The American Veterinary Medical Association (AVMA) comment period on proposed updates to its Policy on Euthanasia is now closed.
The AVMA euphemistically describes the grizzly and outmoded practice of horse slaughter as "humane euthanasia" meaning a humane, good death.
In its 2007 Policy on Euthanasia and the proposed updates, AVMA endorses use of gunshot or the penetrating captive bolt gun to kill horses. In its 2007 Policy, AVMA states that "[a]dequate restraint is important to ensure proper placement of the captive bolt….When an animal can be appropriately restrained, the penetrating captive bolt is preferred to a gunshot."
This caveat about using "adequate" or "appropriate" restraint is echoed on one page of the 2011 proposed guidelines: "Both [gunshot and the captive bolt gun] should only be used by well-trained personnel who are regularly monitored to ensure proficiency, and firearms must be well-maintained. Appropriate restraint is required for application of the penetrating captive bolt". In the discussion of equids specifically, the captive bolt gun is declared only conditionally acceptable unless all criteria for its use are met. In an article linked to the proposed guidelines, there is a warning that "good restraint" is required "so that the device may be held in close contact with the skull" when fired.
But on another page in the same proposed guidelines for use of the penetrating captive bolt gun, AVMA declares it not conditionally acceptable, but acceptable as a method of killing horses. The only disadvantages cited here are that the use of the "captive bolt can be aesthetically displeasing" and "[d]eath may not occur if equipment is not maintained and used properly."
The proposed updates nowhere mention Dr. Lester Friedlander, DVM & former Chief USDA Inspector, who told Congress in 2008, "The captive bolt [used to slaughter horses] is not a proper instrument for the slaughter of equids, these animals regain consciousness 30 seconds after being struck, they are fully aware they are being vivisected."
Nor does the proposed AVMA guidelines mention the Food Safety Inspection Service(FSIS) has been grossly ineffective in protecting horses from cruelty during slaughter. In 2004 the Government Accountability Office (GAO) found the most frequent violation noted by inspectors in slaughter houses was ineffective stunning, meaning "in many cases …a conscious animal reach[ed] slaughter" in violation of Humane Methods of Slaughter Act, 7 USCS § 1902(a); 9 C.F. R. §313.15, 9 C.F.R. §313.50(c). See GAO-04-247, GAO-08-686T.
GAO also noted there had been no effort made to stop the ineffective stunning and the records kept by inspectors were so poor, it was impossible to tell even by 2008 that there had been any improvement. In 2008, USDA’s Office of Inspector General reported that FSIS management controls over preslaughter activities should be strengthened to minimize the possibility of egregious cruelty.
By 2010 GAO was adamant "[a]ctions are needed to strengthen enforcement" of the Humane Methods of Slaughter Act. GAO noted despite years of reports and highly publicized incidents of abuse at slaughterhouses, FSIS enforcement remains grossly inconsistent and in many places, non-existent. GAO 10-203
In effect, in recommending the penetrating captive bolt, AVMA does not consider that slaughter of horses occurs in a brutally cruel environment, not a carefully controlled laboratory setting.
Or maybe they do. As John Holland has explained, "In its 2000 report on methods of Euthanasia, the AVMA stated that the captive bolt gun should not be used on equines unless head restraint could be assured. This is because of the relatively narrow forehead of equines, their head shyness and the fact that the brain is set back further than in cattle for which the gun is intended. It is difficult for an operator to assure proper placement of the gun.
"No slaughter house ever found a practical way to restrain the heads of the horses, so by the AVMA’s very definition, the process was not acceptable. The result was a very large number of ineffective stuns. These misplaced blows undoubtedly caused severe pain until a stunning or fatal blow was delivered. "
What is particularly disturbing is in its 2007 Policy on Euthanasia, AVMA simply omits any mention that horses’ heads should be immobilized during use of the captive bolt gun. The report simply refers to "adequate" or "appropriate" restraint. The type of restraint is not described.
The fact is there was no effort made at the slaughter houses to restrain horses’ heads during slaughter; nor is there any way to do so. There was no effort made to place the captive bolt carefully against the horse’s forehead to ensure an instant death.
Workers at horse slaughterhouses in the U.S. were generally untrained, paid low wages and in many instances undocumented. (In Canada inspectors were ordered to stay off the kill floor during slaughter out of fear for their safety; the government feared the violent workers on the kill floor.)
There is also the issue of danger to the public health. As the Veterinarians for Equine Welfare explain, "[VEW] strongly object[s] to the AVMA … position in favor of horse slaughter for human consumption. For the AVMA… to condone the human consumption of meat derived from equines that have not been raised or medicated in a manner consistent with food safety regulations is, in our opinion, unethical, disingenuous, and dangerous."
A recent European Union Food and Veterinary Office investigation into the horse slaughter plants in Mexico revealed numerous serious violations including drug residues in the meat. For more on the food safety issue created by horse slaughter……
WHAT YOU CAN STILL DO
The AVMA is no longer accepting comments on the 2011 draft of the Euthanasia guidelines. You can still email AVMA at firstname.lastname@example.org Urge AVMA to do the following: (1) reject that the penetrating captive bolt or gunshot can be done humanely and safely in a slaughter house setting, (2) find that horse slaughter is inhumane and (3) call on Congress to ban the slaughter of horses.