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January 3, 2013
Robert Gerlach, DVM
Alaska State Veterinarian
3 pages via email: [email protected]
Dear Dr. Gerlach,
On behalf of Farm Sanctuary and our 250,000 members and supporters in the United States, I am
writing to offer two suggestions for the Alaska Department of Environmental Conservation’s
(DEC) proposed Animal Care Standards.
Farm Sanctuary cares for more than 1,000 farm animals at our three sanctuaries in New
York and California, and over the past 25 years, we have provided lifelong care for thousands
more. Through our extensive experience, we have learned that farm animals are interesting
individuals who have the same physical and behavioral needs, capacity for emotion, and range of
personalities that we all know to exist in dogs and cats.
In her introduction to The Inner World of Farm Animals, Dr. Jane Goodall writes that
“farm animals feel pleasure and sadness, excitement and resentment, depression, fear, and pain.
They are far more aware and intelligent than we ever imagined . . . they are individuals in their
own right.” And meat industry consultant Dr. Temple Grandin writes in Animals in Translation
that “when it comes to the basics of life . . . [other] animals feel the same way we do.”
It is with these observations in mind that we ask you to require that all farm animals in
Alaska: 1) be provided sufficient space to turn around and extend their limbs; and 2) not be
subject to any bodily mutilation unless that mutilation is specifically called for by relevant
veterinary bodies. These requirements would have the very important effect of prohibiting
battery cages for laying hens, gestation and veal crates for pregnant pigs and calves, and the tail
docking of dairy cows.
Gestation & Veal Crates
Immobilization of pigs and calves in crates is highly damaging for them, both physically and
mentally. First, the animals’ muscles and bones waste away from lack of use, so that walking
becomes excruciating; even standing up can be painful. Second, because the animals rub against
the bars of their crates and lie in their own excrement all day and night, they suffer painful
ammonia burns on their skin, and their lungs become raw from breathing putrid air. Third,
mother pigs in crates are in a constant state of starvation because they are fed about half of what
they would normally consume. Fourth, due to lack of exercise and decreased water consumption,
many sows suffer from urinary tract infections (UTIs) so severe that UTIs are a leading cause of
death for crated sows. Try to imagine a worse way to die.
The situation is no better in terms of the animals’ mental health: Pigs are very social
animals who have cognitive and emotional capacities beyond those of dogs; in some areas, they
outperform chimpanzees. Cattle are similarly inquisitive and are also extremely social. So it's no
surprise that they suffer mental and emotional anguish when they're unable to move for most of
their lives. Dr. Grandin states unequivocally what the science proves—that other animals,
including pigs and cattle, share with humans the exact same core emotions and the same “four
basic social emotions,” one of which is the need to engage in social interaction with others. They
love to play, experience joy, and more. All of their natural desires are impossible when they are
confined in tiny crates. The relentless stress and frustration of confinement routinely leads to
mental instability, so that the animals chew maniacally on the bars in frustration, causing their
mouths to bleed from cuts and sores.
Battery Cages
Remarkably, battery cages have an even worse effect on birds than crates do on pigs and calves.
The cages are so small that not one hen could extend her limbs, and yet the industry stuff five or
more in each tiny cage. As you can imagine, the animals’ muscles and bones atrophy from lack
of use; by the time hens are removed from cages after about two years, all of them have suffered
from severe bone loss and one quarter suffer new bone breaks. For some birds, their skeletal
systems become so weak that their spinal cords deteriorate and they become paralyzed; the
animals then die from dehydration in their cages. This horrid situation is so common that the
industry has a term for it, “cage fatigue.” Additionally, standing and rubbing against wire cages
destroys the health of hens’ feathers and skin, and the birds’ overgrown claws often become
caught in cage wires; they either die where they are trapped, or they have to tear their skin to
escape. You can see all of this by reviewing the videos at EggIndustry.com or
MercyforAnimals.com; it is hard to imagine a life worse than that of a battery caged hen.
The emotional and psychological trauma for hens in cages is similar to that of mother
pigs in gestation crates. Chickens outperform both dogs and cats on tests of cognitive, emotional,
and behavioral complexity. As just one example, University of Bristol researchers have shown
that chickens have the capacity to delay gratification. Reporting on this research, Discovery
Magazine explained: “Chickens do not just live in the present but can anticipate the future and
demonstrate self-control … something previously attributed only to humans and other
primates…” In battery cages, these inquisitive and social animals—who are particularly doting
mothers—have their every natural desire frustrated. They never nest, perch, forage, take a dust
bath, or explore their surroundings. Their lives are categorized by unmitigated mental
suffering—from the moment they’re crammed into a cage until the moment they are torn from it
two years later.
Tail Docking
Obviously, amputation without pain relief is painful. Similarly obvious is the fact that cows need
their tails. Remarkably, some dairy producers continue to chop off cows’ tails with no pain relief
at all. Science proves that this procedure causes the animals’ severe pain and distress and that
without their tails, cattle are subject to increased painful fly strikes. The process continues out of
habit, despite having no support from the American Veterinary Medical Association, Canadian
Veterinary Medical Association, National Mastitis Council, National Milk Producers Federation,
or American Association of Bovine Practitioners. Explains Thomas Quaife, editor of Dairy Herd
Management, “[t]he cumulative body of research on tail docking speaks loudly … The dairy
industry should eliminate the routine practice of docking tails.” Please follow the lead of
California—the number one dairy state in the country—by banning the practice.
Conclusion
Alaska law Sec. 03.55.100(a)(2) provides that “[t]he minimum standards of care for animals
[shall] include . . . an environment compatible with protecting and maintaining the good health
and safety of the animal.” Crates for pigs or calves, cages for hens, and tail docking clearly
create an environment that harms the good health of the animals involved. Sec. 11.61.140(a)(1)
states that “[a] person commits cruelty to animals if the person knowingly inflicts severe and
prolonged physical pain or suffering on an animal.” The systems we’re discussion cause severe
and prolonged physical pain and suffering to the animals involved.
While there exists in the statute a legal escape hatch for systems that “conform[] to
accepted veterinary or animal husbandry practices,” the DEC laudably stated at a public
workshop last February that “the purpose of the standards is to ensure humane care.” If that is the
purpose, cages and isolation crates should be prohibited, as should pointless mutilations.
These are mainstream recommendations. The Pew Commission on Industrial Farm
Animal Production included a former USDA Secretary, a former Kansas governor, and multiple
farmers and ranchers. The commission heard from all sides and reviewed all the research on
housing systems, and its final report recommended a complete phase out of battery cages, veal
crates, and gestation crates. The nation’s largest veal producer has already gotten rid of veal
crates and the industry’s trade group has recommended that all veal producers follow suit. In
2012, the two best-known pork producers—Hormel and Smithfield—promised to stop using
gestation crates by 2017. The United Egg Producers is supporting legislation to phase out battery
cages and Burger King has promised to purchase only from cage-free suppliers by 2017. And
there is no longer a single dairy group that supports chopping off cows’ tails.
Thank you for your attention to these issues; I am at your disposal should you wish to
discuss anything in my letter or anything else with regard to the humane treatment of farm
animals.
Sincerely,
Bruce G. Friedrich
Senior Director for Strategic Initiatives