Judging animal welfare
Re: Supply management and animal welfare (WP, Nov. 5).
One could state that this is a poor reflection of factors that influence dairy cow welfare, and even further that it is a shameful attempt at defending supply management.
Here is my reasoning:
1) Comparison of culling rates and longevity, with no qualification of reasons or health/welfare/productivity with longer lives, is a very poor proxy for animal welfare.
There are many reasons for longevity and culling rates to be different in different countries, particularly economics of cull cows and replacement heifer markets, as well as availability of genetic developments in replacement population.
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2) There are lots of good, hard-working employees on dairy farms that do a very good job for animal care and are proud of the work they do.
The statements in this article are insulting, at best, to the people we employ to care for our cows.
Let’s assume (fairly safely) that larger farms are likely to have hired labour working with the dairy cows. Recent work at University of British Columbia has shown that key metrics of dairy cow welfare do not differ with farm size, and that larger farms may have some advantages in the practices they use, which is contrary to the suggestion of the ability of hired labour in the article.
3) The supply management system does offer one model for funding research and a mechanism for application across the industry. However, recognition must be given to other models, particularly the FARM program south of the border, particularly if it is importing milk from south of the border that we are going to be insinuating.
Currently 93 percent of the U.S. milk supply is evaluated by the FARM program, which is verified by third parties for accuracy and aimed at continuous improvement in dairy cattle welfare. It was also developed using a science-based approach, similar to the National Farm Animal Care Council codes and often using the same science, as well as some of the same people on the advisory group.
Although there are strengths and weakness to both proAction and FARM, we should not be so hasty in assuming that supply management is the best or only model for good farm animal welfare across an industry.
There are many pros and cons to supply management, as well as other milk marketing systems. The points I make are not comprehensive evidence of the effect on animal welfare.
I think it is great that animal welfare continues to be inherent to the dairy industry and a topic we write about in our industry publications.
However, in reflecting on animal welfare implications of importing milk or changing industry structure, a more balanced evaluation would likely benefit our understanding and ability to support good dairy cattle welfare.
Christy Goldhawk
Airdrie, Alta.
Thoughts on MRLs
These are some thoughts regarding a recent article regarding maximum residue limits and grain handling (Clever solution to canola problem, WP, Nov. 12).
Canada is a major player in exports of cereals and oilseeds. Canada is even viewed as a supplier of healthy and unadulterated commodities.
Canadian regulators are very conservative when it comes to the establishment of MRLs for these crops, so other countries look toward those decisions made by Health Canada and often rely on their expertise. Human health is always of top priority in development of MRLs and is based on sound science principles.
MRLs, by design, often incorporate huge margins of safety so the overall risk to human health is negligible.
The article stated that registrations of pesticides for use on canola and other crops may jeopardize the canola industry, so grain companies are implementing their right to restrict acceptance of crops treated with pesticides that have no global MRLs established.
Case in point: Canada and the United States have established MRL for quinclorac on canola at a level of 1.5 ppm. China and Japan have not yet established a residue limit and hence the grain companies do not wish to accept crops treated with quinclorac.
However, Japan has proposed and advanced a 2 ppm MRL on canola. China, while actively updating its own MRL database for internal production, will often resort to the default MRL from the country of origin. So instead of elevating this issue in the media, where assumptions deteriorate reality, companies should rely on sound science to make a more logical and educated decision of the potential risk from grain shipments to international markets.
PRTox analyzed a sample of producers canola yields for residues where quinclorac had been applied. Using LC/MS/MS it was found that residue levels averaged 4.7 ppb, which is approximately 300 times below the Canadian MRL. These values were offset by a single sample of 20.7 ppb where product was applied twice due to an early rain following the first application. Our results are consistent with similar observations noted in a larger data set.
So sound science show that quinclorac residue levels are well below the Canadian and US MRLs.
It is also our understanding that only a small fraction of canola acreage was treated with quinclorac to control cleavers. So when these producer yields are mixed with the other 95 percent of the acreage yields beyond the farmgate it is extremely unlikely that any analytical method would detect residues. Especially since the multiresidue analysis panel method, so often used by enforcement agencies, is less sensitive than our method and would be unable to detect levels above 0.01 p.p.m., rendering the exercise futile.
So international trade is not jeopardized by use of quinclorac that may be used to improve productivity.
Media has a place but even they should utilize sound science when providing (information). Grain handlers should participate in the analysis of samples from elevator batches to determine their true residue level and their potential for risk.
Daniel Bechtel
Saskatoon, Sask.
