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1 August 2, 2013 To: the National Farm Animal Care Council Re: Comments on the Draft Pig Code of Practice The Canadian Association of Swine Veterinarians (CASV/ ACVP) was founded in 2003 to bring together veterinarians from across Canada who have a special interest in swine. Membership now includes those in private practice, industry, academia and government. The CASV / ACVP has submitted the following comments through the on line survey: Housing Gestation Sows - As of July 1, 2024, mated gilts and sows must be housed in groups. Individual stalls may be used for up to 28 days after the date of last breeding, and an additional period of up to 7 days is permitted to manage grouping. - For all holdings newly built or rebuilt or brought into use for the first time after July 1, 2014, mated gilts and sows must be housed in groups. Individual stalls may be used for up to 28 days after the date of last breeding and an additional period of up to 7 days is permitted to manage grouping. The committee commented that housing sows in stalls has both positive and negative attributes with respect to animal welfare. For example, aggression between sows in stalls is reduced but the ability to express natural behaviours such as turning around are denied. Housing sows in groups has both positive and negative attributes with respect to animal welfare. For example, sows in groups are able to turn around but fighting may lead to increased pain associated with injury. The committee was unable to identify a clear advantage of stalls over groups or groups over stalls and as such did not agree that the proposed restrictions on the use of stalls should be a requirement at this time. Proper stockmanship skills are important to making either of these systems provide optimum welfare. There was one CASV member that did indicate support for the requirement for the use of group housing after 28 days of gestation. The committee commented that if the proposed restriction of stall housing is approved that movement after 28 days is reasonable but that more flexibility should be allowed for creation of groups. The committee felt that where batch production is used it would be more reasonable to allow 7 to 14 days to create

2 a group. For example, in case of batch farrowing systems one would need a little longer so that the batch is moved all at once. If first sows bred are 28 days post-breeding then last sows might be 42 days post-breeding. The committee commented that if the proposed restriction of stall housing is adopted then the timeline should be delayed so as to allow further research that would allow a better understanding of the various housing systems and especially where retrofitting of existing barns is necessary. - After July 1, 2024, all individual stalls, as well as all new installations and replacements of existing individual stalls that occur after July 1, 2014, must be sized appropriately to allow sows to: Stand up at rest in a stall without simultaneously touching both sides of the stall Lie down without their udders protruding into adjacent stalls Stand up without touching the top bars Stand in a stall without simultaneously touching both ends of the stall The committee agrees with the proposed guidelines for stalls when they are used. The committee agrees that the requirement could go further in stating the following 1. There must be no evidence of trauma to base of tail, hind end, and face. 2. The sow can lie down in a stall without simultaneously touching the feeder at the front end and gate at the back end of the stall Housing Weaned/Grower/Finisher Pig Space Allowances - Pigs must be housed at a space allowance of k = When a short term decrease in space allowance is needed at the end of the production phase: a decrease of up to 15 % for nursery pigs and up to 10% for grower/finisher pigs is allowed; a decrease of up to 20% for nursery pigs and up to 15% for grower/finisher pigs is allowed only if it is demonstrated that the higher densities do not compromise the welfare of the animals as determined by average daily gain, mortality, morbidity and treatment records, as well as the absence of or no increase in vices such as tail biting. The committee requests that the duration of a short-term decrease in space allowance be clarified in order to facilitate an assessment of compliance. The committee requests clarification about the methodology of investigation that will be required to measure the impact of higher density when a decrease in space allowance of 20% for nursery pigs or 15% for grower/finisher pigs is applied. One CASV member suggested that unless randomized, controlled

3 blinded trials were used the validity of the results of an on farm investigation would not be reliable. Housing 1.5 Lighting - Pigs must have access to a darkened area (i.e., ~5 lux or less, with the exception of heat devices in farrowing areas) for at least 6 hours per day (8). The committee proposes that there should be an exception to this rule for newly weaned piglets that would allow that the lights could be left on for 24 hours post-weaning in order to facilitate finding feed and water. A scientific reference for this request could not be located. Feed and Water Weaned/Nursery Pigs: First week - All newly weaned pigs must have continuous access to fresh feed that is presented in such a way that the majority of pigs can eat at one time, and feeder design must be appropriate for the size of the piglets. The committee does not agree that it is necessary for good welfare, nor is it currently a common practice, to have feed presented in such a way that the majority of the pigs can eat at one time. It could be recommended that increased feeder space be made available at weaning if necessary but that it is not a requirement. Animal Health 3.5 On Farm Surgery - On farms where surgeries will be performed, guidance from veterinarians regarding the appropriate techniques of each procedure, pain control, and the need to properly instruct all personnel who will be expected to perform such procedures must be sought. - Stockpersons who perform on-farm procedures must be competent in performing those procedures The committee recommends that there be further definition of what constitutes on-farm surgery. It could be argued that castration and tail docking are surgeries. The committee recommends that some major or invasive surgeries should only be performed by a licenced veterinarian. Eg Caesarian Section, Cryptorchidectomy, Scrotal hernia repair where internal inguinal ring is closed, Umbilical hernia repair The committee recommends that trained farm staff may perform an emergency hysterectomy after a sow is euthanized and is rendered insensible. The committee recommends that trained farm staff may perform a C section with anaesthesia under the supervision of a veterinarian where the sow will be euthanized after the C section is complete.

4 Husbandry Practices 4.1 Handling, Moving, Restraining and Treating Animals - Electric prods must not be used on nursery, distressed, sick or injured pigs (refer to Glossary of Terms for definition of distressed) The committee recommends that it is acceptable to use an electric prod as a last resort when loading pigs out of the nursery. Husbandry Practices Castration Castration performed after 14 days of age must be done with anesthetic and analgesic to help control pain - Stockpersons who perform on-farm procedures must be competent in performing those procedures The committee agreed with the recommendation of 14 days One CASV member felt that that castrations performed after 7 days of age must be done with anaesthetic and analgesic to help control pain. Husbandry Practices Ear notching - Ear notching must only be performed on piglets when deemed necessary and when piglets are less than 14 days of age. The committee agreed with the recommendation of 14 days but would like to see further clarification of the criteria used in determining necessity. One CASV member felt that that ear nothing must only be performed on piglets when deemed necessary and when piglets are less than 7 days of age. Euthanasia 6.3 Methods of Euthanasia Appendix M The committee reviewed the proposed requirements. The committee put more emphasis on the ability of a technique to achieve a successful and highly repeatable outcome when applied by a trained and proficient stockperson. The committee suggests that because a technique may be less practical should not preclude that technique from being acceptable as long as it is able to achieve a successful outcome. The committee recommends that what is most important for any method of euthanasia is: - Education and training of the stockperson including the conditions necessary for use of a technique - Supervision and periodic confirmation of competency by veterinarians - Acceptability of the technique The committee recommends that the requirements would be more clear if they were based on body weights rather than a blend of body weights and stage of production.

5 Blunt Trauma : The committee recommends that blunt trauma should be recognized as an acceptable technique for pigs up to 9 kg in body weight. Electrocution: The committee agrees with the restricted use of electrocution on piglets less than 2.3 kg but recommends that electrocution of 68 kg to 200 kg and mature pigs be allowed as long as the same conditions that are applied for lighter weight pigs are followed. The pig should be properly restrained in a box. The clamps should not cause pain. There is no scientific research that would justify that electrocution should be unacceptable in pigs over 68 kg. This is an area that requires more applied research. CO2 and/or Argon: The committee recommends that the requirement to sedate pigs to the point of unconsciousness be removed from the conditions. A sedative by definition will not produce a state of insensibility and does not provide significant analgesia. At best it could be argued that there may be marginally less distress in the pig. This technique should not be listed as unacceptable for animals greater than 32 kg. The use of this technique in heavier animals should meet the same conditions of effectiveness as prescribed for lighter pigs. The committee recognizes that it may be less practical but not impossible to design equipment for heavier animals. By listing this method unacceptable for pigs over 32 kg it limits the chance for interested parties to develop better techniques or equipment. This is an area that requires more applied research. Penetrating Captive Bolt: The committee recognizes that some penetrating captive bolt equipment may be able to achieve insensibility in heavier animals but are not able to cause cessation of respiration and cardiac function. In these cases a secondary step such as bleeding or pithing will need to be applied prior to the animal regaining consciousness. Where purpose designed equipment is available that provides adequate force to permanently damage the brain stem such that respiration and cardiac function ceases a secondary method would not necessarily need to be applied. Thank you for considering the views of the Canadian Swine Veterinarians in regards to the Pig Code of Practice. Please contact us for any questions. The CASV welfare sub committee, on behalf of the CASV: Dr. George Charbonneau Dr. Karine Talbot Dr. Blaine Tully Dr. Martine Denicourt Dr. Trevor Lank