Fact Sheet: Transport to Slaughter

It is the united opinion of the Veterinarians for Equine Welfare (VEW) that opponents of legislation currently before the United States Congress that would end horse slaughter and prohibit export of horses for slaughter, have been misleading when stating that horses being transported to slaughter are well-protected by existing federal regulations.  This clearly is not the case and the links below provide graphic examples of the condition of slaughter-bound horses during transport.
 
Since 1989, approximately 2 million horses have been slaughtered at USDA-approved horse slaughter plants. [1] The majority of horses are purchased (by commercial killer-buyers who contract with slaughterhouses) at auction terminals across the US and Canada and then transported to one of three existing slaughter plants located in Texas and Illinois. [2] To attempt to ensure that horses destined for slaughter are handled and transported in a humane way, and in response to action taken by various humane organizations, Congress included in the 1996 farm bill authority for the Secretary of Agriculture to issue guidelines to regulate the commercial transportation of horses to slaughter by persons regularly engaged in that activity within the United States. [3]
 
The regulations issued by the Secretary of Agriculture, which were published in December 2001, are available at http://www.aphis.usda.gov/. Although the intent of Congress was to protect horses being sent to slaughter, the resulting regulations are inadequate, unclear, and contain many loopholes. The net result is that the regulations are very difficult to enforce, there has been little improvement in transport conditions, and horses continue to experience inhumane treatment enroute to slaughter.
 
Existing Transport Regulations are inadequate in many ways, including the following:
 
1. The definition of “shipper” in Section 88.1 is too narrow. This narrow definition exempts commercial shipments of horses to slaughter when that is “incidental” to the principal activity of production agriculture. This loophole means that many horses shipped to slaughter are not even protected by the regulations.
 
2. The USDA Animal and Plant Health Inspection Service recognized that transporting horses in double-deck trailers is both inhumane and unsafe. [5] However, the regulation in Section 88.3 allowed horses to continue to be transported to slaughter in double-deck trailers until December of 2006. Unfortunately, many horses continued to suffer serious injuries and trauma during this “grace” period , and many are still at risk.  The remaining risk results from a loophole in the regulations that bans double-deck trailer use only for hauling directly to slaughter plants.  Horses in the slaughter pipeline can still legally be hauled in double-deck trailers to feedlots or other holding points (sometimes in close proximity to the slaughterhouses), provided they are off-loaded and transferred to single-deck trailers for final delivery.
 
3. Section 88.3 attempts to outline other standards that are required for conveyances. Unfortunately, the requirements are vague and rely upon the subjective judgment of individuals, many of whom are motivated exclusively by economic considerations. For example, what constitutes “adequate ventilation?” and what is meant by “doors and ramps of sufficient size and location to provide for safe loading and unloading?” In Section 88.4, what exactly is “enough floor space to ensure that no equine is crowded in a way likely to cause injury or discomfort?” The open-ended nature of these specifications makes adequate enforcement very difficult. In addition, the regulation does not address vehicle and ramp flooring. Slipping during loading and transport results in numerous (often serious) injuries caused by the animals not being able to secure footing.
 
4. In Section 88.4, requirements for transport are again too vague to be meaningful and adequately enforced. While the regulation requires that horses be allowed the opportunity to rest, eat and drink for at least six hours prior to transport to their final destination, it fails to provide a clear description of adequate nourishment and hydration. Depending on how horses are grouped in holding pens, dominant and/or aggressive horses may prevent other horses access to food and water. With no description appropriate management procedures or the quality or quantity of food and water to be provided, horses are not adequately protected.
 
5. More importantly, the only proof that such services are provided is a signed owner/shipper certificate.  Allowing the owner/shipper, who is financially motivated by sending his horses to slaughter in the cheapest and quickest manner, to verify whether his own activities meet the regulations, is ludicrous. Because no veterinary inspection takes place prior to loading the horses, whether or not the conditions have been met depends entirely on the word of the owner/shipper. There is nothing to prevent falsification of documents which is in the financial interest of the owner/shipper.
 
6. Even though the regulation provides for inspections en route (i.e., from the point of loading the horses on the conveyance to offloading them) to slaughterhouses as well as at the facilities themselves, such inspections rarely occur. A case of abuse during transport was exposed in Texarkana, Arkansas .  Given budgetary constraints and a USDA that is understaffed to carry out inspections, this provision is almost meaningless. It is impossible for a USDA inspector at a slaughter facility to determine with certainty that the owner/shipper has complied with the requirements outlined in Section 88.4. Reliance on a certificate that can be easily falsified defeats the purpose of the regulation and leaves horses at the mercy of the owner/shipper.
 
7. In addition to providing the above mentioned documentation of care, the owner/shipper certificate is the official record that identifies each horse being transported to the slaughterhouse.   Unfortunately, the description and tattoo/brand information is often incompletely recorded, and the regulation only requires the owner/shipper to retain a copy of the certificate for one year. Poor compliance in terms of identification of slaughter-bound horses, and the short retention period for the required documentation, often fail to allow traceback of stolen horses so that law enforcement agencies and members of the public who are attempting to track down lost or stolen horses can determine what happened to them.
 
8. The regulation allows the use of electric prods on horses if human safety is threatened, yet more humane equipment which is widely regarded as safer and more effective for handling and controlling horses is readily available. In fact, horses respond unpredictably (often violently) to the use of electric prods, potentially increasing the threat to human safety, yet the regulation allows this practice to continue.
 
9. The regulation also does not call for separation of horses by size. Many horses suffer injuries caused by being knocked down or crushed when smaller and younger horses are not separated from larger, heavier horses during transport.
 
10. Based upon findings in numerous scientific studies, some of which were funded by the USDA, but curiously absent in the explanation of the regulation, the 28 hour maximum transport limit without rest and nourishment is scientifically unjustifiable. It appears that the USDA is simply adopting the same rule that applies to the transport of other livestock despite Congress’s determination that horses being transported to slaughter have unique and special needs. If, for example, offloading for food and water is generally recommended every four hours for privately-owned horses, it is clear that the 28 hour limit is excessive and contributes to the inhumane treatment of horses in transit to slaughter.  It is also virtually impossible to enforce.

11. In addition to allowing horses to be transported for up to 28 hours, the regulation only requires that horses be checked every six hours during transport. This interval is much longer than that which would normally be recommended for horses being transported for other purposes (generally 2 hours), and again, in practice, the regulation is virtually impossible to enforce.

 
[1] Report of the United States Department of Agriculture, Animal and Plant Health Inspection Service.
 
[2] See id.
 
[3] See id.
 
[4] Christopher J. Heyde, Necessary Evil or Blind Eye? Putting an End to the Cruel Practice of Horse Slaughter, Animal Welfare Institute Quarterly, Winter 2002, at http://www.awionline.org/pubs/Quarterly/winter02/blindeye.htm. 

[5] "We acknowledge that some double-deck trailers are likely to cause injuries and trauma to equines." Commercial Transportation of Equines to Slaughter; Final Rule, United States Department of Agriculture, Animal and Plant Health Inspection Service.

(Updated February 2007)

 

 

 

 

 


Note: Inclusion of extermal links () here is not an endorsement; those listed are not necessarily in accordance with VEW aims and policies.