“I urge you to consider this rule from an animal welfare perspective before you finalize it,” wrote Grandin.
The letter pointed out that integrated beef-processing companies that own feedlots or production facilities would, for example, be required to ship cattle to either their own plant or to an independent dealer, perhaps hundreds of miles away, rather than selling to another company’s packing plant that could be in the same proximity of the feedlot or ranch.
“Adding shipping time is stressful to livestock and stands to increase injury and potentially death losses, particularly among pigs because they are more subject to transport stress,” Grandin wrote. She added that involving independent dealers to facilitate transactions also would present unnecessary animal welfare risks, because they likely would not have the animal handling programs and standards in place that have become the standards among production and processing facilities. Grandin is also concerned that the proposed rule would complicate and compromise the effectiveness of many established animal welfare-certification programs by requiring another level of paperwork and recordkeeping to track the additional transactions.
“As a scientist who has dedicated her life to improving livestock welfare, I am extremely alarmed that although this rule is concerned with marketing and competition, the department ultimately responsible for it – USDA – is also charged with enforcing the Humane Slaughter Act and apparently has paid so little attention to the animal welfare implications of this proposal,” Grandin stated in the letter.