The CFIA should legally be enforcing all sections of its current animal transport regulations. Thus, horses’ heads must not come into contact with the tops of shipping containers and horses over 14 hands must be segregated when being transported by air, as per Sections 142 (a) and 141 (8), respectively of the Health of Animals Animal Transport Regulations. I am aware, from access to information documents that many of these shipments are comprised of draft horses that are residing in feedlots and as such, they are considered to be wild due to minimal handling. As a result, they have the potential to do serious damage to one another if they aren’t segregated. Installing partitions, between the horses from the withers down, would still allow horses to see one another and socialize. Such partitions would prevent serious inflictions of leg injuries by other horses, while providing the animals with sufficient space to remain upright during flight.
There is currently no provision in the International Air Transport Association (IATA) Live Animals Regulations (LARs) to permit draft horses to be transported unsegregated in bulk wooden containers (personal communication with IATA). Exception 5 of the IATA LARs only allows for small polo ponies, Icelandic ponies, weaned pony foals, and pony yearlings to be shipped in unsegregated containers. There is no such provision for draft horses. It further states that it is essential that sufficient space be given to all animals so that they can move in order to balance and maintain good foothold. The IATA regulations require at least 8 inches head clearance for larger farm stock and minimally 3 inches between horses at their widest points. These requirements have not been respected with a number of these shipments (access to information documents).
In summary, both the federal animal transport regulations and IATA regulations are in place to help protect the welfare of animals. Horses have been both injured and killed in some of these shipments (access to information documents). The World Organization for Animal Health (OIE) recognizes the IATA LARs as the international standard for live animal transport by air. As an OIE member country, Canada is expected to implement those standards. After 40 years, the CFIA recently embarked on updating the Health of Animals Animal Transport Regulations. It is very disconcerting that within the proposed changes, the CFIA is removing the current requirement of segregation for horses over 14 hands and the requirement of horses heads not to come into contact with the tops of shipping containers. To do so would not be consistent with the international standards of IATA and the OIE.