PROPOSED UPDATES TO SHEEP CODE OF CARE: TAKE ACTION!
Canada’s Code of Practice for the Care and Handling of Sheep was recently updated and released for public consultation. Although the codes of practice are voluntary, they have the potential to set the legal standard, and thus it is important that they address the most painful and cruel industry practices. Public opinion is crucial in encouraging positive changes for the animals.
You can help by submitting comments on the draft code – here’s how!
Step 1: Click here to go to NFACC’s website.
Step 2: Select the red square titled “Click here to participate in the sheep code of practice public comment period.”
Step 3: Fill out the survey. While the entire survey is lengthy and covers many issues, you can save time by focusing on the sections we’ve highlighted below with bold text. Note: The survey must be submitted by September 6.
Thank you for taking a few minutes to lend your voice to help animals!
Suggested comments on the draft sheep code:
Section 1: Environmental Conditions
“Producers must take reasonable steps to promptly assist individual sheep displaying signs of heat or cold stress”: reasonable steps are not, and cannot be defined, and leave too many opportunities for inaction when animals are in distress. This sentence should therefore be replaced by:” Producers must promptly assist individual sheep displaying signs of heat or cold stress, regardless of cost.”
Animals should be chosen with consideration of their ability to thrive in the prevailing climatic conditions of the operation. Therefore, recommended practice a (“select a breed or type of sheep that is suitable for the location, climate, and management system”) should be a requirement.
Section 1.1.1: High Temperature, and Humidity, and Provision of Shade
The requirement “allowing sheep to rest during the heat of the day (e.g., allow rest breaks as needed if trailing sheep long distances)“ should be amended to include a requirement that animals are not transported during extreme temperatures and/or when humidex is high.
1.1.2 Provision of Shelter during Cold and Windy, and Cold and Wet Conditions
Loads of wet snow on the back of sheep can part their wool and, as a result, sheep can get chilled and sick. Thus, sheep do need more than shelterbelts in snowstorms, and producers should always provide sheep with a properly built shelter, and not simply count on the presence of hedgerows, natural windbreaks or land features such as less side of a hill, bush, gully or coulees. The sentence “if bad weather is predicted and adequate shelter for all sheep is not available” should be modified accordingly, and producers reminded of the necessity to have shelter available for all animals, at all times, appropriate to the weather conditions.
The phrasing of the part related to planning for extreme events is unduly lenient, as “producers must consider and be able to consider relocating sheep to a sheltered area or shed” and “producers must consider and be able to consider providing extra bedding”. To minimize the risks of cold stress and animal suffering, these actions must become firm requirements.
In really cold weather, sheep can’t keep their lower limbs warm without a deep enough bed of straw. As such, the provision of a deep layer of straw during cold weather should be a requirement.
Finally, recommended practices b (“if adverse conditions are expected, consider postponing shearing”) and c (“use a cover comb (or lifter) to provide some protection against cool temperatures, insects, and solar radiation as this leaves more wool than a regular comb”) are both important to minimize the risks of animal suffering from hypothermia, and should be requirements. Recommended practice a (“consult a veterinarian to establish a protocol for treatment options for sheep showing signs of hypothermia and include this in the flock health and welfare plan”) is necessary to prevent further suffering to an animal suffering from hypothermia and should also be a requirement.
Section 2: Facilities
2.1 Housing and Handling for all sheep
Permanent indoor confinement should be prohibited. (Note: The suggested pen sizes provided in the draft document do not give sheep enough space to properly exercise and maintain their muscle strength over a long period of time. The concentration of sheep in small areas can also lead to increased diseases. If the code does not prohibit permanent indoor confinement, these problems should be addressed as the space requirements provided are insufficient for long-term housing and stocking rates.)
All animals should have regular pasture access along with access to a properly built shelter, appropriate to the weather conditions.
Apart from overnight shelter, animals must only be kept indoors with no access to the outdoors in an emergency situation or in extreme weather conditions, particularly during the winter, if their welfare would be otherwise affected. When temporary kept in these conditions, sheep should have free movement, and have enough space to lie down and interact with each other.
Male breeding animals should be kept with the main flock, with at least one other compatible animal or have nose to nose contact with other animals of the same species. Rams should not be kept in individual stalls.
Unless the health of other sheep is at risk, sick or injured animals isolated in a sick pen should be able to see the other sheep.
Recommended practices b (“slope or mound feedlot pens, loafing areas, and yards appropriately to provide dry areas and promote drainage”) and c (“allow space for sick/hospital pens when building or setting up a facility”) should be requirements.
Fire alarm systems should be installed in all buildings where sheep are confined, even if the confinement is only temporary.
2.1.1 Temperature, humidity and air quality
Given the potential health risks of high ammonia levels, recommendation c (“take action if ammonia is detectable by people entering the building”) should be a requirement.
Recommendation d (“check for drafts at animal level and adjust ventilation”) should also be a requirement.
2.1.2 Social Environment and Enrichment
Sheep being highly social animals, they should have both visual and physical contact with other sheep, and not be crated in individual stalls. If animals need to be temporarily single-housed, they should have visual and auditory contact with others.
Lambs should be raised by their mother.
Male breeding animals should be kept with the main flock, with at least one other compatible animal or have nose to nose contact with other animals of the same species. They should not be crated in individual stalls.
The preamble to this section states that “sheep must be provided with an appropriate period of rest from artificial lighting (e.g., 6h)”, yet ensuring six hours of darkness in a 24-hour period is only proposed as a recommended practice. It should be a requirement.
All sheep, including breeding animals, should be exposed to natural light, and always exposed to a natural daylight cycle. Intensive confinement practices where animals are permanently kept indoors without access to pasture should be prohibited.
2.1.4 Bedding and Manure Management
Sheep should have outdoor pasture access, and bedding should always be available to them. In cold weather, a deep bed of straw should be provided.
Slated floors systems where bedding cannot be provided and other permanent intensive indoor confinement systems should be considered improper systems to raise sheep.
Section 3: Feed and Water
3.1 Nutrition and Feed Management
All sheep should have outdoor pasture access. They should be able to graze, except of course during seasonal unavailability of grass where supplemental feeding must be provided.
To ensure proper rumen function, sheep must be provided with 70 percent long fiber roughage/forage in their diet on a daily dry matter basis from weaning onwards.
3.1.2 Artificial Rearing
Lambs should be raised by their mothers, unless separating them is required for medical reasons.
Conditions should not be manipulated to increase the occurrence of multiple births (for ex., flushing ewes).
In the case of orphan, abandoned or excess lambs, they should be fostered onto other ewes, and only artificially reared if all other attempts fail. Lambs should never be raised in isolation.
Given the importance of proper hydration, the lack of reliability of snow as a sufficient source of water (quantity, quality), and the need for regular close observation of the snow quantity and quality available (something that some producers might not be able to appropriately gauge), snow should never be the only source of water available, and it should be required (and not recommended) that producers provide water at all times, regardless of cost.
Section 4: Health Management
4.1 Relationship of Animal Health to Animal Welfare
Recommended practices a (“participate in continuing education activities related to animal health and welfare”), b (“keep accurate and detailed animal health records”) and c (“participate in animal health/surveillance programs”) should be requirements.
4.2 Stockmanship Skills Related to Animal Health and Welfare
Recommended practice c (“establish an inspection schedule that optimizes well-being as part of the flock health and welfare plan that includes, at a minimum, daily inspection”) is essential to detect potential health and management problems, and as such should be a requirement. In the same vein, recommended practices a (“incorporate written best management practice protocols within the flock health and welfare plan”) and b (“ensure staff are trained in and apply best management practices”) should be required.
4.4 Sick, injured or cull animals
The preamble to this section stating that providing sheep with comfort and appropriate care are priorities for sheep welfare, providing suffering sheep with pain relief should be a requirement, regardless of cost.
Withholding treatment in order to preserve an animal’s eligibility for market should be prohibited.
Field evidence shows that tail-docking is not necessary to maintain the health and welfare of sheep and lambs, and the risks of fly-strike can be mitigated in ways that do not require the painful mutilation of the animals’ tails. For instance, producers should choose ‘easy care’ breeds as some of these appear more resistant to fly strike than other breeds.
While tail docking should be prohibited, the use of anesthesia and analgesics to reduce the pain of the procedure should be a requirement if its use continues.
Animals with fresh or healing wounds should be attended to and provided with care to mitigate the risk of fly strike in the wounded part.
Due to the strong potential for pain and suffering caused by lameness, measures should be taken to mitigate the occurrence of this condition and the environment in which sheep are raised should not be wet or muddy, conditions which are linked to the development of lameness. Therefore, producers should not simply “avoid” maintaining sheep in wet or muddy conditions for long periods of time, but be required to not maintain sheep in wet or muddy conditions.
As the preamble states that “lameness in sheep is usually an indication of pain and suffering”, the pain experienced by lame animals should not be disregarded and pain relief should be provided to all suffering animals, regardless of cost. Thus, appropriate treatment and control strategies should include pain control, regardless of cost (the proposed requirement merely says “may include pain control”).
Section 5: Husbandry Practices
5.1 Handling, Grouping and Moving Animals
To minimize fear and stress, recommended practice e (using “positive reinforcement (e.g., feed rewards) to encourage positive response for future handling”) should be a requirement. For the same reason, recommended practices i (“working sheep with dogs should be limited to times where their use is necessary”) and h (“minimize isolation of individual sheep “) should also be requirements.
Ear tagging is a stressful and painful procedure that should be prohibited.
Recommended practice b (“consult with a veterinarian if infection or other problems develop “) should be a requirement.
Both hot and cold branding cause acute pain and should be prohibited. Live-export of sheep to countries and regions which require branding should also be prohibited.
5.3 Predation Control
“Producers must provide prompt and appropriate care for sheep that have been attacked by predators.” This should include the use of pain killers, regardless of cost, to prevent further suffering to injured animals.
Non-lethal methods of predator exclusion should first be used. In the event that exclusion is unsuccessful and predation remains an issue, live trapping may be used, providing that live traps are checked twice daily. All other forms of traps, as well as the use of poisons, should be prohibited.
If guardian animals are used to protect sheep, they must be chosen with consideration of their ability to thrive in the prevailing climatic conditions of the production facility.
5.4 Shearing and Crutching
Sheep breeds which shed naturally and do not require shearing should be used by all producers not raising sheep for their wool.
Recommended practice a (“using a cover comb or lifter to leave an insulating layer of wool, if shearing must take place during poor weather conditions”) and b (“provide extra feed, shelter, and shade for sheep after shearing”) should be requirements.
Any sheep accidentally cut during shearing should receive immediate treatment.
5.5 Hoof Trimming
Foot root and other hoof conditions should be treated immediately.
Castration is a painful procedure that should be prohibited.
Scientific studies have concluded that the use of anaesthetics (which should be done in accordance to the castration method used) was effective in reducing pain. Studies have also showed that animals experience pain after castration. In particular, the use of a ring to castrate lambs causes considerable pain and distress to the lamb for up to a month after the initial procedure. If allowed to continue, castration should therefore be performed only if proper anesthetics and analgesics are provided, regardless of cost.
Recommended practice a (“leave ram lambs intact in management systems where rams are weaned early, reared separately, marketed prior to puberty, and not sold into feedlots”), d (“administer pain relieving drugs (anesthetics and/or analgesics)” and e (“monitor for signs of post-operative complications and take appropriate corrective action”) should be required.
5.7 Tail Docking
Tail docking should be prohibited. It is a painful mutilation whose practice is justified as a preventative treatment for blowfly strike. Yet, field evidence shows that tail-docking does not necessarily prevent blowfly strike. In the UK, for instance, 80 per cent of sheep flocks are affected by blowfly strike each year despite tail docking. Producers should choose ‘easy care’ breeds as some of these appear more resistant to fly strike than other breeds.
While tail docking should be forbidden, the use of local anesthesia and analgesics to reduce the pain of the procedure should be a requirement if its use continues.
Animals with fresh or healing injuries should be attended to and provided with care to mitigate the risk of fly strike in the wounded part. Producers should attend immediately to ewes and lambs who are scouring.
5.9 Dehorning/Horn Trimming
Dehorning should be prohibited. Horns may be tipped as long as the living tissue inside the horn is not being cut.
Ewes must not lamb before the age of 18 months.
Laparoscopic artificial insemination and embryo transfers should be prohibited.
Because good welfare measures call for the minimization of pain, recommended practice a (”seek veterinary advice for pain management for obstetrical procedures”) should be a requirement.
All surgical procedures should be done with proper anesthesia and the use of analgesics.
Sheep affected by vaginal or uterine prolapsed should be treated immediately and be given pain killers, regardless of cost.
Animals should not undergo genetic selection to the point that their welfare is negatively affected.
Breeding programs must focus on breed characteristics that will improve welfare.
Electro-ejaculation should be prohibited.
5.11 Pregnancy, Lambing and Neonatal Care
Recommended practice c (“ensure all stockpeople can identify lambs that have not suckled and early signs of hypothermia. Be prepared to implement corrective actions promptly (e.g., have a warming box, stomach tube and supplemental colostrum readily available (86,87), seek expert advice (e.g., veterinary or specialist) on appropriate management procedures to (a) reduce the risk of hypothermia and (b) treat hypothermic lambs”) and h (“euthanize lambs with frostbitten feet”) should be requirements.
As the preamble states, “maternal (ewe-lamb) bonding is very important for lamb welfare and survival” and lambs should be raised by their mothers, unless separating them is required for medical reasons.
5.12 Dairy Sheep – Milking Procedures
Mastitis being a painful condition, animals must be checked regularly for signs of mastitis, and treated immediately, regardless of cost.
Animals showing resistance to enter the milking system should not be beaten, hit or kicked, and the use of electric prods should be forbidden.
5.13 Dairy Sheep – Early Weaning of Lambs
Lambs should remain in the flock and be reared by their mothers until weaning naturally occurs, or at the very least, after they are three months old.
The early removal of lambs shortly after birth should be prohibited.
Orphan lambs or abandoned lambs should be fostered by other ewes, and only artificially reared if all other attempts fail.
Section 6: Transportation
6.1 Pre-Transport Decision Making
Producers should be required to ensure that sheep are provided with water and food at regular intervals for the duration of their transit.
6.1.1 Fitness for transport
Sheep should not be transported during extreme weather and/or when the humidex is high.
Lambs should not be transported around the farm or off the farm until they are at least six weeks old.
Recommended practice c (“shipping only healthy animals to auction markets, breeding stock sales and livestock sales”) should be a requirement.
6.1.2 Arranging Transport
Recommended practices b (“train staff in loading in and unloading sheep”), d (“ensure loading facilities are compatible with the type of trailer being used by the transporter”) and e (“ensure the following information is discussed and agreed upon between transporter and shipper”) should be requirements.
6.1.3 Preparing Sheep for Transport
Sheep must be fed within the five-hour period immediately prior to being loaded even if the expected duration of the animal’s confinement on the vehicle is less than 24 hours from the time of loading.
Lactating dairy ewes must be milked out immediately before being transported, and not transported more than half a day, unless steps are taken to provide them with rest, food, water and relieve their udder of extra milk if they are not accompanied by a lamb.
Recommended practice a (“ensure all documentation is completed to avoid unnecessary delays at inspections stations or other checkpoints along the way, or for shipments leaving the province or country”) should be a requirement.
6.2 Loading and Unloading
Sheep must not be kicked, hit, beaten or electrically-proded.
Proper training in sheep behaviour should be a requirement for all stockesperson participating in the loading and unloading of sheep.
Recommended practices b (“move sheep in groups appropriately sized for the compartments on the hauler “), c (“allow sheep to move at a pace that capitalizes on their strong instinct to follow the leader “) and d (“load sheep calmly and quietly”) should be requirements.
Animals should not be crowded during transport. It is especially important for sheep with fleece to have enough space/ air circulation to prevent over-heating in warm weather.
Section 7: Euthanasia
“The method of euthanasia must be quick, cause minimal stress, pain and result in rapid loss of consciousness followed by death without the animal regaining consciousness”: the word “immediate” should be used in this sentence instead of the word “rapid” (i.e. “result in immediate loss of consciousness”).
Non ambulatory animals with no reasonable chance of recovery must be euthanized where they lie in a manner that renders them immediately insensible to pain. Minimizing handling and movements for downed, injured and sick animals (recommended practice b) should be a requirement.
Conditional on the method of euthanasia used, if handling of animals is required, the use of sedation to help minimize fear, distress and the risk of injury, regardless of cost, should be a requirement.