In comments filed recently with USDA’s Food Safety and Inspection Service, the American Meat Institute detailed the strong economic benefits that support humane livestock handling and said that FSIS should reject two petitions filed by the Humane Society of the United States and Farm Sanctuary, which suggest that no such incentives exist.

“Their key argument is completely nonsensical,” says Mark Dopp, AMI senior vice president of regulatory affairs/general counsel.

FSIS asked for public comment on the petitions, as well as on the agency’s clarifications for rules regarding non-ambulatory animals, in the Feb. 7 Federal Register

Of particular concern to the dairy industry, the HSUS petition seeks immediate euthanization of veal calves that cannot walk when they arrive at federally inspected plants. The petition seeks to prohibit the common practice of warming veal calves to permit them time to rest and become ambulatory. FSIS indicated that it is inclined to grant this petition.  

The Farm Sanctuary petition seeks immediate euthanization of any livestock arriving at plants that are non-ambulatory for any reason.

In both petitions, the petitioners argued that when livestock are unable to walk, an incentive exists for plant personnel to abuse the animals and force them to walk. AMI’s comments deconstructed that argument by showing the strong incentives that exist to ensure an animal’s welfare, both in terms of the quality benefits and in terms of the costs attendant to lost production time when regulatory actions are taken in response to inhumane treatment of livestock.

AMI also noted that granting the Farm Sanctuary petition, in particular, would  impede disease surveillance and could cause confusion if, for example, a non-ambulatory hog that is simply tired and refusing to rise becomes ambulatory before a veterinarian arrives to check it.   

“Absent an FSIS dictate that all animals be held for ante-mortem inspection, many non-ambulatory animals would be euthanized and disposed of before being examined for disease.  Ironically, many animals, especially in the case of hogs, in the time it can take for the federal veterinarian to arrive to conduct such an inspection likely would become ambulatory, thereby creating a quandary regarding the status of such animals when subject to ante-mortem inspection,” according to the AMI filing.  “That is, would livestock in such circumstances still be subject to condemnation even if found not to be diseased?  If so, why and if not, why should they be treated differently from animals that are non-ambulatory, are subjected to inspection, and also found to be disease free?”

In conclusion, AMI said that granting the petitions would result in unnecessary waste with no identifiable benefit.  

“If a non-ambulatory pig or veal calf could become ambulatory with rest or warming, if they can be handled in a way to minimize discomfort, if economic incentives exist to promote good care, and if these animals can pass ante-mortem inspection, is it really appropriate, ethically, morally, and otherwise, to turn livestock that have the potential to nourish people into little more than a waste disposal problem?  In destroying these livestock, a farmer’s livelihood is also harmed dramatically,” AMI says.  “The only beneficiaries under this scenario are the petitioners, who will be able to claim ‘victory’ to their constituents, a collection of persons whose underlying purpose is to oppose animal agriculture and meat consumption.”

Dopp says that while the official public comment period is technically closed, it’s not too late for concerned famers to contact the agency with additional comments.

“It’s almost impossible to say when FSIS will make their final decision on these requirements,” he concludes.