs not permitted for use in equines slaughtered for food, and banned from the food chain. The CFIA may wish to deny the connection, but this will not erase what the public already knows – that the likelihood of prohibited drugs being inadvertently consumed by people in Quebec and overseas is very high. By the CFIA’s own admission, two horsemeat samples have tested positive for phenylbutazone in Canada since 2010. As the most sensitive target for this drug is kidney [Metabolism Excretion, Pharmacokinetics and Tissue Residues of Phenylbutazone in the Horse, Lees, P., Taylor, J.B., Maitho, T.E., Millar, J.D., Higgins, A.J., 1987. Cornell Vet. 77, 192–21:, and not muscle as claimed by the CFIA, one can only wonder how many more positive samples would have been found if the target tissue were the correct one.  Further, in an e-mail to CHDC, the CFIA stated that only 143 samples taken from 93,812 horses in 2009 were tested for phenylbutazone – a woefully inadequate testing sample considering that most horses at some point in their lives have been administered this drug.

With regard to the statement about video footage versus eyewitness testimony, we seriously wonder how this statement would play out in court. Video is an objective accurate account of an event; eyewitness testimonies have often been found to be flawed due to human error or bias. Is the CFIA saying that video images tell lies? The public can view the stun footage online, including longer clips of just some of the ineffective stuns that we released the day this letter was mailed, captured at Les Viandes de la Petite-Nation in July 2011, and decide for themselves whether an eyewitness statement would have been more accurate than real-time footage. It is truly appalling that the CFIA has chosen to trivialize evidence and to shirk its responsibilities toward suffering animals and the general public that relies on the agency to be transparent and truthful.

The CFIA states that there was a “significant time lag between the shooting of the video and its presentation to the CFIA”. The time lag of less than five months occurred because it was our duty to have the evidence thoroughly assessed by independent animal welfare professionals before handing it over to an agency that has proven itself beholden to industry. We have learned this from the three prior horse slaughterhouse cruelty cases we have brought forward since 2008, to the disturbing documents we received in response to a freedom of information request on the CFIA’s botched handling of the Natural Valley Farms/Natural Meat Company cruelty case. Truly the CFIA has become the fox that guards the henhouse. The mandate of the CFIA is to ensure food safety. The mandate of those involved in animal protection is exactly that—to safeguard the well being of animals. The CFIA’s poor track record in the past concerning slaughterhouse investigations did nothing to assure us that this most recent slaughterhouse footage would be handled fairly. As expected, the agency has once again demonstrated, via a continuing stream of shockingly poor and groundless excuses, that animal welfare is not only not a concern for the agency but that it appears to be the agency’s role to protect industry at all costs – especially those costs borne by the animals under its “care”.

Certainly it is true that a number of checkpoints on the head of an animal are used to determine whether stunning has been effective. However, whinnying, rearing, mouthing (visible when horses moved their heads to one side) should not be ignored and were often evident on the videotape. The sheer numbers of re-stun attempts were also indicative of horses not rendered insensible after one shot, as was the shooter “replying” to unstunned horses’ whinnying. Also, the shooter’s statement “Aye – you’re not dead” is clearly indicative of a still-conscious horse despite numerous attempts. The shooter was clearly visible from the front, showing his repeated attempts with the captive bolt pistol.  We would like the CFIA to explain, if the inspector has the authority to stop the line, why he did not do so, given that this particular shooter was clearly lacking in training? We further ask the CFIA what retribution this shooter and/or Les Viandes de la Petite-Nation, as well as the CFIA inspector, received as a result of these obvious acts of incompetence.  Were these acts treated as infractions, and have any prosecutions followed?  To deny the importance of these other parameters in determining sensibility is illogical and proves to the public that the CFIA is simply covering up cruelty. 

Dr. Nicholas Dodman, anesthesiologist and animal behaviourist at Tufts University stated the following regarding the large Belgian whose level of consciousness the CFIA is questioning: [After five shots] “This large horse still appears to be conscious and is shot again in the forehead and even that doesn’t do it as it heaves and tries to rise again…The large size of this horse plus imprecise CBG placement probably led to this totally unacceptable and inhumane result.”

Dr. Dodman’s expert opinion on practices at Les Viandes de la Petite-Nation concludes with: “…my final conclusion, after reviewing 150-plus horse slaughters in this series of videos, is that the process was terrifying for most of the horses and, in many cases, horribly inhumane. The inhumane treatment of horses at Les Viandes de la Petite Nation must be stopped immediately.”

We would also like to address our concerns regarding the design of the knock box that was raised in our report.  It is plainly evident that there is no provision made, besides a flimsy plastic curtain, for horses to avoid viewing the bleed-out/butchering room.  Many horses looked inside past the curtain (that was sometimes left open) and this understandably elevated their fear levels.  Also evident was the fact that larger draft breeds did not fit into the small dimensions of the knock box, causing many of them to hit their heads on the overhead stanchion.  It was also these large draft types that more often required multiple shots to render them unconscious.  In addition, the shooter had to reach up to these larger horses, causing him to shoot at the wrong angle, which is supposed to be from the top down, not reaching up high over his head to try to obtain the right angle. We noted as well that there was no evidence of rubber matting to secure their footing.  The knock box floor was not hosed down regularly to clear slippery blood, urine and manure. Finally, the decreased elevation into the stun box caused many of the horses to stumble upon entering it.

We have learned from Dr. Brian Evans that a rifle will now be the weapon of choice at Les Viandes de la Petite-Nation. This decision is baffling to us as our past evidence from Bouvry Exports and Viandes Richelieu (2010) clearly illustrated blatant animal suffering when shooters were faced with moving targets, specifically the thrashing heads of terrified horses. We also recall that observers are not permitted to be in the shooting area. Who, therefore, does the monitoring, and how will oversight be achieved?

We expect to receive a detailed response within 30 days explaining how the agency will respond to the violations of the Meat Inspection Act (specifically 62. (1), 63. (2), 64, 65, 78, 79 (a) and 80); the OIE Standards of Slaughter (Chapter 7.5); the American Meat Institute Slaughter Audit standards; and the fraudulent EID activity. Specifically, we require answers to the following areas of concern:

  • High percentage of inaccurate stuns (40+% over two days of recording)
  • Use of “pithing” of horse which is known to render an animal immobile but not unconscious when stabbed for bleed-out
  • Length of suffering inflicted on horses repeatedly shot (up to 3 1/2 minutes for horse 33 on day 1)
  • Terror-filled environment
  • Mishandling of a “downed” animal (the downer horse shown during the walk-through who was not penned alone or euthanized)
  • Fraudulent EID activity
  • Lack of CFIA inspector presence

We also require an explanation for the agency’s choice of preference for testing muscle tissue rather than kidney for phenylbutazone.  What scientific study is the CFIA relying upon when choosing muscle as the target for testing?

And, finally, Dr. Evans states in his earlier letter: “As a result of investigations and enhanced inspection activities, a number of actions have been taken, including training and certification delivered…et al.”  We would like to see documentation of all corrective actions the CFIA has introduced, including monetary penalties, suspensions and/or revocation of operating licences, and/or legal charges brought against either persons or companies at any and all of the four slaughter plants operating currently in Canada.

It is not too late for the denial to stop and for truth and pursuit of justice to take its place.

Sinikka Crosland, Executive Director
Canadian Horse Defence Coalition
[email protected]