In a previous Blog posting on Animal Welfare, we noted that Chicken Farmers of Canada ("CFC") had reached an agreement in July 24, 2012 with all provinces to adopt CFC's animal welfare system (ACP). Only six provinces (BC, AB, SK, MB, ON, PE) have made ACP mandatory for their #ChickenMafia members.
To see what this is all about, we used Ontario as a test case. Anybody can volunteer to do the same for all the other jurisdictions, send it to me, and I will post your results.
Chicken Farmers of Ontario ("CFO") has a new policy to implement ACP. CFO's new Policy 195-2013 for Food Safety & Animal Welfare was passed by the CFO Board on Mar. 7, 2013 and came into force on April 21, 2013. According to this policy, all #ChickenMafia farms in Ontario were to be audited and found to be compliant, or ready to be compliance audited on or before April 20, 2013.
This new policy has a few interesting or questionable features, as follows:
- To have and keep quota allocation (ie. be licensed to produce chicken), the #ChickenMafia member must be compliant with this Policy.
- CFO adopts CFC's On-Farm Food Safety Assurance Program, except that administering of vaccinations and medications to the birds must be documented and reported on Form 3, including those done at the hatchery. According to Regulation 2446-2013, “Form 3” means a Flock Production and Marketing Form completed by a producer prior to processing as prescribed on the form. Under CFO's General Regulation 2422-2013, this Form 3 has to be filed with CFO within 10 business days (ie. 14 calendar days) after the birds arrived at the slaughter plant. If the form(s) aren't filed or filed late, the #ChickenMafia members quota could be reduced by 100 kg. (ie. 50 birds, or $166 in gross sales, or about $30.00 in profit, or 0.2% of gross sales $). In other words, a nuisance wrist slap.
- If you are a brand new #ChickenMafia member, you get to practice on the Ontario public with the first 3 flocks your produce (ie. about 18 weeks, about 4.5 months), and will only be audited at the end of your practice period. Guess where the most mistake and non-compliances are likely to occur? I would think it would be a good idea that somebody from CFO was auditing 100% of the flocks at the beginning, middle, and end of the first three flocks so as to protect the #ChickenMafia member, as well as the public. This seems to be very shortsighted, risky, and questionable practice by CFO.
- CFO places each chicken factory on a 3 year audit schedule. In the first year, CFO audits both the chicken factory and the documents produced and records kept by the site. In year 2, CFO doesn't come to the chicken factory, they just look at the documents & records that are submitted for their inspection. In year 3, CFO doesn't do anything, the #ChickenMafia member just sends CFO a letter telling them that everything is fine, and CFO takes their word for it.
So let's assume that things start to go terribly wrong right after the CFO Auditors leave the chicken factory after Year 1 audit. Of course, in Year 2 the farmer, knowing he is in trouble, will fudge the documents so as to keep CFO in the dark and keep those monthly cheques coming like clockwork. In Year 3, the farmer sends the letter to CFO, and CFO files it. In Year 4, CFO finally comes to the chicken factory and is shocked to see how bad things are.
By that time, 3 years have gone by, and 650,000 chickens have been produced by this renegade farm, and eaten by the public in spite of their questionable quality.
The big issue of course, is the torture that those 650,000 bird might have to suffer through before the renegade #ChickenMafia member is caught. Is that an acceptable risk those chickens are willing to take? Will the animal rights people allow the CFO to put that many birds at risk for that long with little or no hope of being rescued from their fate? To me, this doesn't seem acceptable.
The only additional system is that CFO will randomly select 10% of the #ChickenMafia members who are in Year 2 or Year 3 of the cycle for an on-farm audit. Not very good odds of finding that renegade farm.
In comparison, under the international quality standard ISO 9001 and ISO 16485 which are used to manufacture good like TV's and cars, an annual on-site audit by an independent third party auditor is mandatory. No exceptions. But alas, we're only going to feed the chicken to our family. CFO must assume that the quality of our TV picture is far more important to get right than the quality of chicken.
- If a #ChickenMafia member is found to be non-compliant, a corrective action request can be issued.
- The #ChickenMafia member can appeal an audit result, and get an overturning of audit results in 10 days, or confirmed. I wonder how often that overturning of audit results happens? Sorry, that's top secret too.
- The #ChickenMafia member is required to agree in writing that they will stay compliant to the requirements between audits. A promise easily made, and easily broken; especially when it's 4 years to the next verification audit.
- Unfortunately, there is no requirement for a #CHickenMafia member to inform CFO prior to making any change in their approved process. This has a significant risk associated with keeping CFO in the dark.
- The #ChickenMafia member is only required to keep books and records available for 2 years. What?!? We just showed above that it can be 4 years between on-site auditing. All the past sins can be hidden by disposal of the records just before the auditor shows up for the next on-site audit. The Year 2 audit specifically states that it is a partial or subset audit, not a comprehensive document audit. This appears to be the Achilles' Heel of the CFO compliance and auditing system.
- There is no defined criteria for CFO's auditors. Do they have the attitude, education, skills, and experience to be an effective auditor? Did they receive any training in chickens, and/or auditing? We'll never know, for CFO's system is silent on this issue. For all we know, CFO had an excellent janitor who cleaned the offices, and the next day they were promoted to be Chief Auditor for CFO. Another huge weakness in the system. I suggest all audits and auditors must be done in compliance with ISO 19011:2011 or equivalent.
- If a #ChickenMafia member is unwilling or unable to meet these standards, they can always request to have the requirement waived by the CFO Board by filling in a form. Of course, this is top secret, and nobody is permitted to find out how often this has occurred. Only the CFO Board knows for sure.
CFO's animal welfare system is better than nothing, but has some very significant holes in it, thereby putting the animals, CFO, the #ChickenMafia members, and the public at significant risk.
CFO's system need immediate and significant improvements.
- Are you satisfied with CFO's current system for preventing and/or minimizing the severity and duration of animal abuse within the #ChickenMafia system?
- Do you support the comments and recommendations I have made on CFO's ACP system?
- Do you have additional recommendations for improving CFO's ACP?